Terms of Use

Effective Date: April 2026 · Infohealth Ltd (Company No. 04004930) · Software as a Medical Device (SaMD) — Class I Medical Device

1. Introduction

These Terms of Use (“Terms”) govern the access to and use of the Pharmacy1st.ai platform (“the Platform”, “the Service”) by pharmacies, pharmacy organisations, and their authorised personnel (“you”, “the Customer”, “your Pharmacy”).

Pharmacy1st.ai is owned and operated by Infohealth Ltd, a company registered in England and Wales (Company No. 04004930), with its registered office at Lynwood House, 373–375 Station Road, Harrow, England, HA1 2AW, trading as Pharmacy1st.ai from 1st Floor Offices, 28 Chipstead Valley Road, Coulsdon, Surrey, CR5 2RA.

Pharmacy1st.ai is registered as a Software as a Medical Device (SaMD), classified as a Class I Medical Device in accordance with the Medical Devices Regulations 2002 (as amended) and Medicines and Healthcare products Regulatory Agency (MHRA) guidance.

By subscribing to, accessing, or using the Platform, you confirm that you have the authority to bind your pharmacy organisation and that you agree to be bound by these Terms. If you do not agree to these Terms, you must not access or use the Platform.

2. Description of the Service

Pharmacy1st.ai is a business-to-business (B2B) software-as-a-service (SaaS) platform that provides AI-powered clinical decision support to pharmacies participating in the NHS Pharmacy First programme. The Platform is designed to be used by pharmacies to offer consultations to their patients.

2.1 How the Platform Works

The Platform operates through the following process:

• Patient Consultation:The pharmacy’s patient engages with the Platform’s AI-driven consultation interface, which conducts a structured clinical assessment using natural language processing across the seven NHS Pharmacy First clinical pathways.
• Clinical Validation: The AI validates patient responses for completeness, consistency, and red-flag detection.
• PGD Eligibility Determination:A binary logic engine evaluates the patient’s eligibility against the inclusion and exclusion criteria of the applicable Patient Group Directions (PGDs).
• QA Document Output: The Platform generates a structured quality-assured (QA) document summarising the consultation findings, eligibility assessment, red-flag analysis, and a reasoned recommendation with full clinical rationale.
• Pharmacist Review and Decision: The pharmacist reviews the QA document as a clinical decision-support tool and exercises their own independent professional judgement to decide whether to prescribe, not prescribe, or refer the patient, under the terms of the relevant PGD.

2.2 Clinical Decision Support — Not Autonomous Prescribing

Pharmacy1st.ai is a clinical decision-support tool. It does not prescribe, diagnose, or make treatment decisions. The QA document produced by the Platform is an aid to the pharmacist’s clinical judgement — it is not a prescription, a diagnosis, or an instruction.

The final clinical decision on whether to prescribe under a PGD, to refer, or to take no action rests solely with the responsible pharmacist. No medication is dispensed or supplied without the pharmacist’s independent professional sign-off. The Platform cannot be bypassed in a way that removes the pharmacist from the prescribing decision.

3. Medical Device Classification

Pharmacy1st.ai is registered as a Class I Medical Device under the UK Medical Devices Regulations 2002 (as amended). As a Software as a Medical Device (SaMD), the Platform is designed to provide clinical decision support to qualified healthcare professionals and is not intended for direct use by patients without pharmacist oversight.

The Platform has been designed and developed in accordance with applicable MHRA guidance for SaMD, including clinical safety, risk management, and post-market surveillance requirements. The manufacturer is:

Infohealth Ltd
Company No. 04004930
Lynwood House, 373–375 Station Road, Harrow, England, HA1 2AW

4. Customer Eligibility

The Platform is available exclusively to:

• Pharmacies registered with the General Pharmaceutical Council (GPhC) in England
• Pharmacies enrolled in the NHS Pharmacy First programme
• Pharmacists and pharmacy staff authorised by the Customer pharmacy to access the Platform

The Customer warrants that all users accessing the Platform on its behalf are appropriately qualified, registered, and authorised to provide NHS Pharmacy First services.

