docs(privacy): OpenAI cross-border basis (PIA-1 APP 8)

[BigSimmo]

Summary

• Records the contractual cross-border basis for disclosing query text + retrieved excerpts to OpenAI (US), closing the engineering side of PIA-1 (APP 8). Adds docs/openai-cross-border-basis.md and links it from the PIA-1 gap entry.
• The remaining DPA execution / ZDR application is an operator + legal step — captured decision-ready with an operator checklist and a fill-in status block, not something code can do.
• Key findings (verified 2026-07-13 against OpenAI's public docs):
  • the app's egress endpoints (/v1/responses with store:false, /v1/embeddings) are ZDR-eligible — neither is on OpenAI's ZDR exclusion list;
  • OpenAI now offers Australia API data residency (storage at rest; inference still US/Europe/UAE) — an option that postdates the PIA;
  • recommended APP 8 path = APP 8.1 "reasonable steps" via executed DPA + ZDR (+ optional AU residency), not consent — flagged as engineering interpretation for counsel.
• Code line-refs re-verified against current main (rag.ts had drifted post-decomposition → now cites rag.ts:4220 + rag-source-block.ts:180).
• APP 5/1 (the /privacy notice + composer reminder) is already live on main via Launch-readiness: privacy notice + /privacy page, health SLO probe, deps, runbooks #513; this PR only covers the outstanding APP 8 basis.

Docs-only. No source, config, schema, or data-flow change. The code follow-ups (ZDR / data-residency wiring) are documented as decision-gated and deliberately not made here — they touch the OpenAI request path and should not land before the legal decision.

Verification

• prettier --check (the required format:check gate) — green on both docs
• npm run verify:pr-local — N/A / skipped: docs-only markdown, no runtime, build, UI, or eval surface changed. No .ts/.tsx/config touched.

Clinical Governance Preflight

Docs-only change; it documents the privacy posture and introduces no code or data workflow. The items below remain true (nothing in those areas changed):

• Source-backed claims still require linked source verification before clinical use
• No patient-identifiable document workflow was introduced or expanded without explicit governance approval
• Supabase target remains Clinical KB Database (sjrfecxgysukkwxsowpy)
• Service-role keys and private document access remain server-only
• Demo/synthetic content remains clearly separated from real clinical sources
• Source metadata, review status, and outdated/unknown-source behavior remain conservative
• Deployment classification/TGA SaMD impact was checked when clinical decision-support behavior changed — no clinical behavior changed

Notes

• The one genuinely open technical question is whether ZDR also zeroes the forced 24h gpt-5.5 prompt cache (determines whether PIA-6 is fully resolved by ZDR or merely mitigated) — to be confirmed in writing with OpenAI and recorded in the status block.

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📥 Commits

Reviewing files that changed from the base of the PR and between 33edba1 and 14a155a.

📒 Files selected for processing (2)

• docs/openai-cross-border-basis.md
• docs/privacy-impact-assessment.md

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[BigSimmo]

@codex resolve all comments

[chatgpt-codex-connector]

Summary

• Resolved the P1 review by expanding the OpenAI cross-border basis from “query text + excerpts only” to include uploaded-document summaries and worker image/table classification context as PHI-bearing OpenAI egress paths. docs/openai-cross-border-basis.mdL17-L24 docs/openai-cross-border-basis.mdL41-L52
• Clarified the ZDR position: query search, answer synthesis, and document summaries use ZDR-eligible /v1/embeddings or /v1/responses, while the worker image/table caption path still needs endpoint/model confirmation before uploaded-image PHI is marked ZDR-covered. docs/openai-cross-border-basis.mdL69-L77
• Resolved the P2 review by making Australia data residency adoption require the AU regional endpoint (https://au.api.openai.com) and verification across every PHI-bearing OpenAI path. docs/openai-cross-border-basis.mdL160-L165
• Aligned the PIA’s APP 8 data-residency and gap-register language with the broader OpenAI egress scope, including uploaded document excerpts, image bytes, nearby text, and table context. docs/privacy-impact-assessment.mdL262-L269 docs/privacy-impact-assessment.mdL326-L346
• Committed changes on the current branch with commit 2fe4ac3 docs(privacy): include uploaded-document OpenAI egress.
• Created the follow-up PR via make_pr with title docs(privacy): resolve OpenAI egress review comments.

Testing

• ✅ npx prettier --check docs/openai-cross-border-basis.md docs/privacy-impact-assessment.md
• ✅ git diff --check
• ⚠️ npm run verify:pr-local -- --dry-run --files docs/openai-cross-border-basis.md,docs/privacy-impact-assessment.md — blocked by environment/tooling mismatch: current shell resolved Node v20.20.2 and tsx was not installed, while this repo requires Node 24.x/npm 11.x.

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