AI phone assistants and PHIPA: a checklist for Ontario clinics

An AI assistant that books appointments can take real pressure off a front desk. It also becomes a processor of your patients' personal health information, so it has to be chosen like any other system that touches patient data. This checklist is a starting point, not legal advice.

You stay the custodian

Under PHIPA, a clinic remains responsible for the personal health information in its custody when it uses an AI system, and its obligations continue to apply (Norton Rose Fulbright on the Ontario IPC's AI guidance). The vendor acts as your agent or service provider, and that needs a written agreement.

The checklist

1. Privacy impact assessment. Ontario's Information and Privacy Commissioner treats AI tools that process health information as new processors that need a PIA, vendor due diligence and an acceptable-use policy before deployment (source).
2. Where the data goes. Ask where records are stored and where the live audio is processed. The IPC's 2026 guidance flags cross-border data flows as a high-risk factor; PHIPA doesn't forbid processing outside Canada, but you must know about it and have safeguards in the contract.
3. Collect the minimum. Booking needs a name, a phone number, a visit type and a time. It doesn't need symptoms, a health card number or a date of birth on the phone.
4. No clinical advice. The assistant should never diagnose, say whether something can wait, or discuss results or medications.
5. Emergencies first. Chest pain, trouble breathing, stroke signs: "hang up and call 911". A mental-health crisis: 988.
6. Other people's information. It should never confirm whether someone is a patient or discuss someone else's appointment.
7. Retention and audit logs. How long transcripts are kept, and whether you can see who viewed them.
8. AI disclosure. Patients should be told they're speaking with an AI assistant, and be able to reach a person.

How Notanai handles it

Our clinic assistant collects only what booking needs (a short reason category at most), never gives medical advice, sends emergencies to 911 or 988, says it's an AI at the start of every call, stores bookings and transcripts in Canada (Toronto), deletes transcripts after 30 days and logs who viewed each one. The live voice conversation is processed by Google's AI service, which may process audio outside Canada; we don't keep recordings. We complete a PIA and a service agreement with each clinic before going live.