Crisis detection: limits and responsibility
A counsel-reviewed, plainly worded statement of what the platform's automated crisis detection is, what it is not, and where the boundary of First Six's responsibility sits relative to the institution's own duty of care.
What this policy commits us to
- Detection is a per-tenant text-pattern match run twice — in the student's app and again on the server; the server can only ever upgrade a request to crisis, never downgrade.
- Deliberately biased toward over-flagging: the cost of a missed crisis is far higher than a handled false positive.
- Explicitly not a clinical assessment tool, not a substitute for care, and not exhaustive — indirect phrasing can and will be missed.
- The institution is the care provider and data controller; automated detection does not discharge its duty of care.
- A staff-initiated escalation path exists as the safety net, firing the same responder fan-out.
Controls mapped to this policy
Mapping controls to the policy is how we check adherence. A green dot marks a control that is operating and traceable to evidence; an amber dot marks one that is documented and scheduled but has not run yet.
Standards mappings
Through its controls, this policy maps to the following standards and frameworks. Each entry states our real relationship with the standard.
ISO/IEC 27001:2022InfoSec complianceSelf-assessed
A full 93-control Annex A Statement of Applicability is maintained and honestly dispositioned, and the ISMS went live on 26 July 2026 with its first completed management review. Not certified: no external audit has occurred, the clause 9.2 internal audit is openly unmet, and the certification trigger (a named tender, funding, or first hire) was formally decided at the first management review.
- A.8.16Monitoring activities
- 9.1Monitoring, measurement, analysis, evaluation
Australian Privacy Act 1988 (APPs, incl. the NDB scheme)PrivacyApplicable law
The primary legal regime. APP 8 drives the residency objective and every disclosed cross-border flow, APP 11 drives retention and erasure, and the Notifiable Data Breaches scheme's assessment clock is built into the incident runbook with OAIC contacts documented. The privacy policy, terms, and DPA template are counsel-reviewed and approved.
- APP 1Open and transparent management of personal information
GDPR (EU General Data Protection Regulation)PrivacyApplicable law
Applies via international students. The 72-hour breach path is in the incident runbook, Article 28 processor terms sit in the counsel-approved DPA, Article 17 erasure maps to the student's own hard-delete cascade (with the audit-trail carve-out disclosed rather than hidden), and Article 22-equivalent disclosure covers automated crisis detection.
- Art. 22Automated decision-making disclosure (equivalence)
Request access and we can share the full policy set, assessment reports, and completed questionnaires under NDA — or answer your security questionnaire directly.