Quick answer: For healthtech support, choose on paperwork before features. As at 4 October 2026, Lorikeet, Zendesk and Intercom document a HIPAA business associate agreement (BAA) route on public pages; Sierra and Decagon list HIPAA in their trust centres but not a BAA process. Four of the six vendors read today document Australian hosting, each with conditions; Decagon documents EU-only.
People searching “best Decagon and Sierra alternative for healthtech support” need the shortlist that survives a healthcare security review: will the vendor sign a business associate agreement under the US Health Insurance Portability and Accountability Act (HIPAA); where does protected health information (PHI) sit and where does the model that reads it run; when does the agent hand a patient to a clinician; and, for Australian teams, what the Privacy Act 1988, Australian Privacy Principle (APP) 8 and the My Health Records Act 2012 change. This page scores seven vendors on those questions only: Lorikeet, Zendesk AI agents, Intercom Fin, Sierra, Decagon, Hippocratic AI and, with a caveat, Ada. Every vendor fact comes from that vendor’s own page, linked, read on 4 October 2026 (for Ada, an archived copy).
Disclosure: this page is published by Zian AI, which sells autonomous AI agents including a Customer Support Agent. It publishes no HIPAA, BAA, SOC 2 or ISO 27001 attestation, so it is not scored below; where it can fit is covered near the end. This is general information about published regulations and vendor documents, not legal advice.
Where Zian fits in a healthtech support stack, and where it does not
Zian AI publishes no HIPAA, BAA, SOC 2 or ISO 27001 attestation. If gate B or gate A binds the workflow, Zian is not on that shortlist.
Some healthtech support traffic carries no health information: partner onboarding, B2B enquiries, IT support for clinic staff and sales follow-up. For those flows, Zian’s AI customer support agents run 24/7 in 30+ languages across live phone, SMS, email and WhatsApp, with knowledge-base lookups, HubSpot, Salesforce, HighLevel and Zapier integrations, and a niched IT Technical Support Agent. The point that touches gate R is private model deployment on customer infrastructure: the model runs where you run it. That answers where inference happens; it does not replace a BAA or an audit report.
You can run the BRACE review yourself; the table above is the method. Filling it for six vendors took more than 30 saved vendor pages, two Acts, the HIPAA rules in 45 CFR and the OAIC’s APP 8 guidelines, and two sites (ada.cx and hhs.gov) refused automated reads. Budget a working day per shortlist, plus security-team time for the reports.
What does healthtech support need that a generic CX agent may not?
A generic customer-experience (CX) agent is judged on resolution rate, channels and price. A healthtech agent is judged first on five gates; fail one that binds your organisation and the demo does not matter. We call this the BRACE test:
- B – BAA. If you are a HIPAA covered entity or business associate, will the vendor sign a business associate agreement, on which plan, and does it cover the AI features you will actually switch on?
- R – Residency, including inference. Where is patient data stored, where is it processed, and where does the model that reads the conversation run? Decagon’s own glossary lists four residency controls (at rest, in processing, contractual guarantees and audit trails) and on processing says: “Model inference calls must be routed to compute nodes inside the region, which rules out certain shared multi-tenant inference APIs.”
- A – Attestations. Which reports can your security team actually download or request: SOC 2 Type II, ISO 27001, a HIPAA audit report?
- C – Clinical escalation. What does the vendor say its agent will not do, and how does a conversation that needs clinical judgement reach a person with the context attached?
- E – Excluded scope. Which products, add-ons, channels or plans sit outside the BAA, the residency commitment or the intended use?
A healthtech support platform is chosen by its BAA, data and inference location, audit reports, clinical hand-off and exclusions list, in that order; resolution rate is a tie-breaker.
Best Decagon and Sierra alternative for healthtech support: the BRACE table
Each cell is what the vendor’s own page says, as at 4 October 2026. “Not stated” means the named pages were read, with a positive control found in the same saved copy; it means you have to ask, not that the vendor cannot do it.
| Vendor | B – BAA | R – Residency and inference | A – Attestations | C – Clinical escalation | E – Excluded scope and conditions |
|---|---|---|---|---|---|
| Lorikeet | Signs BAAs for healthcare customers (trust page); pricing lists a DPA or BAA (incl. HIPAA) as standard on Start and Scale, custom on Signature (pricing) | US primary hosting on Google Cloud; storage residency available in Australia and the EU; pricing table lists USA on Start and Scale, custom on Signature. Trust centre lists OpenAI, Anthropic and Baseten (each on a zero-data-retention basis) and every other model-inference subprocessor that shows a location in the USA | SOC 2 Type II, ISO 27001:2022, HIPAA, GDPR; reports downloadable under NDA (trust centre) | Runtime guardrails detect sensitive or clinical topics and hand off with full context; care agents can guide the AI in real time (healthcare page) | Pricing lists data residency as USA on Start and Scale and custom on Signature, which carries a $75K platform fee |
| Zendesk AI agents | BAA through the Advanced Compliance add-on on Suite Professional, Enterprise or Enterprise Plus (Advanced Compliance) | Data Center Location add-on (free on Suite Professional and above) offers Australia, and Service Data may still be processed outside the chosen region (add-on article). The Regional Data Hosting Policy covers AI agents, but only for AI agents accounts created on or after 10 March 2026 (older accounts: EEA or US only); Forethought AI agents are not covered; production troubleshooting logs and platform and ML analytics data cannot be hosted in Australia, and workflow and taxonomy data (such as bot names and intent labels) is hosted in the US. Its Sub-processor Policy lists AI agents hosting by Google Cloud, MongoDB, Aiven and Grafana Labs in the United States and Belgium, and gives no processing location for its language-model providers, such as OpenAI and Microsoft, beyond “No hosting of Service Data” | Business associate requirements met through SOC 2, ISO 27001/27018 certifications and internal HIPAA audits (Advanced Compliance article) | Voice AI agents escalate to a human with an AI summary; “not intended” for emergency healthcare patient triage systems (voice AI agents) | HIPAA-enabled add-ons include AI agents – Advanced and Forethought AI agents; Early Access Programs, Marketplace apps and social messaging integrations are not covered; Talk is covered excluding Text; Contact Center also needs a BAA with AWS |
| Intercom Fin | Terms bar PHI unless covered by a business associate agreement executed with Intercom (Terms of Service) | Regional Data Hosting in the US, EU or Australia, for new workspaces on Advanced and Expert plans on contract; for Australian workspaces, billing and admin data may leave Australia and emails go through the US (help article); for Australian workspaces, the subprocessor list places AWS and Snowflake processing, including AI processing, in Australia, but AI processing by OpenAI, Anthropic, Google and models on AWS Bedrock in the USA | SOC 2 Type II, HIPAA, ISO 27001, 27018, 27701 and 42001; Fin AIUC-1 certified (security page); HIPAA report in the trust centre | Fin escalates to a human agent when confidence thresholds are not met (security page FAQ); no clinical-specific escalation feature on the pages read | Terms state the Services are not PCI DSS compliant; existing workspace data cannot be migrated directly to a region, and conversation history can only be exported |
| Sierra | Not stated on its healthcare, trust-and-reliability or trust-centre overview pages; trust centre lists a 2026 HIPAA audit report and a resource titled “Enabling Healthcare: HIPAA for AI Agents” (trust centre) | Subprocessor list: AWS localisation available in the US, EU, Southeast Asia, Japan and Australia; Anthropic listed United States; the other AI-services subprocessors besides AWS (OpenAI, Google, Microsoft, Deepgram and five more) localise only in the US or EU (subprocessor list) | ISO/IEC 27001:2022, ISO/IEC 42001:2023, SOC 2, HIPAA, PCI DSS 4.0.1, GDPR, CCPA, CSA STAR, EU AI Act, FedRAMP High, AIUC-1 (trust centre) | Healthcare page lists triage and routing (authentication, intent recognition, issue-based routing); trust page describes filters for off-limits topics (trust page) | Healthcare use cases named: payers, providers, revenue cycle, pharmacy and PBMs, medical devices (healthcare page) |
| Decagon | Not stated on its security page, health and wellness page, llms.txt or DPA security annex; trust centre lists HIPAA (trust centre) | EU-only data residency on request (DPA security annex); subprocessors shown (Google Cloud, OpenAI, AWS, Azure) list USA and EU; Australian residency not documented | SOC 2 Type II, GDPR, CCPA, HIPAA, EU AI Act, ISO 27001:2022, PCI DSS 4.0.1 (trust centre) | Bad-actor detection deflects unsafe inputs or escalates to a human; Watchtower flags compliance risks (security page) | Health page names enrolment, scheduling and prescription-adherence reminders “without crossing regulatory boundaries” (health page) |
| Hippocratic AI | Not assessable: trust centre is behind an access request | Not assessable from public pages read | Not assessable: trust centre is behind an access request | “Our AI agents do not diagnose or prescribe” (home page); safety framework’s fourth phase is escalation to a human nurse (safety page) | Publishes 1000+ healthcare agents, largely patient-facing: screening and vaccination outreach, scheduling, post-procedure follow-up and clinical-trial support |
| Ada (caveat) | Not re-checked: ada.cx refused automated requests on 4 October 2026 | Not re-checked | Archived copy of its trust page dated 7 March 2026 lists SOC 2 Type II, GDPR and HIPAA, plus AIUC-1 certification (Internet Archive) | Not re-checked | Reconfirm every cell directly with Ada |
The B column: three of six vendors assessed today (Lorikeet, Zendesk, Intercom) document a BAA route publicly. The R column: four of six (Lorikeet, Zendesk, Intercom, Sierra) document an Australian hosting option, each with a condition: a custom plan, the Data Center Location add-on on Suite Professional or above (for AI agents, only accounts created on or after 10 March 2026), a new contract workspace, or a subprocessor localisation listed as available. Lorikeet and Intercom list their large language model providers in the USA even when data is stored in Australia, Sierra’s AI-services subprocessors other than AWS localise only in the US or EU, and Zendesk gives no processing location for its language-model providers. Decagon documents EU-only residency; Hippocratic AI’s answers sit behind an access request.
Does the vendor sign a HIPAA business associate agreement?
Under 45 CFR 164.502(e)(1)(i), a covered entity may disclose PHI to a business associate, or let it create, receive, maintain or transmit PHI on the entity’s behalf, only if the covered entity obtains satisfactory assurance that the business associate will appropriately safeguard the information. Paragraph (e)(2) requires that assurance to be documented in a written contract or other written arrangement meeting 164.504(e). Paragraph (e)(1)(ii) pushes the duty down a level: the business associate must get the same assurances from its subcontractors, and paragraph (e)(1)(i) says the covered entity need not obtain them from a business associate that is a subcontractor. For an AI vendor the subcontractors usually include the model provider, so the subprocessor list matters as much as the BAA.
The sentence that cuts against treating this as universal: HIPAA’s definition of a covered entity in 45 CFR 160.103 has three limbs, a health plan, a health care clearinghouse, or a health care provider who transmits health information electronically in connection with a covered transaction. A wellness app that bills consumers directly and never touches an insurer may be none of the three, and then the BAA rule does not reach it. Work out which you are before you disqualify a vendor on gate B.
- Lorikeet states “We sign Business Associate Agreements for healthcare customers” and says PHI is handled on a minimum-necessary basis and automatically redacted. Its pricing table puts the DPA or BAA as standard on the two published plans.
- Zendesk lets customers on Suite Professional or above sign its BAA through the Advanced Compliance add-on, and lists AI agents – Advanced as a HIPAA-enabled add-on. Its own HIPAA FAQ adds the caveat that matters: “Compliance with HIPAA depends on how you use the software.”
- Intercom has no HIPAA or BAA article in its help-centre sitemap as at 4 October 2026, but its Terms of Service define PHI not covered by “a duly executed Business Associate Agreement with Intercom” as Sensitive Personal Information the customer must not submit. The BAA is therefore the documented route, and the default is no PHI.
- Sierra and Decagon both list HIPAA in their trust centres, and Sierra lists a 2026 HIPAA audit report. Neither describes its BAA process on the public pages named in the table. Ask for the BAA, its covered-services list and its subcontractor schedule in the first call.
For the full subcontractor chain behind a voice agent, see the HIPAA BAA chain for AI voice agents, which walks who signs at each of five layers.
Where does patient data sit, and where does the model run?
For an Australian healthtech team the residency question starts in the Privacy Act 1988, not on a vendor’s trust page.
First, health information is sensitive information: paragraph (b) of the definition of “sensitive information” in section 6(1) of the Privacy Act. Second, the small business exemption does not help a health provider: under section 6D(4)(b), an entity is not a small business operator if it “provides a health service to another individual and holds any health information except in an employee record”, whatever its turnover. Third, APP 8.1: before an APP entity discloses personal information to an overseas recipient that is not in Australia or an external Territory and is not the entity or the individual, it must take reasonable steps to ensure the recipient does not breach the APPs (other than APP 1). Section 16C then treats certain breaches by that overseas recipient as breaches by you.
APP 8.2 lists seven exceptions to APP 8.1: the entity reasonably believes the recipient is bound by a substantially similar law or binding scheme with mechanisms the individual can access to enforce it; the recipient is subject to a country or scheme prescribed under APP 8.3; the individual consents after being expressly told APP 8.1 will not apply; the disclosure is required or authorised by an Australian law or court or tribunal order; a permitted general situation exists (other than items 4 and 5 of the section 16A table); and two that apply only to agencies, an international information-sharing agreement and enforcement-related disclosures.
The sentence that most weakens a blanket “Australian hosting only” rule comes from the regulator. The OAIC’s APP 8 guidelines at paragraph 8.14 say that giving information to an overseas contractor may be a “use” rather than a disclosure, so APP 8 does not apply, where the entity keeps effective control. The OAIC’s example is a cloud provider storing data, and it sets three conditions: a binding contract limiting the provider to those purposes, the same obligations passed to subcontractors, and a contract that gives the entity effective control over how the information is handled. Whether a model provider generating answers from patient messages fits that storage example is a question for your privacy adviser, not one to assume. Paragraph 8.15 adds the catch: because you still “hold” the information, mishandling while it is in the contractor’s possession can still be your breach.
The My Health Records Act is narrower than it is often described. Section 77(1) binds four kinds of entity: the System Operator, a registered repository operator, a registered portal operator and a registered contracted service provider, where it holds records for the purposes of the My Health Record system or has access to information relating to them. Each must not hold or take those records outside Australia, must not process or handle the related information outside Australia, and must not cause or permit another person to do either. Subsection (2) carves out the System Operator for records and information that contain no personal or identifying information. The penalties are a fault-based offence of up to 5 years’ imprisonment or 300 penalty units, or both, and a civil penalty of 1,500 penalty units. A registered healthcare provider organisation is not in the section 77(1) list; it still has APP 8.
Lorikeet’s trust page says storage residency is available in Australia, while its trust centre lists every model-inference subprocessor that shows a location, OpenAI, Anthropic and Baseten among them, in the USA. Intercom’s Australian workspaces keep Messenger conversation data in region under normal conditions but route emails through the US, and Intercom’s subprocessor list places AI processing for Australian-hosted workspaces by OpenAI, Anthropic, Google and models on AWS Bedrock in the USA. Zendesk’s Regional Data Hosting Policy covers AI agents only for accounts created on or after 10 March 2026, excludes Forethought AI agents, and its Data Center Location article says Service Data may still be processed outside the chosen region; its Sub-processor Policy lists AI agents hosting by Google Cloud, MongoDB, Aiven and Grafana Labs in the United States and Belgium. Sierra’s AWS entry offers Australian localisation, its Anthropic entry says United States, and its other AI-services entries, OpenAI, Google and Microsoft among them, localise only in the US or EU. For a hop-by-hop method to test any vendor’s claim, see how to audit an “Australian hosted” AI vendor claim.
Which certifications should a healthtech AI support vendor hold?
HIPAA compliance is something a vendor asserts and backs with an audit report; SOC 2 and ISO 27001 are reports or certificates issued by an independent auditor or certification body against a named control set. Zendesk says this plainly in its Advanced Compliance article: its business associate requirements are met through SOC 2, ISO 27001 and ISO 27018 certifications plus internal HIPAA audits.
Ask for the current SOC 2 Type II report, the ISO 27001 certificate with its scope statement, and the HIPAA report if one exists. Lorikeet, Intercom, Sierra and Decagon all list SOC 2, HIPAA and ISO 27001 in their trust centres; Zendesk cites SOC 2, ISO 27001 and ISO 27018 in its Advanced Compliance article. ISO 42001, the AI management-system standard, appears for Intercom and Sierra. Read the scope statement: a certificate that does not cover the production environment answers a different question.
Will the AI agent escalate to a clinician?
A retail agent never hears “my chest has been tight since this morning”. What each vendor publishes:
- Lorikeet names the feature, Clinical Escalation: runtime guardrails detect sensitive or clinical topics and hand off to your team with full patient context, on the same channel.
- Hippocratic AI states its agents “do not diagnose or prescribe”, and its safety page lists escalation to a human nurse as the fourth phase of a five-phase framework.
- Zendesk states what its voice product is not for. Its voice AI agents article says they are “not intended to be used to evaluate and classify emergency calls, or to dispatch or prioritize emergency first response services or emergency healthcare patient triage systems.”
- Sierra lists triage and routing on its healthcare page, described as replacing an IVR with authentication, intent recognition and issue-based routing, and its trust page describes filters for topics that are off-limits under your policies.
