Privacy is part of the operating model.

Introduction and scope

Sequrin is a healthcare claims-integrity technology platform designed to help medical schemes and authorised claims-integrity teams identify unusual activity, understand relationships between claims and relevant entities, and conduct structured, human-led investigations.

This Privacy Policy applies to the public website at sequrin.tech, the authenticated Sequrin service, pilot projects and controlled evaluations, communications with Sequrin, and the administration, security and operation of the service.

Sequrin is currently an unincorporated project operated by Sbusiso Mdingi. References to “Sequrin”, “we”, “us” or “our” mean Sbusiso Mdingi operating the Sequrin project and service.

This policy is intended to operate in accordance with the Protection of Personal Information Act 4 of 2013 (“POPIA”), applicable regulations issued under POPIA, including the Regulations relating to the Processing of Data Subjects' Health Information by Certain Responsible Parties, 2026, and other applicable South African law.

Responsible Party and Operator roles

Sequrin's role depends on the processing context.

Sequrin may act as a Responsible Party where it determines the purpose and means of processing, including for website visitors, business contacts, prospective customers and partners, authorised application users, and security, administrative or support records processed for Sequrin's own purposes.

Where a medical scheme, administrator or other authorised customer provides personal information to Sequrin for claims-integrity analysis or investigation, that customer will ordinarily determine why the information is processed. In that context the customer will ordinarily be the Responsible Party and Sequrin will ordinarily act as an Operator, processing the information only under lawful customer instructions, applicable agreements and applicable law.

Sequrin does not obtain independent ownership of customer personal information merely because the information is processed through the platform.

Information Officer

Sequrin's Information Officer is Sbusiso Mdingi.

Privacy enquiries may be sent to sbusiso@sequrin.tech.

Do not send patient records, medical-scheme claims, member information, clinical records, investigation evidence, passwords or other sensitive information to this address unless Sequrin has expressly provided an authorised secure method for doing so.

Information Sequrin may process

Depending on the service and customer scope, Sequrin may process medical-scheme membership and dependant identifiers; claim and transaction references; provider and healthcare-practitioner identifiers; facility information; dates and times of treatment or claims activity; benefit, tariff, procedure and service information; diagnoses or other health-related claim information; claim amounts and associated financial information; relationships between members, dependants, providers, facilities and claims; historical claims activity; and customer-supplied reference data.

Sequrin may also generate or store analytical observations, anomaly indicators, model outputs, investigative signals, prioritisation information, relationship analysis, investigation notes, evidence references, chronology, case status, human-recorded findings and audit records.

For authorised application users, Sequrin may process names, work email addresses, organisation, account status, authentication and session information, assigned roles, permissions, administrative actions, access history, security events and other activity required to maintain an auditable service.

Infrastructure may process ordinary technical and security information such as IP addresses, access times, client information, authentication events, application events, errors and server or security logs.

Where information comes from

Information may be obtained directly from a Data Subject, from a customer using Sequrin, from an administrator or other party authorised by the customer, from authorised users, from customer-approved reference data, from activity generated through authorised use of the platform, from communications sent to Sequrin, or from infrastructure and security systems used to operate the service.

Where Sequrin acts as an Operator, the customer is responsible for ensuring that it is authorised to provide the information to Sequrin and to instruct Sequrin to process it.

Why information is processed

Personal information may be processed to provide and secure the service; authenticate users; enforce organisational and role-based access; analyse claims for authorised claims-integrity purposes; identify unusual activity; generate investigative signals; analyse relationships; support human-led investigations; record evidence, chronology and investigation activity; preserve auditability; provide support; conduct controlled evaluations; administer customer and prospective-customer relationships; respond to requests; establish or defend legal rights; and comply with legal or regulatory obligations.

Sequrin will not process customer information for an unrelated purpose merely because the information is technically available to the platform.

Customer claims data is not used to train Sequrin's own general models

Sequrin does not use identifiable or pseudonymised customer claims data, investigation data or other customer-controlled personal information to train, fine-tune, benchmark, develop or improve Sequrin's own general models or models intended for use across customers.

Customer data may be processed by analytical methods within the service where necessary to provide the agreed service to the customer that supplied or controls the information. That does not authorise Sequrin to reuse the data for independent model-development purposes.

Product development, testing and general model development may instead use synthetic data, lawfully obtained non-customer datasets, genuinely de-identified information that cannot reasonably be linked back to a Data Subject, and permitted non-sensitive service telemetry or feedback.

Pseudonymised information is not treated as de-identified merely because direct identifiers have been removed.

Health and other Special Personal Information

Claims information may contain health information and other Special Personal Information protected under POPIA. Sequrin recognises the heightened sensitivity of this information and processes it only for authorised and defined purposes, subject to customer instructions where applicable, confidentiality obligations, reasonable technical and organisational safeguards, and applicable South African law.

