Legal
Privacy notice
1. Who we are
OncoPrint is a molecular pathology and genomics laboratory. We perform genomic, molecular and pathology testing on samples referred to us by hospitals, cancer centres, treating clinicians and — where the law permits — individuals directly.
This notice covers the testing service, the reports we issue, and the
websites at oncoprint.ai and
portal.oncoprint.ai.
2. Controller and processor — which one we are depends on how you reached us
The distinction changes who you exercise your rights against, so it is stated first rather than buried.
| How the sample reached us | Our role | Who you ask first |
|---|---|---|
| Referred by a hospital or cancer centre | We act on that organisation's instructions in respect of the clinical record | Your hospital, in the first instance. We will assist them. |
| Arranged directly by you, with your doctor's referral | We determine the purposes ourselves | Us, directly — see section 13. |
In both cases we remain independently responsible for the obligations a laboratory cannot delegate: accreditation, record retention, and the integrity of a report once signed.
3. What we hold
About patients
- Identifiers — name, date of birth, sex, national identification or health-insurance number, and the accession number we assign to the case.
- Contact details, where you or your clinician give them, so a result can be discussed.
- Clinical information supplied with the order — diagnosis, specimen type and site, prior treatment, and the question the test is meant to answer.
- Health and genetic data — the sequencing, molecular, immunohistochemistry and in-situ hybridisation results; whole-slide images; variant interpretations; and the report itself. Genetic data is sensitive in a way most personal data is not: it can imply things about your relatives, and it cannot be reissued if it is exposed.
- Billing information, including the claim codes derived from the assays actually performed.
About people who use the portal
- Your username, role, organisation, and the professional registration recorded against a sign-out where the role has one.
- An audit record of every action — what was done, by which account, from which address, and when. This is not optional and cannot be switched off; a laboratory record whose history can be deleted is not a laboratory record.
About people who write to us
What you type into the enquiry form, plus the address it was sent from so a flood can be blocked. The form asks you not to include patient-identifying details, and we will reply with a secure route before you send any.
4. Why we hold it
- To perform the test that was ordered and issue a report that can be acted on clinically.
- To make sure the result is attached to the right patient. Most of the identifying data we hold exists for this reason alone.
- To meet the quality obligations of an accredited laboratory — validation, external quality assessment, and the ability to reconstruct how any given result was produced.
- To bill for the work, including claims to BHYT where they apply.
- To keep the platform secure and to investigate misuse.
5. Our lawful basis
Under Decree 13/2023/ND-CP, health and genetic data are sensitive personal data and generally require your explicit consent, obtained separately from any other agreement. We rely on:
- Your consent, given to us or to your treating clinician on our behalf, for testing and for reporting the result to the clinician who ordered it.
- Performance of a contract with the hospital or with you, for the testing service itself.
- Legal obligation, for record retention, accreditation and mandatory reporting.
- A separate, specific, withdrawable consent for any research use — see section 10. Withdrawing it does not affect your testing or your report.
6. Who it is shared with
- The clinician who ordered the test, and the hospital or centre they work for.
- You, where you are entitled to your own result.
- Our molecular tumour board, where a case is referred for review before release.
- BHYT and insurers, limited to what a claim requires.
- Regulators and accreditation bodies, where they have a legal right of access.
- Reference laboratories, where an assay we do not hold in scope is sent out. You are told when this applies to your case.
We do not sell personal data, and we do not use it for advertising. Isolation between organisations is enforced at the database row, not by a filter in application code: a query made under one hospital's session returns nothing for another's patients, even by primary key.
7. How long we keep it
| What | How long | Why |
|---|---|---|
| The signed report and the case record | The statutory medical-record retention period, and not less than 10 years | Legal obligation; and a genomic result stays clinically relevant for years |
| Raw sequencing data and slide images | Per the retention schedule for the assay | Reinterpretation as evidence changes, and quality investigation |
| Residual specimen material | Per the specimen retention schedule, then destroyed | Repeat and confirmatory testing |
| The audit log | With the record it describes | A record whose history is shorter than the record is not auditable |
| Enquiries sent through this website | 24 months | To answer, and to follow up |
A signed report is immutable. A correction is issued as an amendment that names what changed and why; the original is not overwritten, because a clinical decision may already have been made on it.
8. How it is protected
- Encryption in transit; access over authenticated sessions only.
- Role-based authorisation, enforced centrally rather than per screen — only a pathologist may sign out a case, and the software refuses it for anyone else.
- Row-level isolation between organisations, at the database.
- An append-only audit trail of every action.
- One live session per account: signing in ends the others, and the count is shown so a shared password is noticed.
No system is perfectly secure. If a breach affects your data we will notify you and the regulator as the law requires.
9. Your rights
Subject to Decree 13/2023/ND-CP and to the limits below, you may ask to access your data, correct it, receive a copy, restrict or object to processing, withdraw consent, or complain.
Two limits are real and we would rather state them than surprise you:
- Erasure is limited. We cannot delete a signed diagnostic record we are legally obliged to retain, and we would not do so even on request — a missing result is a clinical hazard to you.
- Correcting a report is an amendment, not an edit. See section 7.
Where a hospital referred you, ask them first; we will help them answer. We respond within the statutory period and do not charge for a first request.
10. Research, and the de-identified corpus
We may hold a de-identified research corpus to improve assays and interpretation. Three commitments:
- It is opt-in and separately consented. Declining changes nothing about your test or your report.
- Consent is withdrawable, and a record can be withdrawn from the corpus afterwards.
- De-identification is treated as reducing risk, not eliminating it. Genomic data is inherently difficult to anonymise completely, and any claim that it has been made anonymous forever would be false. Where our tooling cannot decide whether something is identifying, it is treated as identifying and a person reviews it.
11. This website
We use no analytics, no advertising, and no third-party trackers. The public site loads nothing from another company's servers — no fonts, no scripts, no tag managers — so visiting it does not disclose you to anyone but us.
The portal sets one strictly necessary cookie, which holds your session. It is not used for tracking, and the site cannot function without it. There is no cookie banner because there is nothing to consent to.
Our sites are delivered through a content-delivery network, which processes connection data (including your IP address) to serve the page and to mitigate attacks.
12. What is still open
Stated plainly, so nobody relies on something we have not finished:
- Legal review against Decree 13/2023/ND-CP, and registration or impact-assessment filings where required.
- The registered legal entity name, address and business registration number, which will appear in section 13.
- The named data protection contact.
- The exact retention periods per assay, once the retention schedule is approved.
- A Vietnamese translation. Where the two differ, the Vietnamese text will govern for patients in Vietnam.
13. Contacting us
Write to us through the enquiry form and mark it for the data protection contact. Do not include patient-identifying details in that form; we will reply with a secure route.
If we cannot resolve your concern, you may complain to the competent authority for personal data protection in Vietnam.
If a clinical question is urgent, telephone the laboratory rather than writing.