- Decagon and Intercom describe general escalation: Decagon’s bad-actor detection deflects unsafe inputs or escalates to a human, and Fin escalates when confidence thresholds are not met. Neither names a clinical-escalation feature on the pages we read, so the rule has to be written into your own procedures.
Whatever the vendor, write the rule yourself: which intents end the automated conversation, who receives it, how fast, and what the patient is told meanwhile. Passing context so a nurse does not restart the conversation is covered in AI-to-human handoff and context transfer.
Which BRACE gates apply to your organisation?
Not every gate binds every buyer. Find the row that describes you; the third column lists the gates a vendor must pass.
| If you are | Instrument | Gates that bind |
|---|---|---|
| US health plan, clearinghouse, or provider that bills insurers electronically | 45 CFR 160.103; 164.502(e) | B mandatory before any PHI reaches the agent; A and E to confirm the BAA covers the AI add-on |
| US business associate (for example, a billing or care-coordination vendor) adding AI support | 164.502(e)(1)(ii) | B with your own subcontractor: you need the AI vendor’s BAA; then check its model subprocessors |
| US direct-to-consumer health app that is not a covered entity or business associate | 160.103 (none of the three limbs) | B optional under HIPAA; R, A, C still matter commercially |
| Australian health service provider of any size | Privacy Act s 6(1), s 6D(4)(b), APP 8 | R mandatory as an APP 8 analysis: storage and inference location, or a documented 8.2 exception or 8.14 “use” basis |
| Registered repository operator, portal operator or contracted service provider in the My Health Record system | My Health Records Act s 77(1) | R absolute for those records: no holding or processing outside Australia, and no causing or permitting another person to do so |
| Any team whose agent may hear symptoms or medication questions | Vendor intended-use statements | C mandatory: a written escalation rule and a vendor whose intended use does not exclude your workflow |
Who each Decagon and Sierra alternative is wrong for
- Lorikeet is wrong for an Australian team that needs Australian data residency but not Signature-scale volume: residency outside the USA is custom on Signature, a plan Lorikeet describes for fast-scalers with 20K+ monthly ticket volume and/or dedicated support, with a $75K platform fee and a $25K+ forward-deployed support package.
- Zendesk AI agents are wrong for anyone planning to put PHI through a Marketplace app, an Early Access Program feature or a social messaging integration, all outside its Healthcare Agreement, and for voice triage of urgent symptoms, which its own article excludes.
- Intercom Fin is wrong for teams that need Australian residency on an existing workspace, because regional hosting needs a new workspace and history is export-only, for teams that need all AI processing inside Australia, since its subprocessor list places AI processing by OpenAI, Anthropic, Google and models on AWS Bedrock in the USA for Australian workspaces, and for card-payment flows, since Intercom’s terms say the Services are not PCI DSS compliant.
- Sierra and Decagon are wrong for a buyer who must see BAA terms before a sales call. Decagon is also wrong where Australian residency is mandatory, because its published residency option is EU-only.
- Hippocratic AI is wrong if what you need is a general helpdesk agent for account, billing and app questions; the agents it publishes are patient-facing outreach and follow-up agents.
Running healthtech support and want the non-PHI half automated? Zian AI’s Customer Support Agent works 24/7 in 30+ languages across phone, SMS, email and WhatsApp, with private model deployment on your own infrastructure. Zian is in partnership-application beta. Apply For Partnership
Frequently asked questions
What is the best Decagon or Sierra alternative for healthtech support?
It depends on the gate that binds you. As at 4 October 2026, Lorikeet, Zendesk and Intercom document a business associate agreement route on public pages, while Sierra and Decagon list HIPAA in their trust centres without describing a BAA process. For Australian residency, Lorikeet, Zendesk, Intercom and Sierra each document an option with conditions; Decagon documents EU-only residency.
Does Decagon or Sierra sign a HIPAA BAA?
Both list HIPAA in their trust centres, and Sierra lists a 2026 HIPAA audit report. Neither describes its BAA process on the healthcare, security or trust pages we read on 4 October 2026, so ask for the BAA, its covered-services list and its subcontractor schedule in the first call.
Do I need a BAA with an AI customer support vendor?
Only if HIPAA applies to you. Under 45 CFR 164.502(e), a covered entity may disclose PHI to a business associate, or let it create, receive, maintain or transmit PHI, only with satisfactory assurance, documented in a written contract that meets 164.504(e). A health plan, a clearinghouse or a provider transmitting health information electronically in a covered transaction is a covered entity; a consumer app that is none of those may not be.
Does Australian health data have to stay in Australia?
