Privacy and safety

Security checklist for AI clinical documentation tools

Security review should follow the information from capture to deletion. Start with strong account controls, then verify technical and organizational safeguards, vendor access, logging, incident obligations, recovery, and evidence that controls work in practice.

Reading time
3 minutes
Updated
01

Identity and access

Email-based verification or two-factor authentication depends on the security of the user's mailbox. Require strong email protection, current recovery information, screen lock, device updates, and prompt reporting of lost devices or unexpected codes.

  • Individual accounts; no shared clinical or administrative credentials.
  • Two-factor authentication for sensitive access and protected email accounts.
  • Role-based access aligned with job responsibilities.
  • A controlled invitation, role-change, leave, and offboarding process.
  • Session protection, secure password reset, and monitoring for suspicious sign-in.
02

Data and technical safeguards

Ask what happens at the application layer, not only the hosting layer. A secure cloud provider does not automatically secure the vendor's authorization checks, code, support process, or configuration.

  • Encryption in transit and at rest, with documented key and secret management.
  • Tenant and object-level authorization tested on every sensitive route.
  • Secure upload limits, validation, malware controls where appropriate, and safe file handling.
  • Rate limits, abuse controls, dependency management, and timely vulnerability response.
  • Environment separation, protected deployment credentials, backups, and recovery testing.
03

Vendor and subprocessor assurance

  • Current list of subprocessors, processing locations, purposes, and change notice.
  • Restrictions on vendor workforce access and a logged approval process.
  • Contractual confidentiality, safeguards, incident notification, return, and destruction terms.
  • Independent assurance relevant to the actual service scope, with exceptions reviewed.
  • Clear model-provider terms, including whether customer information is used for training.
04

Detection and incident response

  1. 01

    Detect

    Define which access, administrative, export, deletion, and processing events are logged and who reviews meaningful signals.

  2. 02

    Contain

    Know how to suspend an account, revoke sessions, stop a workflow, preserve evidence, and contact the vendor.

  3. 03

    Assess

    Identify the information, people, systems, time period, cause, and ongoing risk without spreading more sensitive data.

  4. 04

    Notify and report

    Follow PHIPA, contract, insurer, regulator, law-enforcement, and patient-notification requirements as applicable.

  5. 05

    Learn

    Correct the control weakness, verify the fix, document decisions, and monitor for recurrence.

05

Retention, continuity, and exit

  • Approved retention and deletion rules for each data type and backup.
  • A tested way to export required records in a usable form.
  • Downtime procedures that do not depend on the unavailable system.
  • Recovery objectives appropriate to the workflow and evidence that restore works.
  • A contract-exit plan covering access removal, data return, deletion, and confirmation.

Sources and further reading

Sources were checked on . External guidance can change; open the source before relying on it.

  1. Baseline cyber security controls for small and medium organizationsCanadian Centre for Cyber Security
  2. Protecting Personal Health InformationCollege of Physicians and Surgeons of Ontario
  3. Privacy Breach ProtocolInformation and Privacy Commissioner of Ontario

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