Data processing agreement
Pursuant to Art. 28 GDPR, between the submitting veterinary practice (controller) and Equipixel Veterinary Teleradiology (processor).
1. Subject matter and duration
The processor provides teleradiology reporting services to the controller through the portal at https://portal.equipixel.com, for the duration of the business relationship.
2. Nature, scope and purpose
Case data submitted by the controller is processed for the purpose of producing radiology reports and invoicing the service provided.
3. Types of data and categories of data subjects
Data: imaging data including DICOM header fields, patient (animal) name, species, breed, age, sex, owner's name, history and clinical question, name and contact details of the referring veterinarian, practice address and billing details.
Data subjects: practice staff and owners, referring veterinarians, and animal owners whose names appear in the submitted data.
4. Obligations of the processor
- Processing only on documented instructions from the controller.
- Confidentiality undertakings from everyone with access.
- The technical and organisational measures set out in Annex 1.
- Assistance with data subject requests and with Art. 33 and 34 notifications.
- Notification of personal data breaches without undue delay.
- Deletion or return of the data at the end of the agreement, at the controller's choice, subject to statutory retention obligations.
- Evidence of compliance on request.
5. Sub-processors
The controller consents to the following sub-processors:
| Sub-processor | Service | Location |
|---|---|---|
| Host Europe GmbH | Server hosting and data storage | Deutschland / Germany |
| Dropbox International Unlimited Company | Storage of the submitted imaging data | Irland / USA |
| Microsoft Ireland Operations Ltd. | Email delivery (notifications, invoices) | Irland / EU |
Changes or additions are announced four weeks in advance; the controller may object.
6. Place of processing
Processing takes place in the European Union. Where a sub-processor processes data in a third country, this is based on an adequacy decision or standard contractual clauses.
7. Scientific use of anonymised images
The controller permits the processor to anonymise the images submitted and to use the anonymised images for teaching, research, professional presentations and scientific publications.
Anonymisation removes from the image and its metadata the names of patient, owner and practice, the referring vet, case and study numbers, acquisition dates and device identifiers. Only clinically necessary details are kept, such as species, breed, age group, sex, anatomical region and modality. Where this leaves no means of identifying a person, the data no longer fall within the GDPR and the processor acts in that respect on its own responsibility rather than as a processor.
The controller may object to this use at any time, informally by email. From that point onwards no further images from the controller are used for these purposes. Objecting is free of charge and has no bearing on the scope of the service, turnaround time or fee. Publications already issued are unaffected. The controller's practice is not named unless it expressly asks for this.
Annex 1 — Technical and organisational measures (Art. 32 GDPR)
| Area | Measure |
|---|---|
| Encryption | TLS for all traffic (HTTPS, HSTS). Passwords stored only as scrypt hashes. |
| Access control | Individual accounts, signed and time-limited session cookies, rate-limited sign-in with temporary account lockout. |
| Authorisation | Tenant separation: each practice sees only its own cases, reports and invoices. Every file and document request is authorised server-side. |
| Auditability | Logging of sign-ins, case submissions, report releases and billing actions with time, user and IP address. |
| Availability | Daily backup of database and files with integrity verification, fourteen generations retained, documented restore procedure. |
| Separation | Production kept separate from test and development environments. |
| Hardening | Unprivileged service account, restricted write paths, reverse proxy with automatic certificate renewal, firewall. |
Signatures
Name / address: ______________________________
Place, date, signature: _______________________
Equipixel Veterinary Teleradiology
Dr. Mahmoud Mageed, DipECVDI-LA
Alte Dorfstraße 21, 49456 Bakum
Place, date, signature: _______________________
Last updated: 28 Sep 2026