Data Handling Plan

Model Ortho (operated by Anita Brown through Freedom in Honesty LLC)

1. Purpose

This plan describes how Model Ortho collects, uses, stores, and disposes of client data during a consulting engagement.

2. What We Collect

We work with operational practice data only, such as:

• Schedule and booking data
• Production and collection figures
• Capacity, staffing, and provider-hours data
• Historical practice metrics needed for modeling

We do not collect, request, or store patient-identifying information, including names, dates of birth, chart numbers, contact details, or protected health information (PHI).

3. Clean-Room Principle

Modeling and forecasting run on aggregate and de-identified operational data. Protected health information is not required for the work and is excluded by design.

If PHI ever becomes necessary for a specific engagement, the Client will be asked to sign a written acknowledgment, and the information will be handled in accordance with applicable privacy law and the Client's direction.

4. Storage and Access

• Client data is stored in access-controlled locations, including the Model Ortho client portal and encrypted cloud storage.
• Access is limited to Anita Brown for the duration of the engagement.
• Client data is not shared with third parties without the Client's written consent.

5. Retention and Deletion

• Client data is retained only for the term of the engagement.
• On completion or termination, working data is returned to the Client or securely deleted at the Client's direction.
• Final deliverables (the Outlook and the Schedule Canvas) are provided to the Client for its internal use.

6. Security

• Access controls are applied to all storage locations.
• The client portal stores no protected health information.
• Cyber liability coverage is being secured; certificates will be provided upon issuance.

7. Breach Response

If any unauthorized access or disclosure of Client data is discovered, the Client will be notified promptly.

8. Advisory Nature

All services are advisory. Model Ortho does not make clinical decisions and does not provide medical, legal, tax, or accounting advice.