5. Data Roles and Responsibilities

The data governance model under these Terms is as follows:

• The Customer (Your Pharmacy) is the Data Controller: For all purposes and intents, your pharmacy is the data controller in respect of all patient personal data and special category health data processed through the Platform. Your pharmacy determines the purposes and means of processing patient data and is responsible for ensuring a valid lawful basis exists, that patients are informed about how their data is used, and that all data subject rights requests are handled in accordance with the UK GDPR and the Data Protection Act 2018.
• Infohealth Ltd is the Data Processor:Infohealth Ltd processes patient personal data on behalf of and under the instructions of the Customer pharmacy. Infohealth Ltd does not determine the purposes or means of processing patient data and acts solely in accordance with the Customer’s documented instructions and the terms of the Data Processing Agreement (DPA) entered into between the parties.

A Data Processing Agreement in accordance with Article 28 of the UK GDPR will be provided to each Customer as a schedule to the subscription agreement and must be executed before the Platform is used to process patient data.

6. Customer Obligations

As a Customer of the Platform, you agree to:

• Ensure that only authorised, appropriately qualified pharmacy personnel access the Platform
• Act as data controller for all patient data processed through the Platform and comply with all applicable data protection legislation
• Ensure that patients are provided with appropriate privacy information (in the form of your own pharmacy privacy notice) before their data is submitted to the Platform
• Ensure that a registered pharmacist reviews every QA document produced by the Platform and exercises independent clinical judgement before making any prescribing decision under a PGD
• Not use the Platform for any purpose outside the scope of the NHS Pharmacy First programme
• Not reverse-engineer, decompile, disassemble, or otherwise attempt to derive the source code, algorithms, or underlying clinical logic of the Platform
• Report any suspected data breaches, clinical safety incidents, or adverse events relating to the Platform to us without undue delay
• Maintain current GPhC registration and NHS Pharmacy First programme enrolment throughout the term of the subscription

7. Pharmacist Responsibilities

The Platform produces a QA document that is designed to be used as a clinical decision-support tool. The pharmacist is required to:

• Review the complete QA document before making any prescribing decision
• Apply their own independent professional clinical judgement, taking into account the QA document, their knowledge of the patient, and any other relevant clinical factors
• Prescribe only where the pharmacist is personally satisfied that the patient meets the criteria of the relevant PGD and that prescribing is clinically appropriate
• Refer the patient where the QA document indicates referral, where red flags are identified, or where the pharmacist determines that referral is clinically necessary
• Document their prescribing decision in accordance with GPhC professional standards and NHS record-keeping requirements

The pharmacist retains full professional accountability for all prescribing decisions. The Platform does not diminish, transfer, or alter the pharmacist’s professional responsibility in any way.

8. Intellectual Property

All intellectual property in the Platform, including but not limited to the software, algorithms, clinical logic, AI models, user interface, branding, trademarks, documentation, and all associated materials, is and remains the exclusive property of Infohealth Ltd or its licensors.

The Customer is granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform for the duration of the subscription, solely for the purpose of providing NHS Pharmacy First consultations within the Customer’s pharmacy.

The Customer may not reproduce, distribute, sublicence, modify, create derivative works of, or otherwise exploit any part of the Platform without the prior written consent of Infohealth Ltd.

9. Clinical and Medical Disclaimer

Pharmacy1st.ai is a clinical decision-support tool. It does not provide medical diagnoses, prescriptions, or treatment plans. The QA document generated by the Platform is an aid to pharmacist decision-making and does not constitute medical advice.

The Platform is not a substitute for the pharmacist’s own clinical assessment. The pharmacist must not rely solely on the QA document and must exercise independent professional judgement in all cases.

Pharmacy1st.ai does not provide emergency medical services. Where the Platform identifies a potential emergency or serious clinical concern, it will flag this in the QA document. However, it remains the pharmacist’s responsibility to take appropriate action, including directing the patient to call 999 or attend A&E.

