Treating Customers Fairly (TCF) Policy
Updated 10 October 2025
1. Purpose
The purpose of this policy is to outline IVC Health’s commitment to ensuring that all customers are treated fairly, ethically, and transparently in accordance with the Treating Customers Fairly (TCF) principles, the Protection of Personal Information Act (POPIA), and applicable South African digital health and consumer protection laws.
IVC Health strives to deliver safe, accessible, and reliable digital/virtual healthcare services that protect patients’ rights, personal data, and overall well-being.
2. Scope
This policy applies to:
- All digital health services, including virtual consultations, telemedicine, digital prescriptions, patient support services, digital screening services, health scores, etc.
- All employees, consultants, and partners are engaged in the delivery of these services.
- All customers and patients who use IVC Health’s digital platforms.
3. Commitment to Treating Customers Fairly
IVC Health is committed to embedding the six TCF outcomes across our operations:
Outcome 1: Culture of Fair Treatment
- Fair customer treatment is central to IVC Health’s culture and decision-making.
- All staff receive training on conduct, confidentiality, and POPIA compliance.
- Performance metrics consider customer satisfaction and ethical conduct, not just operational efficiency.
Outcome 2: Products and Services Designed for Customers’ Needs
- Digital health products and virtual consultation services are designed with a clear understanding of patient needs, accessibility, and health literacy levels.
- Clinical safety, data security, and ease of use are built into all service design processes.
- Regular patient feedback is collected and used to improve service quality and inclusivity.
Outcome 3: Clear Information and Transparency
- Customers receive clear, concise, and accurate information about services, fees, data usage, and limitations before, during, and after consultations.
- Digital consent forms explain how personal and medical data are collected, stored, and used, in line with POPIA.
- Marketing and educational materials are transparent, factual, and never misleading.
Outcome 4: Services Perform as Promised
- IVC Health ensures all virtual consultations and related services perform as advertised and meet clinical and technical standards.
- Service performance is continuously monitored to ensure reliability, privacy, and safety.
- Patients are informed promptly of any service disruptions or system failures.
- Outcome 5: No Unreasonable Barriers to Access or Complaint Handling
- Customers can easily register, book, and access consultations through intuitive digital platforms.
Outcome 5: No Unreasonable Barriers to Access or Complaint Handling
- Customers can easily register, book, and access consultations through intuitive digital platforms.
- Complaints or feedback can be submitted online or via email, with clear escalation processes and to be responded to as soon as reasonably possible.
- Customers can withdraw consent, request data deletion, or access their health information as per POPIA and the Promotion of Access to Information Act (PAIA).
- See IVC Health PAIA policy here: https://ivc.health/paia-popia-manual/
Outcome 6: Customers Are Treated Fairly When Things Go Wrong
- In the event of an error, service failure, or data breach, IVC Health takes immediate corrective action, communicates transparently with affected users, and offers appropriate redress.
- Breaches of confidentiality or data protection are reported and managed in accordance with POPIA and the Information Regulator of South Africa guidelines.
- Patients’ welfare remains the highest priority in all resolution processes
4. Data Privacy and POPIA Compliance
- Personal and health information is collected lawfully, with explicit consent from the data subject.
- Data is used only for the purposes agreed upon and stored securely using encryption and access controls.
- Only authorized personnel may access identifiable patient data.
- Data is not shared with third parties without explicit consent or legal basis.
- IVC Health regularly reviews data protection measures to ensure ongoing compliance with POPIA and other applicable acts.
5. Digital Ethics and Security
- All digital health platforms comply with the Health Professions Council of South Africa (HPCSA) telemedicine guidelines.
- Video and chat consultations are conducted using encrypted platforms.
- Digital records are maintained in line with Health Information System Interoperability Standards and FHIR protocols where applicable.
- Continuous cybersecurity monitoring and data integrity checks are in place.
6. Complaints and Escalation Process
Customers can submit complaints or queries via:
- Email: support@ivchealth.co.za
- Online form on the IVC Health portal
- Telephone (during office hours)
Response and Resolution Timeline:
- Acknowledgement within 48 hours.
- Investigation and resolution within 7 business days, unless otherwise communicated.
- Escalations reviewed by the Compliance Officer and Clinical Governance team.
7. Governance and Accountability
- The Board of Directors oversees TCF and POPIA compliance.
- The Compliance Officer monitors adherence to this policy and reports to the Board.
- Regular training, internal audits, and system reviews ensure ongoing compliance.
8. Review and Continuous Improvement
This policy will be reviewed annually or whenever there are changes to legislation, digital health regulations, or service offerings. Feedback from customers, regulators, and internal audits informs continuous improvement.
