PRIVACY & INFORMATION STEWARDSHIP
Discretion is not a feature.
It is the foundation.
For families sharing sensitive health information with Molliora, privacy is not a legal formality. It is a core part of what we provide. This page explains how we handle, protect, and govern the information entrusted to us.
WHAT WE HOLD AND WHAT WE DO NOT
Information Molliora holds
- -Coordination records: correspondence with specialists, appointment history, referral notes
- -Health Passport: summary of family members health profiles, maintained by Molliora and shared with the family
- -Preferences and protocols: communication preferences, emergency contacts, access authorisations
- -Annual review records: plans, priorities, and gaps identified during member reviews
Information Molliora does not hold
- -Primary medical records: these remain with treating physicians and institutions
- -Diagnostic data: scan results, laboratory reports, and clinical notes remain with the issuing institution
- -Insurance or financial data: Molliora is not involved in billing, reimbursement, or insurance claims
- -Biometric data: Molliora does not store or process biometric identifiers
ACCESS AND CONTROL
Who can access your information
Access to member information is restricted by role and by explicit authorisation. No information is shared with any third party without prior written consent from the relevant family member.
Molliora staff access member information only when operationally necessary. All access is logged. Logs are retained for a minimum of three years.
Family members
Each family member can access their own Health Passport and coordination records. Cross-family-member access requires explicit written authorisation.
Health Directors
Assigned Health Directors access only the information required to coordinate care for the families they serve. Access is role-scoped and reviewed quarterly.
Specialists and providers
Information shared with external specialists is limited to what is clinically necessary for the specific engagement, and only with prior family consent.
Third parties
Molliora does not sell, license, or share member data with insurers, pharmaceutical companies, data brokers, or any commercial third party.
STORAGE AND INFRASTRUCTURE
Where information is held
Member data is stored on infrastructure hosted within the European Economic Area, subject to the General Data Protection Regulation (GDPR). Molliora is the data controller for information held in connection with member engagements.
Encryption
All data is encrypted at rest and in transit. Access requires authenticated credentials with multi-factor verification for internal systems.
Retention
Coordination records are retained for the duration of membership and for a defined period thereafter, in accordance with applicable law. Families can request earlier deletion.
Deletion
Upon termination of membership, personal data is deleted or anonymised within 90 days, except where retention is required by law or where the family requests otherwise.
COMMUNICATION CHANNELS
A note on WhatsApp and messaging
Molliora uses WhatsApp for initial contact and logistical coordination because it is the channel families use. However, WhatsApp is not an appropriate channel for sensitive health information. We ask all member families not to share medical details, diagnoses, or test results via WhatsApp or any unencrypted messaging service.
For all substantive coordination, Molliora uses its secure member portal or encrypted email. Your Health Director will guide you on appropriate channels at onboarding.
INCIDENTS AND RIGHTS
Incident response
In the event of a data incident affecting member information, Molliora will notify affected families without undue delay and in accordance with applicable GDPR obligations.
Your rights
Members have the right to access, correct, export, restrict processing of, and delete their personal data. Requests are handled directly by Molliora leadership within 30 days.
Minors
Health information relating to minor family members is handled with additional care. Access is restricted to parents or legally authorised guardians unless otherwise instructed.
Consent
Each family member provides consent for their own information to be held by Molliora. Consent can be withdrawn at any time. Withdrawal does not affect information already shared with treating providers.
QUESTIONS
Privacy questions from members
Any question about how your information is handled should be directed to Molliora leadership directly. We do not route privacy enquiries through automated systems.