AI processing disclosure — Comprehendly
Provider: UltraDigital Limited (“StepCare”, “Comprehendly”)
Effective date: 11 November 2026
Version: 1.2
Comprehendly is a StepCare product operated by UltraDigital Limited.
This document is incorporated into our Privacy Policy and Terms of Service. It explains how Comprehendly uses artificial intelligence and automated systems.
1. Overview
Comprehendly may use automated systems, including third-party speech recognition and language models, to:
- Transcribe voice input in real time
- Map spoken or typed content to structured form fields
- Suggest values, summaries, or labels for fields
- Detect incomplete answers where configured
- Support phone-based guided form completion
Outputs are suggestions. Your organisation is responsible for reviewing and approving data before it is relied on for care, compliance, employment, eligibility, or legal purposes.
2. What data is sent to AI systems
| Data | Sent to OpenAI (or equivalent)? | Notes |
|---|---|---|
| Live voice audio stream | Yes, during an active session | Processed in real time |
| Form field labels and context | Yes | To align speech/text to fields |
| Optional text transcript | If user or Customer opts in | Stored per tenant policy |
| Account password | Never | |
| Payment card data | Never | Handled only by Stripe |
OpenAI processes customer content under contractual terms that prohibit use of that content to train models.
3. Human involvement
| Activity | Human role |
|---|---|
| Form completion | User accepts, edits, or rejects suggested field values |
| Supervisor review | Optional review workflow where enabled |
| Locked submissions | May prevent further automated changes after sign-off |
Comprehendly is not intended to replace professional judgement of clinicians, managers, assessors, or compliance officers.
4. Accuracy and limitations
AI systems may:
- Mishear or mistranscribe speech
- Map content to the wrong field
- Omit or invent detail
- Perform poorly with accents, noise, or specialised terminology
Always verify AI-filled content against source facts and organisational policies.
5. Decisions about individuals
Current product: Comprehendly does not typically make solely automated decisions that produce legal or similarly significant effects (for example eligibility denial, employment outcomes, or statutory reporting) without human approval.
If we introduce features that significantly affect individuals’ rights or interests through automated processing, we will:
- Update this disclosure and the Privacy Policy Schedule A (Australia) before activation
- Notify Customers before activation
- Require Customers to update their own notices to end users
6. Voice recording and surveillance law
Voice capture may be subject to workplace and surveillance laws in Australia (state/territory) and New Zealand. Customers must:
- Obtain required consents and authorisations
- Not use the Service for covert recording where unlawful
- Say, at the start of every phone call, that the call is being transcribed, and end the call if the person does not agree
7. Phone channel
Production phone calls are placed through the Twilio account and number the Customer connects. Live audio goes to that account and to the speech provider so the form can be filled. Twilio call-recording storage is disabled. Raw audio is not persisted as an audio file.
The Customer decides who may be called and keeps the consent and suppression records. New Zealand voice calls are outside the Unsolicited Electronic Messages Act 2007. Australian telemarketing calls must comply with the Do Not Call Register Act 2006 (Cth), including sections 11 and 12, and with the Telecommunications (Telemarketing and Research Calls) Industry Standard 2017. The Spam Act 2003 (Cth) does not regulate voice calls.
8. Contact
End of AI processing disclosure