AI Governance for Healthcare

Helping Alberta clinics navigate
AI scribe compliance.

If your clinic uses an AI scribe, Alberta's Health Information Act requires a Privacy Impact Assessment before implementation. We guide physicians through the process from start to OIPC submission — so you can focus on patients.

The Requirement

What Alberta physicians need to know.

AI scribes are making a real difference in clinics across Alberta — reducing documentation time, easing burnout, and letting physicians focus on patients. But these tools record patient conversations and transmit health information to third-party vendors, which triggers specific obligations under the Health Information Act that most clinics haven't yet addressed.

Do I need a separate PIA for my AI scribe?
Yes. Your existing EMR PIA doesn't cover it. The AI scribe involves different data flows, a different vendor relationship, and different privacy risks — including audio recording and third-party processing. The OIPC requires a separate submission.
I got my scribe through the Infoway program. Am I covered?
No. Infoway has distributed over 10,000 free licenses nationally, but compliance remains entirely the physician's responsibility. The OIPC has confirmed it has not reviewed any vendor products in the program.
What goes into an AI scribe PIA?
The OIPC published specific guidance in September 2025. A compliant submission addresses data flows, vendor obligations under Section 66, patient consent, collection limitations, how you handle AI-generated errors, security safeguards, breach procedures, and ongoing review processes.
What if I've been using the scribe without one?
Most clinics are in the same position. The law requires submission before implementation, so getting current is important. It's significantly easier to submit proactively than to respond to a complaint or investigation without a PIA on file.
Can I complete the PIA myself?
The OIPC provides a general template. But an AI scribe PIA involves nuances — Cloud Act implications, vendor IMA requirements, data residency — that the template doesn't address. Most clinics find it more efficient to work with a specialist.
What We Do

AI scribe compliance, handled for you.

We work with privacy specialists who have direct experience with AI scribe vendors, HIA requirements, and OIPC submissions.

Privacy Impact Assessments

Full AI scribe PIAs drafted to the OIPC's September 2025 guidance. We conduct intake, map your data flows, draft the assessment, manage revisions, and submit to the OIPC on your behalf.

Vendor & Contract Reviews

Your AI scribe vendor handles patient data on your behalf. We review your vendor agreement and Information Manager Agreement against HIA Section 66 requirements.

Policies & Documentation

Patient consent forms, collection notices, privacy policies, and breach response plans — drafted specific to your AI scribe implementation and aligned with HIA obligations.

How It Works

Four steps. Minimal time on your end.

Your main involvement is one intake session and reviewing the draft. We handle everything else.

1

Compliance Check

A free conversation to assess where your clinic stands. If you're already covered, we'll tell you.

2

Intake Session

45 minutes with the lead physician to understand your setup, vendor, and workflow.

3

Drafting & Review

Our specialist drafts the PIA and all supporting documents. You review and provide feedback.

4

OIPC Submission

We submit on your behalf and handle any follow-up. You're compliant.

Pricing

Fixed fees. No surprises.

Every engagement includes specialist drafting, all supporting documentation, and OIPC submission. You'll know the cost before we begin.

PIA Update
Existing PIA needs an AI scribe addendum
$1,500
Fixed fee · 2–3 weeks
  • Review existing PIA against Sept 2025 guidance
  • AI scribe addendum drafted
  • Updated vendor assessment
  • OIPC submission
  • One revision round
Inquire
AI Scribe Compliance
Single physician · Single AI scribe tool
$3,900
Fixed fee · 4–6 weeks
  • Full PIA to OIPC AI Scribe Guidance
  • Vendor agreement & IMA review
  • Data flow diagrams
  • Patient consent forms & collection notices
  • Privacy policies & breach response plan
  • Two revision rounds
  • OIPC submission & follow-up
Book a Conversation
Multi-Tool Compliance
Multiple AI tools or physicians
$6,500
Fixed fee · 6–8 weeks
  • Everything in AI Scribe Compliance
  • Multi-vendor data flow mapping
  • Cross-tool compliance analysis
  • Staff training materials
  • Extended revision rounds
  • Dedicated project coordinator
Inquire
Ongoing AI Governance

Privacy compliance doesn't stop at submission.

AI regulations in Alberta are evolving quickly. The OIPC issued AI scribe guidance in September 2025 and proposed AI-specific legislation in December 2025. Provincial privacy management programs become mandatory in June 2026.

Meanwhile, your AI scribe vendor pushes updates, enables new features, and changes how data flows through their system. Each change can affect your PIA's accuracy — and the OIPC expects your PIA to reflect your current environment.

For clinics that want to stay ahead of these changes, we offer an ongoing governance partnership that keeps your compliance current as the landscape evolves.

$249/mo
or $2,500/year (save $488)
  • Quarterly compliance reviews
  • PIA amendments when vendors update
  • Regulatory change alerts & impact briefs
  • Annual gap analysis refresh
  • Priority support — 24hr response
  • Vendor contract review on renewal
  • Breach response guidance
Ask About Governance
Available to clinics with a completed Coda PIA engagement.

The AI scribe PIA requirement is confirmed by the following Alberta regulatory and professional bodies.

OIPC Alberta CPSA Alberta College of Family Physicians Alberta Medical Association HIA Section 64