Infohealth Ltd does not accept clinical liability for prescribing decisions made by pharmacists using the Platform. Clinical liability for prescribing under a PGD remains with the pharmacist and/or the pharmacy organisation in accordance with the applicable PGD framework and GPhC professional standards.

10. Availability and Service Levels

We aim to maintain Platform availability 24 hours a day, 7 days a week. However, we do not guarantee uninterrupted or error-free access. We reserve the right to suspend or restrict access for maintenance, updates, security patches, or regulatory compliance, with reasonable notice where practicable.

Specific service level commitments, including uptime targets and support response times, are set out in the Customer’s subscription agreement.

We shall not be liable for any loss or inconvenience arising from the Platform being temporarily unavailable, except as expressly provided in the subscription agreement.

11. Limitation of Liability

To the maximum extent permitted by law:

• Infohealth Ltd provides the Platform on an “as is” and “as available” basis, without warranties of any kind, whether express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement
• Infohealth Ltd shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or connected with the Customer’s use of the Platform
• Infohealth Ltd’s total aggregate liability under these Terms shall not exceed the fees paid by the Customer in the twelve (12) months preceding the claim, except where a lower or higher cap is specified in the subscription agreement
• Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited under English law
• Clinical liability for prescribing decisions made under PGDs remains with the pharmacist and the Customer pharmacy; Infohealth Ltd does not accept liability for clinical outcomes resulting from prescribing decisions

12. Indemnification

The Customer agrees to indemnify and hold harmless Infohealth Ltd, its directors, officers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in any way connected with:

• The Customer’s breach of these Terms
• Prescribing decisions made by the Customer’s pharmacists
• Failure to comply with data protection legislation in the Customer’s capacity as data controller
• Failure to ensure adequate pharmacist oversight of Platform outputs
• Any claim by a patient arising from the Customer’s use of the Platform

13. Confidentiality

Each party agrees to keep confidential all information of a confidential nature disclosed by the other party, including business information, technical data, clinical logic, pricing, and patient data. This obligation does not apply to information that is publicly available, independently developed, or required to be disclosed by law, regulation, or professional obligation.

14. Third-Party Services

The Platform may integrate with third-party services, including NHS systems (such as the Electronic Prescription Service, GP Connect, and NHS Spine), cloud infrastructure providers, and AI model providers. We are not responsible for the availability or performance of third-party services. Where applicable, third-party processing is governed by our Data Processing Agreement and sub-processor disclosures.

15. Term and Termination

The subscription term is as specified in the Customer’s subscription agreement. These Terms remain in effect for the duration of the subscription.

We may suspend or terminate access to the Platform immediately if:

• The Customer materially breaches these Terms and fails to remedy the breach within 14 days of written notice
• The Customer’s GPhC registration is suspended, revoked, or lapses
• The Customer is no longer enrolled in the NHS Pharmacy First programme
• Continued access poses a risk to patient safety, data security, or regulatory compliance

Upon termination, the Customer’s access to the Platform ceases immediately. Data retention and return obligations are governed by the Data Processing Agreement.

16. Changes to These Terms

We reserve the right to update or modify these Terms at any time. Material changes will be communicated to the Customer in writing with at least 30 days’ notice. Continued use of the Platform following the effective date of any changes constitutes acceptance of the revised Terms.

17. Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of England and Wales. Any disputes arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

18. Regulatory Information

Pharmacy1st.ai is operated by Infohealth Ltd.

• Infohealth Ltd is registered with the General Pharmaceutical Council (GPhC) under registration number 1036487
• Pharmacy1st.ai is a registered Class I Medical Device (Software as a Medical Device) in accordance with the UK Medical Devices Regulations 2002 (as amended) and MHRA guidance
• The Platform is designed to comply with NHS England specifications for the Pharmacy First programme
• The manufacturer of the medical device is Infohealth Ltd, Lynwood House, 373–375 Station Road, Harrow, England, HA1 2AW

19. Contact Us

If you have any questions about these Terms of Use, please contact us: