Partnership Policy & Clinical Responsibility Charter

This Partnership Policy ("Policy") sets forth the legal, regulatory, data protection, and clinical governance principles governing all commercial partnerships, host dental practices, Clinical Dental Technicians (CDTs), Dental Surgeons, and specialist dental laboratories participating in the Denturaa network (Denturaa).

Denturaa operates strictly as a digital technology, patient introduction, marketing, and booking coordination platform. Denturaa does NOT provide dental examinations, deliver surgical procedures, prescribe custom medical devices, or practice dentistry within the meaning of the Dentists Act 1984 (as amended) or the Health and Social Care Act 2008.

By entering into a partnership arrangement, hosting a Denturaa sessional clinic, or accepting patient introductions through the platform, partners unconditionally agree to the terms, clinical divisions of responsibility, and data governance standards set forth in this document.

• Applicable Entities: Independent dental clinics, surgery room host facilities, GDC-registered Clinical Dental Technicians, GDC-registered General Dental Practitioners, dental locums, and contracted dental appliance laboratories.
• Regulatory Independence: The commercial relationship between Denturaa and any partner is that of an independent contractor and booking introduction agency. Nothing in this Policy creates a partnership, employment, joint venture, or agency relationship in clinical decision-making.

Partners and treating clinicians are SOLELY and EXCLUSIVELY responsible for all clinical treatments, patient care, examinations, diagnoses, prescriptions, and dental prosthetic procedures provided to any patient introduced through Denturaa.

Denturaa holds no clinical liability whatsoever for patient outcomes, satisfaction, or healthcare delivery. Under UK healthcare law, the direct doctor-patient or clinician-patient legal duty of care is established exclusively between the patient and the treating partner clinic or independent registered practitioner.

• Sole Responsibility for Treatment Delivery: The treating partner holds absolute clinical responsibility for oral health assessments, patient medical history evaluations, impressions (digital scans or physical moulds), bite registrations, trial fittings, denture insertions, surgical extractions, implant placements, and ongoing post-insertion adjustments.
• Independent Clinical Autonomy: Treating clinicians retain total clinical discretion and professional autonomy. Denturaa does not direct, oversee, influence, or participate in any clinical diagnosis or treatment decision.
• Right to Decline Treatment: Partners maintain the absolute clinical right and obligation to decline, postpone, or refer elsewhere any patient if the clinician determines that the requested prosthetic treatment is clinically contraindicated, unsafe, or inappropriate for the patient's oral anatomy.
• Informed Consent: Partners are strictly responsible for securing valid, informed, and documented patient consent in compliance with Montgomery standards and GDC guidance prior to initiating any irreversible treatment or prosthetic manufacturing.

To maintain active partner status within the Denturaa network, partners warrant, represent, and guarantee ongoing compliance with the highest UK dental standards:

• GDC Professional Registration: Every practicing clinician (CDT or Dentist) must maintain active, unencumbered registration with the General Dental Council (GDC) and adhere stringently to 'GDC Standards for the Dental Team'.
• Statutory Clinic Registration: Host premises must be registered with and inspected by the appropriate national healthcare regulator (Care Quality Commission (CQC) in England, Healthcare Inspectorate Wales (HIW) in Wales, or Healthcare Improvement Scotland (HIS) in Scotland).
• Mandatory Professional Indemnity: Every partner and practicing clinician must hold adequate, continuous professional medical malpractice and dental indemnity insurance (e.g. Dental Protection, DDU, MDU, or allied FCA-regulated medical defence organisations) with retroactive cover sufficient to meet all potential civil claims.
• Custom Medical Devices Compliance: All custom-made dental prosthetics, cobalt-chrome frameworks, and acrylic appliances manufactured for patients must comply with the Medical Devices Regulations 2002 (UK MDR 2002) and MHRA custom-made device manufacturing standards, including supplying patients with the statutory Statement of Manufacture upon request.

Data ownership, processing rights, and statutory record-keeping obligations are strictly delineated under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and Caldicott principles:

• Platform Data Controller (Denturaa): Denturaa is the independent Data Controller for all platform registration data, website booking inquiries, lead attribution records, WhatsApp photo triage coordination logs, commercial transaction records, and aggregated website analytics. Denturaa retains full proprietary rights over platform databases, booking engines, and brand assets.
• Clinical Record Data Controller (Partner): Upon the patient's arrival at the host clinic or upon initiating clinical care, the partner clinic becomes the independent statutory Data Controller for the patient's formal clinical dental records, intraoral radiographs, clinical charts, treatment plans, medical history questionnaires, and clinical photography.
• Statutory Retention Obligations: Partners must store, protect, and retain all clinical records in compliant dental practice management software (e.g., Software of Excellence (SOE), Carestream R4, Dentally, iSmile) in accordance with the GDC and British Dental Association (BDA) retention rules (typically minimum 10 years for adults, or up to age 25 for paediatric patients). Denturaa does not retain or store formal clinical healthcare records on behalf of partner practices.
• Secure Data Transfer & Confidentiality: Patient contact details and preliminary photo triage assets shared by Denturaa with a partner are transferred exclusively for scheduling, clinical assessment, and care delivery. Partners agree never to disclose, sell, leak, or cross-market platform-introduced patient data without explicit, verifiable consent.
• Subject Access Requests (SARs): Requests by patients to access clinical records must be processed directly by the partner clinic holding the patient chart. Requests relating to platform coordination or marketing communications are managed by Denturaa.

Denturaa and its partners maintain full commercial transparency in accordance with Advertising Standards Authority (ASA) and Competition and Markets Authority (CMA) guidelines:

• Transparent Written Quotes: Partners agree that all treatment fees quoted to patients must be itemised and provided in writing before clinical treatment commences. Any necessary supplementary clinical procedures (such as preparatory extractions, periodontal therapy, or ridge augmentation) must be clearly explained with associated costs.
• Commission & Referral Remuneration: Partners acknowledge and agree that Denturaa operates as an introduction and booking agency. Denturaa may receive a commercial introduction fee, marketing retainer, or referral commission for introducing patients to partner practices, in full compliance with GDC Standard 1.7.4 (full commercial transparency).
• Stripe & Financial Processing: Booking deposits or consultation reservation fees processed through Denturaa's Stripe payment gateway are managed in accordance with our Refund & Payment Policy (/refund-policy) and Cancellation Policy (/cancellation-policy).

Because partners exercise complete clinical independence and bear exclusive clinical liability, complaints and disputes are allocated as follows:

• Direct Clinical Complaints: Any patient complaint regarding treatment quality, prosthetic fit, clinical complications, clinician conduct, or refund requests for clinical procedures must be handled directly by the partner clinic in accordance with their statutory local complaints procedure and GDC complaint standards.
• Indemnity & Hold Harmless: The partner clinic and treating clinician unconditionally agree to indemnify, defend, and hold harmless Denturaa, its directors, officers, employees, and technology contractors from and against any and all claims, civil actions, liabilities, damages, losses, costs, or legal fees arising out of: (a) any clinical act, omission, negligence, or malpractice by the partner or its clinicians; (b) any breach of GDC, CQC, or statutory regulatory standards; or (c) any data protection breach occurring within the partner's systems or facilities.

This Partnership Policy, and any dispute or claim arising out of or in connection with its subject matter or formation (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of England and Wales.

Partners irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this Policy or its enforcement.