Portavis Privacy Notice

Version 1.3 · 14 October 2026

Who is responsible for your information?

For incident reports, witness information, staff records, investigations, and safety-management records entered for a customer organisation, that organisation is normally the data controller. James Maltby, trading as Portavis, provides the software and processes that information on the controller's instructions.

James Maltby, trading as Portavis, is a controller for information needed to create and secure user accounts, administer subscriptions and customer relationships, maintain service security, meet legal obligations, and operate this website.

Information processed

Depending on how the service is used, information may include names, work roles, contact details, account identifiers, incident narratives, dates, locations, staff involvement, witness statements, photographs, uploaded documents, investigation findings, audit logs, device/network metadata, notification preferences, and support communications. Incident records may contain health, injury, alleged misconduct, or other sensitive information supplied by a controller or reporter.

Purposes and lawful bases

Customer controllers determine the lawful basis for their incident and safety processing. Common bases may include legal obligation, public task, legitimate interests, contract, or vital interests, with an additional condition required for special-category or criminal-offence data. James Maltby, trading as Portavis, processes customer data under contract and documented controller instructions.

For Portavis's controller activities, processing is undertaken where necessary to perform a contract, comply with law, protect service security and legitimate business interests, or where another lawful basis is identified. A required privacy acknowledgement records that information was presented; it is not necessarily the controller's lawful basis.

AI processing

External OpenAI incident analysis is disabled for each organisation until its Owner enables it. When enabled, the software removes explicit database identifiers and redacts known names, email addresses, phone numbers, addresses, and incident references where possible. OpenAI receives only the minimised incident fields needed to interpret and answer the question. Portavis configures applicable OpenAI API requests not to store responses for application-state purposes (store=false). OpenAI may nevertheless retain certain API content in abuse-monitoring logs for a limited period in accordance with its applicable API data controls. Free text may still contain information that cannot be reliably detected, so users should avoid unnecessary personal data in AI questions and narratives.

When external incident analysis is enabled, the same minimised/redacted incident fields may be sent to OpenAI to select relevant report themes from a controlled vocabulary. If it is disabled or unavailable, tagging uses a conservative local fallback.

The separate, read-only software help assistant is available when Portavis enables it. When you ask it a question, OpenAI receives your question, up to four previous answered exchanges, relevant software guides and minimal screen, module and permission labels. It does not retrieve your organisation's operational records or make changes. Requests use store=false, subject to the provider's applicable abuse-monitoring retention. Do not enter personal or sensitive records, passwords or other secrets. Help conversations are private to your account through the application. If you submit a support ticket, authorised Portavis staff can read the request; your conversation is included only if you explicitly choose to attach it. Replies and status updates are shown in your account.

Recipients and subprocessors

Portavis uses Railway for application and database hosting, logs and backups; Microsoft 365 / Exchange Online for service and incident emails; Cloudflare R2 for private uploaded-file storage when configured; and OpenAI for external analysis where an organisation enables the relevant feature, and for software help when Portavis enables the help assistant and a user asks it a question. These providers may process customer personal data on the customer organisation's behalf. Stripe handles Portavis subscription payments and invoicing (billing contact name, email, billing address, tax ID and payment details entered directly with Stripe; Portavis does not receive or store full card numbers). Stripe's billing role is distinct from processing customer incident records on an organisation's instructions. Other recipients include OpenFreeMap/OpenStreetMap infrastructure for interactive map tiles, OpenStreetMap Nominatim for map-centring geocoding, Open-Meteo for supplementary weather context, and the Environment Agency real-time flood-monitoring API for measured tide readings on incident records. Customer controllers may also authorise their own recipients.

Where your information is stored

The Portavis application and its PostgreSQL database are hosted by Railway in its EU West region (Amsterdam, the Netherlands), within the European Economic Area. Uploaded documents, photographs, statements and other files are stored either on Portavis's configured Railway media storage or, when enabled, in a private Cloudflare R2 bucket. The selected R2 bucket uses Cloudflare's EU jurisdiction for stored objects; file references and metadata remain in PostgreSQL. Protected files are accessed through Portavis's permission-checked application rather than a public R2 bucket. The UK recognises the EEA as providing an adequate level of data protection for storage there, but the R2 bucket's EU jurisdiction alone does not establish where Cloudflare support or other processing takes place.

Portavis is a multi-organisation service: customer organisations' records are held in a shared database, and each record is tied to its organisation. Ordinary users' access is checked against their organisation membership and role; organisations do not have access to one another's data. Authorised Portavis staff and superadmins can access all organisations where needed to provide support, maintain security, or meet legal obligations.

International transfers

Portavis's operator is based in Australia and may access customer data there for authorised support, security and service administration. A UK customer making information accessible to Portavis as an Australian sole trader makes a restricted transfer to a separate legal person. Australia is not covered by UK adequacy regulations: the customer and Portavis must put appropriate safeguards in place, such as the UK International Data Transfer Agreement or UK Addendum with a transfer risk assessment, unless a lawful exception applies. This must happen before access takes place. Some providers listed above (including Cloudflare for support or other processing, OpenAI where external AI is enabled, Stripe for payments, and Microsoft 365 for email) may also process information outside the UK and EEA. The EU location of a storage bucket does not alone determine where provider support or other processing takes place.

Retention

Customer organisations set their incident-retention period and must consider maritime safety, regulatory, insurance, limitation, employment, and legal-hold requirements. When a period expires, Portavis places the record in an Owner review queue; no incident is deleted automatically. Legal hold blocks deletion. Portavis retains its own account, security, contractual, and statutory records only for as long as needed for the applicable purpose or legal requirement. Deleted information may remain in protected backups until those backups expire.

Your rights

Depending on the circumstances, you may have rights of access, correction, erasure, restriction, objection, and data portability, and the right to complain to the UK Information Commissioner's Office. For customer incident data, contact the organisation named on the form or request first. Portavis will assist that controller as required by its data-processing agreement.

Security and incidents

Portavis uses tenant access controls, role-based permissions, audit histories, encrypted HTTPS transport in production, minimised AI payloads, and provider-storage controls. No internet service can guarantee absolute security. Where James Maltby, trading as Portavis, acts as a processor and becomes aware of a personal-data breach affecting customer data, Portavis will notify the relevant customer organisation as controller without undue delay. The controller is responsible for assessing the breach and determining whether notification to the Information Commissioner's Office or affected individuals is required.

Contact and complaints

Portavis privacy contact: [email protected]

You may complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint.