Developing Privacy Impact Assessments for AI Scribe Tools
The Office of the Information and Privacy Commissioner (OIPC) of Alberta has issued a guidance document that will assist custodians under the Health Information Act (HIA) in ensuring they are compliant with HIA when using AI scribe tools.
Under the HIA, custodians are required to submit to OIPC privacy impact assessments (PIAs) that describe the effect of any proposed administrative practice or system or change in administrative practice or system involving the collection, use and disclosure of individually identifying health information. This means that custodians must submit a PIA on any implementation and use of AI scribe tools.
Artificial intelligence (AI) scribe tools transcribe and summarize interactions between people. In the case of custodians, such as dentists, the AI scribe tool would listen to and record conversations with patients, which would generally include sensitive information, and would then transcribe those conversations into a summarized text file, which is stored with the patients’ medical records. AI scribe tools have other capabilities as well, including generating prescriptions and referral letters, and integrating diagnostic images into records.