Claims-integrity work may also involve allegations, suspicions or information potentially relating to unlawful or criminal behaviour. The existence of an anomaly, signal, network connection, allegation or investigation does not mean that misconduct has been established.

Children and dependant information

The Sequrin application is intended for authorised professional and organisational users and is not directed at children. Medical-scheme claims may nevertheless lawfully include information relating to child dependants.

Sequrin may process such information where it forms part of customer-controlled claims data and the relevant Responsible Party is lawfully authorised to process it. Sequrin does not treat a child appearing in claims data as a user of the service and does not independently solicit healthcare information from children through the public website.

Analytical processing and human decision-making

Sequrin may use rules, statistical methods, analytical models and relationship analysis to identify activity that deserves closer examination. These systems may generate anomalies, scores, patterns, relationships, prioritisation information or investigative signals.

A Sequrin signal does not, by itself, establish fraud or misconduct, reject or delay a claim, withhold or redirect payment, recover money, impose a sanction, terminate a provider or member relationship, make a criminal allegation, or publish a person or organisation into a shared warning network.

Consequential conclusions and actions remain subject to the customer's authorised human and organisational processes. Sequrin is designed so analytical detection does not independently exercise claims-adjudication, sanction or publication authority.

Secure Integrity Network and cross-organisation sharing

Sequrin's current claims-integrity operating model is based on controlled organisational and customer boundaries. Sequrin does not operate an unrestricted national fraud blacklist, and information belonging to one customer is not made available to another merely because both organisations use Sequrin.

Any future Secure Integrity Network functionality involving cross-organisational integrity information will require additional governance before implementation, including lawful purpose, defined roles, information minimisation, evidence and publication standards, access controls, correction and challenge mechanisms, auditability, contractual arrangements, Special Personal Information requirements and any applicable prior-authorisation obligations.

Lawful processing

Where Sequrin acts as a Responsible Party, personal information will only be processed where permitted by POPIA and applicable law. Depending on the circumstances, processing may be justified by consent where appropriate, contractual necessity, a legal obligation, protection of a legitimate interest, performance of an applicable public-law duty, or legitimate interests where permitted by POPIA.

Where Sequrin acts as an Operator, the customer is responsible for establishing the lawful basis and purpose for processing customer-controlled information. Sequrin processes that information within the authority granted by the customer and applicable law.

Disclosure and service providers

Sequrin does not sell personal information. Customer data may be made available to appropriately authorised users of the relevant customer under organisational, role and permission controls.

Sequrin may use carefully selected service providers to operate, secure or support the service. The authenticated Sequrin platform uses Amazon Web Services (AWS) for cloud infrastructure. Service providers receive only information reasonably necessary for the relevant service and are subject to appropriate contractual, confidentiality and security requirements where required.

Information may also be disclosed to professional advisers under appropriate confidentiality obligations, to legal or regulatory authorities where lawfully required, or to a recipient that the relevant Responsible Party lawfully instructs Sequrin to use.

Hosting and international transfers

The authenticated Sequrin platform uses AWS cloud infrastructure. The specific AWS region, service configuration and processing location applicable to a customer deployment may be documented in the relevant customer agreement, technical documentation or subprocessor information.

Sequrin does not assume that use of a cloud provider automatically means all information remains inside South Africa. Where personal information is transferred to a recipient outside South Africa, the transfer must satisfy applicable POPIA requirements, including section 72 where relevant.

Where Sequrin acts as an Operator, international transfers of customer data will be carried out only in accordance with the customer's lawful instructions, applicable contractual safeguards and applicable law.

Security

Sequrin applies reasonable technical and organisational safeguards appropriate to the nature and sensitivity of the information processed. The security approach is intended to protect information against loss, damage, unauthorised destruction, unauthorised access, unlawful processing, unauthorised alteration and unauthorised disclosure.

Controls may include organisational and tenant boundaries, role-based access controls, restricted administrative privileges, authentication controls, access and activity logging, audit trails, secure cloud infrastructure, security monitoring, protected backups, vulnerability and dependency management, controlled development and deployment processes, and confidentiality obligations.

No information-security system can eliminate every risk. Sequrin therefore maintains safeguards intended to reduce risk, identify security incidents and support an appropriate response.

Security compromises

Where Sequrin acts as an Operator and there are reasonable grounds to believe customer-controlled personal information has been accessed or acquired by an unauthorised person, Sequrin will notify the relevant Responsible Party as required by POPIA and the applicable agreement.

Where Sequrin acts as the Responsible Party, Sequrin will notify the Information Regulator and affected Data Subjects where and in the manner required by applicable law. Sequrin will also take reasonable steps to investigate the incident, limit continuing unauthorised access, mitigate foreseeable harm, preserve evidence and address identified weaknesses where appropriate.

Retention and deletion

Sequrin follows the principle that personal information should not be retained for longer than necessary for the purpose for which it is processed, subject to legal, contractual, evidentiary and regulatory requirements.

Customer claims and investigation data remain controlled by the relevant customer. Unless an applicable customer agreement, legal obligation, preservation requirement or lawful customer instruction provides otherwise, customer data will be retained while required to provide the service and, after termination or a valid deletion instruction, will ordinarily be scheduled for deletion from active systems within 90 days. Protected residual copies may remain in backups for up to a further 90 days before being overwritten in the ordinary backup lifecycle.

Application-user, administrative, security and general platform audit records may ordinarily be retained for up to 24 months after the relevant relationship or event, unless longer retention is reasonably necessary for a legal claim, audit, investigation, security incident or regulatory process. Ordinary business correspondence may ordinarily be retained for up to 24 months after the last substantive interaction.

Information that has genuinely been de-identified so that it is no longer reasonably capable of identifying a Data Subject may be retained for longer. Pseudonymised customer data is not treated as de-identified for this purpose.

Data Subject rights

Subject to POPIA and other applicable law, a Data Subject may have rights to ask whether a Responsible Party holds personal information relating to them; request access; request correction; request deletion or destruction where retention is no longer authorised; object to certain processing; withdraw consent where consent is the relevant basis; object to direct marketing; lodge a complaint with the Information Regulator; and exercise other rights provided by law.

Sequrin may require reasonable proof of identity before acting on a request. Rights may be subject to lawful limitations, including confidentiality, third-party rights, legal claims, investigations, statutory retention and applicable access-to-information legislation.

Requests about customer-controlled information

Where Sequrin processes information solely as an Operator, the relevant customer is ordinarily the appropriate organisation to determine and respond to a Data Subject request. For example, a medical-scheme member seeking access to or correction of claims information should ordinarily contact the medical scheme or other Responsible Party.

Where appropriate and required, Sequrin will assist the customer in responding to requests concerning information processed through the service. Sequrin will not independently amend, delete or disclose customer-controlled claims or investigation records contrary to the lawful instructions of the Responsible Party.

Public website

The public Sequrin website is primarily informational. As at the date of this policy, Sequrin does not intentionally use advertising trackers, behavioural advertising technology, third-party advertising cookies or non-essential analytics cookies on the public website.

Hosting, content-delivery, security and network infrastructure may nevertheless process ordinary technical request information, such as IP address, request time, requested resource and security-related information, where necessary to deliver and protect the website.

If Sequrin later introduces non-essential cookies, analytics or similar tracking technology, this policy and any legally required consent mechanism will be updated accordingly.

Email communications

Sequrin email addresses are intended for ordinary business, privacy, partnership, security and service communications. Do not send patient information, healthcare claims, clinical records, investigation evidence, passwords or authentication credentials through an ordinary public email address unless Sequrin has specifically authorised that transmission method.

Sequrin does not currently operate a programme of unsolicited electronic direct marketing as part of the service. If direct electronic marketing is introduced in future, it will be conducted only where permitted by applicable law and with an appropriate means of opting out.

No sale of personal information

Sequrin does not sell, rent or trade customer claims data, health information or other personal information to data brokers, advertisers or unrelated third parties. Sequrin does not use medical-scheme member information for advertising.

Changes to this policy

Sequrin may update this policy to reflect changes to the service, processing activities, subprocessors or infrastructure, applicable law or regulatory guidance, new functionality, or changes to Sequrin's organisational structure.

Where a change is material, Sequrin will take reasonable steps to make the updated policy available and, where appropriate, notify affected customers or users. If Sequrin becomes incorporated or the legal entity responsible for the service changes, this policy will be updated to identify that entity.

Contact Sequrin

Information Officer: Sbusiso Mdingi
Email: sbusiso@sequrin.tech

General enquiries may be sent to info@sequrin.tech. Please do not include sensitive healthcare or claims information in an initial email.

Information Regulator

A Data Subject has the right to lodge a complaint with the Information Regulator (South Africa) where they believe personal information has been processed in contravention of POPIA.

Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, South Africa
Postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017
Telephone: 010 023 5200
Email: enquiries@inforegulator.org.za

Governing privacy principles

Sequrin's privacy approach is based on purpose limitation, minimality, confidentiality, organisational boundaries, human accountability, traceability and governed collaboration.

Signals are not verdicts. Analytical output may identify activity warranting investigation but does not establish misconduct.

No hidden secondary training. Identifiable or pseudonymised customer data is not repurposed for Sequrin's own general model training or improvement.

Governed collaboration. Cross-organisation sharing requires a separate lawful and accountable process.

These principles form part of Sequrin's intended operating model and not merely its public communications.