Not as a general rule. Under the Privacy Act, health information is sensitive information and APP 8.1 requires reasonable steps before disclosing it to an overseas recipient, subject to seven exceptions in APP 8.2. The hard rule is section 77 of the My Health Records Act, which bars the System Operator and three kinds of registered operator or provider from holding or processing My Health Record records outside Australia, or letting another person do so.
Is Zian HIPAA compliant?
Zian AI publishes no HIPAA, BAA, SOC 2 or ISO 27001 attestation, so it should not handle PHI where those are required. It fits support and sales workflows that carry no health information, and it offers private model deployment on your own infrastructure.
Can an AI support agent triage patients?
Check the vendor’s intended use first. Zendesk says its voice AI agents are not intended for emergency healthcare patient triage systems. Hippocratic AI says its agents do not diagnose or prescribe and escalate to human nurses. Lorikeet hands clinical topics to your team with full context. Write your own escalation rule whatever the vendor says.
Where every figure on this page comes from
| Figure | Who published it | Link | Date read |
|---|---|---|---|
| $75K Signature platform fee; $25K+ FDE Platinum package; 20K+ monthly tickets | Lorikeet | https://www.lorikeetcx.ai/pricing | 4 October 2026 |
| Data residency USA on Start and Scale, custom on Signature | Lorikeet (pricing.md) | https://www.lorikeetcx.ai/pricing.md | 4 October 2026 |
| 2026 HIPAA audit report; PCI DSS 4.0.1; ISO/IEC 27001:2022 and 42001:2023 | Sierra | https://trust.sierra.ai/ | 4 October 2026 |
| ISO 27001:2022 and PCI DSS 4.0.1 listings | Decagon | https://trust.decagon.ai/ | 4 October 2026 |
| ISO 27001, 27018, 27701, 42001 listings | Intercom | https://www.intercom.com/security | 4 October 2026 |
| Archived trust page dated 7 March 2026 | Ada, via the Internet Archive | https://web.archive.org/web/20260307213744/https://www.ada.cx/platform/trust/ | 4 October 2026 |
| AI agents covered for accounts created on or after 10 March 2026; Australian secondary-data exceptions | Zendesk | https://support.zendesk.com/hc/en-us/articles/4408883599130-Regional-Data-Hosting-Policy | 4 October 2026 |
| AI processing for Australian workspaces in the USA | Intercom | https://www.intercom.com/legal/subprocessors-list | 4 October 2026 |
| AI agents hosting United States and Belgium (Google Cloud, MongoDB, Aiven, Grafana Labs); language-model providers “No hosting of Service Data” | Zendesk | https://support.zendesk.com/hc/en-us/articles/4408883061530-Sub-processor-Policy | 4 October 2026 |
| 1000+ AI healthcare agents | Hippocratic AI | https://hippocraticai.com/ | 4 October 2026 |
| Five-phase safety framework; phase 4 escalation to a human nurse | Hippocratic AI | https://hippocraticai.com/safety/ | 4 October 2026 |
| Sierra AI-services subprocessors: AWS (Australia available), Anthropic (United States), nine others (US or EU) | Sierra | https://trust.sierra.ai/subprocessors | 4 October 2026 |
| Three limbs of “covered entity” | US eCFR (45 CFR 160.103) | https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-A/section-160.103 | 4 October 2026 |
| Seven exceptions in APP 8.2; s 6D(4)(b); s 6(1) | Federal Register of Legislation, Privacy Act 1988, Compilation No. 104 | https://www.legislation.gov.au/C2004A03712/latest/text | 4 October 2026 |
| Three conditions for a “use” at paragraph 8.14 | Office of the Australian Information Commissioner | https://www.oaic.gov.au/privacy/australian-privacy-principles/australian-privacy-principles-guidelines/chapter-8-app-8-cross-border-disclosure-of-personal-information | 4 October 2026 |
| Four entity types in s 77(1); 5 years or 300 penalty units; 1,500 penalty units | Federal Register of Legislation, My Health Records Act 2012 | https://www.legislation.gov.au/C2012A00063/latest/text | 4 October 2026 |
| 3 of 6 vendors document a BAA route; 4 of 6 document Australian hosting; more than 30 vendor pages read | Zian AI, first-party count from the BRACE table on this page | #brace-table | 4 October 2026 |
Next step: take the BRACE table into your next vendor call and ask for each gate by name. If the workflow you want to automate carries no health information, or you need the model running inside your own environment, Apply For Partnership and tell us which gate you are solving.