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Data Security & Ephemeral Infrastructure Governance

PRIVACY POLICY

Effective Date: May 24, 2026 • Last Updated: August 27, 2026

At Elite Data Solutions (the "Company", "we", "us", or "our"), we enforce an institutional Privacy-by-Design and Zero Data Retention (ZDR) architecture engineered specifically for hospital systems, healthcare legal counsel, and healthcare advisory firms subject to federal price transparency compliance mandates.

This Policy governs how public price transparency datasets, corporate account metadata, and ephemeral compute environments are processed and secured across our platform.

1. STRICT HIPAA EXEMPTION & ZERO-PHI SAFEGUARDS

Our infrastructure evaluates exclusively institutional standard charges, gross charges, CPT/HCPCS coding taxonomies, and payer-negotiated rate matrices mandated for unencumbered public disclosure under 45 CFR Part 180.

  • Zero PHI Ingestion: Under no circumstances do our systems request, ingest, parse, or store Protected Health Information (PHI) as defined under HIPAA.
  • No Patient Records or Claims: The platform contains structural ingestion blocks preventing the submission of patient health records, clinical charts, or consumer identifiers.
  • Statutory BAA Exemption: Because platform operations are restricted to public rate matrices, neither party operates as a HIPAA Covered Entity or Business Associate in connection with price transparency data processing. Execution of a Business Associate Agreement (BAA) is legally inapplicable to public MRF engagements.
Regulatory Dimension 45 CFR Part 180 Public Hospital Data 45 CFR § 160.103 Protected Health Information EDS Safeguards
Data Scope Gross charges, CPT/HCPCS, negotiated rates Individually identifiable health data, claims Exclusively parses public rate matrices
Patient Identity Strictly absent (Institutional public data) Mandatory connection to individual identity Zero patient identifiers accepted
Public Access Mandatory unencumbered public availability Strictly confidential & restricted access Fetches from public hospital URLs
HIPAA BAA Status Commercial Terms of Service apply Business Associate Agreement mandatory BAA non-required; zero HIPAA liability

2. TWO-TIER ARCHITECTURAL PRIVACY MODEL: EPHEMERAL PROCESSING VS. STATUTORY PUBLIC CDN HOSTING

In enterprise SaaS systems, private compliance processing and public statutory publishing represent distinct architectural layers. We strictly delineate the two tiers:

Tier 1: Ephemeral Diagnostic Audit & Remediation Pipeline (100% Volatile RAM & Zero Retention)

All file parsing, 40+ Point Federal Schema validation, syntax diagnostics, and Chargemaster/ERA remittance reconciliations execute strictly inside volatile server RAM and ephemeral scratch containers. Uploaded datasets and intermediate audit matrices are automatically expunged and cryptographically wiped within ≤24 hours of session completion, with zero data written to persistent databases or system backups. Customer hospital files are never used to train machine learning models, LLMs, or AI algorithms.

Tier 2: Client-Elected Statutory Public CDN Hosting (Dedicated Public Delivery Endpoint)

Under 45 CFR § 180.50, hospitals are federally required to host their finalized MRF publicly on an accessible web endpoint without user accounts, passwords, or fees. When an enterprise client elects our statutory hosting service, EDS provisions a dedicated high-availability public Content Delivery Network (CDN) endpoint solely for their finalized, public MRF for the subscription duration. The ephemeral pipeline (Tier 1) never retains private processing data, while the public CDN (Tier 2) hosts exclusively the client's publicly mandated final MRF.

  • Ephemeral RAM Execution: All schema parsing, 40+ Point Federal Schema validation runs, and rate normalization routines execute exclusively in volatile server RAM within isolated containers.
  • Zero Data Retention (ZDR) • ≤24-Hour Cryptographic Purge: Uploaded pricing matrices and chargemasters are held in system memory strictly during active audit execution and are automatically expunged within 24 hours. No customer datasets are written to persistent databases.
  • Express Zero AI Model Training Guarantee: Elite Data Solutions contractually covenants that customer hospital files, proprietary rate matrices, and chargemaster datasets are never used to train, tune, or validate machine learning models, large language models (LLMs), or artificial intelligence algorithms.
  • Multi-Tenant Advisory Sandbox Isolation: Workloads executed on behalf of advisory partners run in logically isolated micro-containers governed by Linux kernel namespaces, cgroups, and non-root process restrictions, eliminating cross-tenant data indexing or memory leakage.

3. B2B CORPORATE METADATA & STATUTORY LEGAL BASES

We collect only minimal non-sensitive B2B corporate and operational metadata strictly necessary to manage enterprise accounts and deliver compliance workpapers:

  • Corporate Account Identifiers: Work email address, enterprise name, professional title, and hashed authentication credentials (processed under GDPR Art. 6(1)(b) Contractual Necessity).
  • Administrative & Audit Records: SOW tracking numbers, corporate billing coordinates, and seat license utilization logs (processed under GDPR Art. 6(1)(c) Legal Obligation).
  • System Telemetry & Institutional URLs: Target hospital website URLs, direct links to public MRFs, execution timestamps, and API diagnostic traces (processed under GDPR Art. 6(1)(f) Legitimate Interests).
  • CCPA / CPRA Service Provider Certification: Elite Data Solutions acts strictly as a commercial B2B service provider. We do not sell or share business contact data for cross-context behavioral advertising.

4. ADVISORY PARTNER CLIENT CONFIDENTIALITY & NON-DISCLOSURE

  • Fiduciary Client Secrecy: Hospital client names, audit ledgers, and rate benchmarks processed on behalf of Advisory Partners are treated as strict commercial trade secrets and confidential information.
  • No Third-Party Sharing: Elite Data Solutions will never sell, lease, disclose, or distribute Advisory Partner client files or hospital pricing models to third-party data brokers, insurers, or marketing vendors.

5. ENTERPRISE CRYPTOGRAPHIC STANDARDS & ACCESS CONTROLS

  • In-Transit Encryption: All communications enforce TLS 1.3 encryption with Perfect Forward Secrecy and HTTP Strict Transport Security (HSTS). Legacy TLS versions are disabled.
  • At-Rest Cryptography: Public pricing catalogs, schema dictionaries, and static assets hosted on CDNs are encrypted at rest using AES-GCM-256 with FIPS 140-3 validated Hardware Security Module (HSM) key management.
  • Identity & Access Controls: System access enforces SAML 2.0 / OIDC Single Sign-On (SSO), mandatory Multi-Factor Authentication (MFA), and strict Role-Based Access Control (RBAC).

6. INCIDENT RESPONSE, 72-HOUR BREACH SLA & AUDITABILITY

  • 72-Hour Breach Notification: In the event of a confirmed security incident impacting platform infrastructure or corporate account metadata, EDS will formally notify affected enterprise clients within seventy-two (72) hours.
  • Independent Compliance Verification: System isolation boundaries and ephemeral security controls undergo annual SOC 2 Type II examinations and third-party penetration testing. Attestations are made available to enterprise counsel upon request.

7. GOVERNING LAW & PRIVACY OFFICER CONTACT

This Privacy Policy is governed by the laws of India, with dispute resolution seated in New Delhi under UNCITRAL rules. For data governance questionnaires, security whitepapers, or SOC 2 verification packages, contact: sru@elitedatasolution.net.