CONSENT & DATA HANDLING POLICIES

CONSENT, AUDIO/VIDEO USE & AI MODEL TRAINING POLICY

Effective Date: 01-12-2025
Issued By: SAHCHI HEARING AND SPEECH SOLUTIONS PRIVATE LIMITED (“Gabify”)
Applies To: Neurolens, all screening activities, all audio/video recordings, child assessments.

1. OVERVIEW & PURPOSE

This Consent Policy outlines:

• When and how consent must be obtained
  
• Legal requirements for uploading child/patient data
  
• Rules governing audio/video recording
  
• AI model training usage
  
• User rights to withdraw consent
  
• Institutional responsibilities
  

This policy ensures compliance with:

• DPDP Act, 2023 (India)
  
• Information Technology Act, 2000
  
• Child safety and health data regulations
  
• Global AI ethics and privacy standards
  

2. WHO MUST PROVIDE CONSENT

For any data uploaded into Neurolens:

2.1 Child Data

Consent must be obtained from the:

• Parent, or
  
• Legal guardian
  

before:

• Screening
  
• Recording audio
  
• Recording video
  
• Performing assessments
  
• Using data for AI training
  

The institution, not Gabify, is responsible for obtaining lawful consent.

2.2 Adult Assessments

For adult clients, informed consent must be obtained directly from the individual.

3. TYPES OF CONSENT REQUIRED

Neurolens requires three separate consents:

3.1 Consent for Screening & Assessment

Covers:

• Inputting personal/clinical details
  
• Observational data
  
• Questionnaire data
  
• Behavioral notes
  

Consent must clarify:

• Purpose of screening
  
• Role of AI
  
• Human oversight requirement
  

3.2 Consent for Audio/Video Recording

Recording may be used for:

• Behavioral observation
  
• Speech samples
  
• Clinician documentation
  
• AI inference
  

Consent must include:

• Reason for recording
  
• Duration of storage
  
• Who may access it
  
• Child rights and parental rights
  
• Withdrawal mechanisms
  

3.3 Consent for AI Model Training (Explicit, Optional)

This is the most sensitive consent.
AI model training requires opt-in consent.

Parents/guardians must be informed that:

• Data may be used to improve AI accuracy
  
• Data will be de-identified
  
• Data will never be sold
  
• Access is restricted to authorized AI trainers
  
• Withdrawal of consent is allowed anytime
  
• Refusal does not affect service quality
  

Neurolens may not deny assessments if the parent refuses AI training consent.

4. CONSENT COLLECTION RESPONSIBILITY

The Institution (School, Clinic, Hospital, Therapist) is responsible for:

• Providing a consent form compliant with law
  
• Verifying the identity of the consenting party
  
• Ensuring consent is informed & voluntary
  
• Maintaining consent documentation
  
• Retaining proof of consent for audit purposes
  

Gabify may provide sample templates but is not responsible for consent collection.

5. CONSENT FORMAT

Consent may be collected via:

• Digital signatures
  
• Written forms
  
• Electronic checkboxes tied to unique user IDs
  
• Institutional records
  

It must include:

• Purpose of processing
  
• Data types collected
  
• Risks & limitations
  
• AI use explanation
  
• Rights of the parent/client
  
• Withdrawal instructions
  

6. WITHDRAWAL OF CONSENT

Parents/clients may withdraw consent by contacting:

• The Institution directly, or
  
• Gabify through the Grievance Officer (only for AI training data)
  

Upon withdrawal:

• Future processing stops immediately
  
• Historical data used for AI training cannot be retroactively removed (industry-standard limitation)
  
• Clinical data may still be retained under legal and audit obligations
  

7. INSTITUTION’S OBLIGATIONS

Institutions must ensure:

• Consent is collected before uploading data
  
• Consent is auditable
  
• Access is restricted to authorized staff
  
• Reports are only shared with authorized individuals
  
• Parents/guardians understand AI limitations
  

Institutions are fully responsible for any legal violations related to lack of consent.

8. GABIFY’S OBLIGATIONS

Gabify ensures:

• Secure storage
  
• De-identification of AI training data
  
• No unauthorized access
  
• Data minimization practices
  
• Industry-standard AI governance
  

9. PROHIBITED ACTIONS

Neither institutions nor users may:

• Upload child data without parental consent
  
• Upload audio/video without explicit permission
  
• Use recordings for non-clinical purposes
  
• Share recordings externally
  
• Process data for marketing or advertising
  
• Use Neurolens as legal evidence
  
• Train external AI using Neurolens data
  

Violations result in account termination.

10. AUDIT & RECORD-KEEPING

Institutions must:

• Retain consent records for at least 3 years
  
• Provide them to Gabify upon audit
  
• Cooperate with regulatory authorities
  

Gabify maintains logs of:

• Consent tags
  
• Timestamped uploads
  
• Data access history
  

11. SPECIAL DISCLAIMER: AI LIMITATIONS

Parents and clinicians must acknowledge:

• AI may make inaccuracies
  
• AI outputs are not final conclusions
  
• AI must be reviewed by a qualified expert
  
• AI is an assistive tool only
  

12. CONTACT FOR CONSENT ISSUES

Email: info@gabify.life