Canada Health Infoway Supports AI Scribe Implementation in Alberta with Reference to OIPC Privacy Guidance

Infoway acknowledges and appreciates the release of the Artificial Intelligence (AI) Scribe Privacy Impact Assessment Guidance developed by the Office of the Information and Privacy Commissioner (OIPC) of Alberta. This guidance provides health information custodians with a clear framework to assess and mitigate privacy risks associated with the implementation of AI scribe tools.

Infoway will use the published guidance to:

• Prepare a standardized Privacy Impact Assessment (PIA) template for use by participating vendors and custodians in Alberta;
• Support the selected AI Scribe Program vendors in preparing PIA materials in accordance with OIPC guidance; and  
• Continue working with OIPC of Alberta to streamline the process for submission and evaluation of the PIAs.

The AI Scribe Program is a national initiative providing fully funded, one-year licenses for AI-powered documentation tools to eligible primary care clinicians across Canada, including family physicians, nurse practitioners, registered nurses in remote communities, and pediatricians providing longitudinal, community-based care. These tools help automate common documentation tasks such as clinical notetaking, appointment preparation, and follow-up summaries, reducing administrative workload and supporting more patient-focused care.

Under Alberta’s HIA, health information custodians are required to submit a PIA to the OIPC that describes the potential effects of any proposed administrative practice or system – or any change to an existing practice or system – before implementation, if it involves the collection, use, or disclosure of individually identifying health information. This includes the implementation of AI Scribe tools. 

While easing administrative burden for clinicians is a key goal of the AI Scribe Program, Infoway recognizes that the use of AI technologies introduces new privacy considerations that must be carefully addressed to protect patient data.

Infoway has conducted a national procurement process to identify vendors that meet robust evaluation criteria in relation to clinical usability, privacy, cybersecurity and interoperability.

In Alberta, Infoway is taking additional steps to support compliance with jurisdiction-specific obligations and to ease administrative burden on clinicians. This includes working with vendors to ensure their tools can be deployed in a way that aligns with Alberta’s HIA and supporting them in developing standardized documentation that will assist custodians in completing PIAs consistent with the expectations outlined in the OIPC’s AI Scribe Privacy Impact Assessment Guidance.

Infoway appreciates the OIPC’s efforts in publishing this guidance, which helps enable the safe and effective use of AI scribe tools in clinical practice.

Custodians and vendors are expected to understand and meet jurisdictional privacy obligations, including ensuring appropriate safeguards are in place when integrating AI scribe technologies into clinical practice. Infoway continues to support custodians and vendors by providing tools, templates, and guidance aligned with jurisdictional privacy obligations and applicable legislation. 

Learn more:

• Infoway’s AI Scribe Program
• This email address is being protected from spambots. You need JavaScript enabled to view it.
• Information on privacy, security, and privacy impact assessment (PIA) requirements for the AI Scribe Program
• Information on the OIPC and Alberta’s PIA requirements

About Canada Health Infoway

At Canada Health Infoway (Infoway) we believe a more connected and collaborative system is a healthier system, and one that leads to better health outcomes for all Canadians. By leveraging digital technologies and innovations, we’re working with governments, healthcare organizations, clinicians, and patients to advance connected care across the country. This improves care coordination, empowers patients to have a more active role in managing their health, and equips care providers with information and insights to support better care both at the point of care and throughout their patients' health journey. Most importantly, it modernizes our health care system towards a future with patient-centered care at its heart.

We’re an independent, not-for-profit organization funded by the federal government and accountable to our Board of Directors and Members of the Corporation (Canada’s 14 federal, provincial and territorial deputy ministers of health). Infoway is led by a team of seasoned professionals who are specialists in their respective fields, including health care, administration, information technology and privacy. Visit us online at www.infoway-inforoute.ca.

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