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Responsible AIEU AI Act · ISO 42001

AI Model Register

A complete register of third-party AI providers used by October Health, maintained in accordance with the EU AI Act and ISO 42001.

01Providers3 registered

OpenAI

Training opt-out confirmed

Models

GPT-5.2GPT-5.3SoraDALL-E 3Realtime Voice

Deployment contexts

Luna agentAsh agentDocument AI

Purpose within October Health

  • Luna conversational AI (emotional support, check-ins)
  • Ash coaching and L&D content generation
  • HR document summarisation
  • Assessment analysis

Data processing

PropertyValue
Training opt-outYes (contractual)
Conversation loggingDisabled
Data retention30 days
DPA in placeYes
International transfersStandard Contractual Clauses (SCCs)

EU AI Act risk classification

Limited Risk (EU AI Act)

Hiring-support features using OpenAI models are classified High Risk and subject to additional human oversight.

Last reviewed: February 2025

Google Gemini

Training opt-out confirmed

Models

Gemini 2.5 FlashGemini 3.0 FlashGemini 3.0 Pro

Deployment contexts

Ivy agentBenchmark reports

Purpose within October Health

  • Ivy AI Dietitian — nutritional advice and meal planning
  • Multimodal document understanding
  • Workplace Wellbeing Benchmark analysis

Data processing

PropertyValue
Training opt-outYes (contractual)
Conversation loggingDisabled
Data retentionZero retention
DPA in placeYes
International transfersStandard Contractual Clauses (SCCs)

EU AI Act risk classification

Limited Risk (EU AI Act)

Nutritional advice is presented as informational; clinical dietary decisions remain with registered professionals.

Last reviewed: February 2025

Anthropic

Training opt-out confirmed

Models

Claude Opus 4.5Claude Opus 4.6

Deployment contexts

Crisis detection layerInternal AI toolingAgent orchestration

Purpose within October Health

  • Complex reasoning tasks within agent pipelines
  • Safety-critical response generation (crisis detection layer)
  • Long-context document analysis
  • AI governance tooling (internal)

Data processing

PropertyValue
Training opt-outYes (contractual)
Conversation loggingDisabled
Data retentionZero retention
DPA in placeYes
International transfersStandard Contractual Clauses (SCCs)

EU AI Act risk classification

High Risk where used in crisis/safeguarding context; Limited Risk otherwise

Crisis detection outputs are always reviewed by a human before any action is taken.

Last reviewed: February 2025

02Data processing statement

No data used for training

October Health does not share user conversation content with any third-party AI provider for the purpose of model training. This is enforced contractually via Data Processing Agreements with each provider and verified during our quarterly audit cycle.

All providers listed above have confirmed in writing that October Health data is excluded from their training pipelines. We use API-tier access with zero or minimal data retention, ensuring that conversation content is not stored beyond what is necessary for immediate processing.

Register last updated February 2025 · reviewed quarterly and whenever a provider relationship changes.