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Data Processing Addendum (Overview)

Last updated: January 16, 2026

1. Purpose

This Data Processing Addendum (“DPA”) describes in greater detail how Health Network Continuum, LLC. (“HNC”) processes personal data and protected health information on behalf of its clients, partners, and affiliated healthcare organizations. It outlines the responsibilities, obligations, and safeguards that govern the handling of such data when HNC provides TeleHealth, remote patient monitoring, care coordination, and related digital health services. The DPA is intended to ensure transparency, compliance with applicable privacy and data protection laws, and alignment with industry best practices for handling sensitive health information.

This overview is provided for informational purposes and summarizes key principles that guide our data processing activities. In situations where a formal, signed Data Processing Addendum, Business Associate Agreement (“BAA”), or other contractual document exists between HNC and a client, the terms of the signed agreement will take precedence. Those agreements may include additional obligations, restrictions, or requirements tailored to the specific services provided or the regulatory environment in which the client operates.

2. Roles of the Parties

HNC generally acts as a “processor” under data protection laws or as a “business associate” under HIPAA when handling personal data and protected health information on behalf of healthcare providers, health plans, medical groups, and other covered entities or controllers. In this role, HNC processes data strictly according to the documented instructions of the client and does not determine the purposes or means of processing.

Clients, such as healthcare organizations or administrative partners, act as the “controller” or “covered entity,” retaining responsibility for determining how and why personal data is processed. HNC supports these entities by providing secure technology platforms, infrastructure, and operational tools that enable them to deliver clinical services, manage patient populations, and fulfill regulatory obligations.

3. Subject Matter and Duration

The subject matter of this DPA concerns the processing of personal data and protected health information necessary for HNC to deliver TeleHealth, remote patient monitoring, and related digital health services. This includes data required to support clinical workflows, communication between patients and providers, device integration, and operational reporting.

HNC processes personal data only for the duration of the applicable service agreement or as otherwise required to fulfill legal, regulatory, or contractual obligations. Once the service relationship ends, HNC will cease processing data except as necessary to complete secure return or deletion procedures, resolve outstanding obligations, or comply with mandatory retention requirements under applicable law.

4. Nature and Purpose of Processing

The processing activities performed by HNC are designed to support the delivery of high-quality TeleHealth and remote monitoring services. These activities may include the secure collection of patient-generated data, storage of clinical information, transmission of data between authorized users, and analysis of trends or metrics to support clinical decision-making. HNC may also display relevant information within dashboards, reports, or communication tools used by healthcare providers and administrative personnel.

Processing activities may include collection, storage, transmission, analysis, and display of health-related and administrative data to support:

  • Remote patient monitoring and continuous health data collection;
  • TeleHealth encounters, including virtual visits and digital communication;
  • Care coordination, clinical workflows, and provider-to-provider collaboration;
  • Quality improvement, operational analytics, and performance reporting.

5. Categories of Data Subjects and Data

Categories of data subjects may include individuals whose information is processed as part of the services provided by HNC. These groups typically include:

  • Patients and members receiving TeleHealth or remote monitoring services;
  • Healthcare providers, clinicians, and care team members who interact with the platform;
  • Administrative users, support personnel, and authorized organizational staff.

Categories of data may include a broad range of information necessary to support clinical and operational activities, such as:

  • Identification and contact information, including names, addresses, and communication details;
  • Health-related information, monitoring data, clinical notes, and care plan details;
  • Usage, technical, and device data related to platform access, performance, and security.

6. Security Measures

HNC implements a comprehensive set of technical and organizational safeguards designed to protect personal data and PHI from unauthorized access, disclosure, alteration, or destruction. These measures include role-based access controls, multi-factor authentication, encryption of data in transit and at rest where appropriate, and continuous monitoring of system activity to detect anomalies or potential threats.

In addition, HNC conducts regular security assessments, vulnerability testing, and policy reviews to ensure ongoing compliance with legal, regulatory, and contractual requirements. Our security program is aligned with industry standards and incorporates administrative, physical, and technical controls to maintain the confidentiality, integrity, and availability of sensitive information.

7. Subprocessors

HNC may engage carefully selected subprocessors to support the delivery of its services. These subprocessors may include cloud hosting providers, communication platforms, analytics tools, and other vendors that provide essential infrastructure or functionality. Each subprocessor is evaluated for security, compliance, and reliability before being granted access to any personal data.

HNC maintains written agreements with all subprocessors that impose data protection obligations consistent with this DPA, applicable law, and industry best practices. Clients may request a list of current subprocessors and will be notified of material changes in accordance with contractual requirements.

8. Data Subject Requests

When HNC receives a request from a data subject—such as a request to access, correct, restrict, or delete personal data—HNC will evaluate the request and, where appropriate, refer it to the relevant client or covered entity. Because HNC acts as a processor or business associate, the client typically determines how such requests should be handled.

HNC will assist clients in responding to data subject requests in accordance with applicable laws, contractual obligations, and the technical capabilities of the platform. This may include providing relevant data, implementing requested changes, or supporting secure data export or deletion processes.

9. International Transfers

If personal data is transferred across national borders, HNC will implement appropriate safeguards to ensure that the data remains protected in accordance with applicable data protection laws. These safeguards may include the use of standard contractual clauses, data transfer agreements, or other legally recognized mechanisms designed to maintain an adequate level of protection.

HNC evaluates international data transfer requirements on an ongoing basis and updates its practices as necessary to comply with evolving regulatory standards and client expectations.

10. Return or Deletion of Data

Upon termination or expiration of services, HNC will return or securely delete personal data processed on behalf of clients, in accordance with the terms of the service agreement, this DPA, and applicable law. Clients may request data exports, archival copies, or other retrieval options as permitted by the agreement.

Data may be retained beyond the termination date only when required by law, regulatory obligations, or legitimate business needs such as audit logs or security records. Any retained data will continue to be protected under the same security and confidentiality standards described in this DPA.

11. Contact

For questions about this DPA overview, to request additional details, or to obtain a signed DPA tailored to your organization, please contact us using the information below. Our team is available to support compliance reviews, vendor assessments, and contractual documentation needs.

Health Network Continuum, LLC.
10 East 40 Avenue, Suite 1055
New York, NY 10015
Email: info@healthnetworkcontinuum.com

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