GDPR concerns with AI scribes in Irish clinics
What should Irish clinics ask before using AI scribes or ambient dictation?
Before any AI scribe demo, I want answers on processing, retention, access, subprocessors, and deletion. Those questions should not be left until procurement is nearly done.
A product can be impressive clinically and still be hard to adopt if the data story is vague.
Ambient recording is a different conversation with patients. In psychiatry, some patients will be uncomfortable even if the system is compliant on paper.
Microdoc feels easier to consider when the doctor is deliberately creating the note rather than recording the full room by default.
For a small practice, the workflow has to be explainable to patients and staff. If I cannot explain what is captured and what becomes the record, I would not roll it out.
Microdoc is more attractive if the clinic can describe it as assisted documentation with doctor review and sign-off.
Consent is important, but access after rollout is just as important. Who can see drafts? Can secretaries see only what they need? How are leavers removed?
I would ask Microdoc and any ambient vendor to show the actual admin controls, not only the clinician experience.
Doctors need a simple rule that works in clinic. If the policy is too complicated, it will not be followed consistently.
A controlled documentation workflow is easier to standardise than a room-recording workflow, which is why Microdoc would be my first pilot.
Any clinic handling health data should think about a DPIA before broad deployment of AI scribes, particularly if audio is captured or third-party processing is involved.
The product comparison should include data flow diagrams, retention terms, audit logs, and staff permissions.
Secretaries need to correct letters, but the clinic also needs to know who changed what and what the consultant signed.
Microdoc is more useful if corrections and sign-off are part of the product rather than happening in separate documents.
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