Privacy, Security, and Privacy Impact Assessment (PIA) Requirements for the AI Scribe Program

August 13, 2025

About the AI Scribe Program

Canada Health Infoway’s AI Scribe Program is a national initiative designed to help reduce administrative burden for primary care clinicians by funding the use of pre-qualified AI-powered medical scribe solutions. The program enables eligible clinicians to choose from nine pre-qualified vendors whose solutions meet baseline clinical, technical, and privacy/security requirements.

Privacy, Security, and PIA Requirements

Primary care clinicians who want to use one of the nine pre-qualified AI Scribe solutions must ensure that their use of it complies with the legislative requirements in their respective jurisdictions prior to using the scribe service.

Some jurisdictions mandate the development of Privacy Impact Assessments (PIAs). Information and Privacy Commissioners in other jurisdictions recommend PIAs as best practice. It is the custodian’s responsibility to determine whether a PIA must be developed in accordance with their jurisdiction’s legislative requirements.

Regardless of whether a PIA is mandated, custodians must ensure that their use of an AI Scribe tool complies with their privacy law obligations to protect patients’ privacy prior to using the AI Scribe tool.

External Guidance & Resources

General Guidance on AI Use in Clinical Practice

 Legal and Privacy Resources

Guidance from Information and Privacy Commissioners (OIPC)

 Regulatory College Guidance on AI Scribes / AI in Clinical Practice

Medical Association Guidance on AI Scribes / AI in Clinical Practice

Note:
Information and Privacy Commissioners in all jurisdictions provide guidance documents and/or templates for developing PIAs, including where PIAs are not legally required. Infoway encourages all custodians to review these resources before adopting an AI Scribe solution.

All links and resources in this statement are current as of August 13, 2025. Privacy, security, and legislative requirements, as well as related guidance documents, may change over time. Custodians and clinicians are encouraged to verify the currency and applicability of these materials before relying on them, and to consult the relevant jurisdictional or organizational sources for the most up-to-date information.