PHIPA, PIPEDA and Law 25: What Compliant AI Documentation Actually Requires

When an AI tool touches patient health information in Canada, three laws apply: PHIPA in Ontario, PIPEDA federally, and Law 25 in Québec. They are not interchangeable, and a tool built outside Canada rarely satisfies all three. Compliant AI documentation is a design decision, not a checkbox.

The single most important requirement is that patient data stays in Canada. DoctorScribe runs entirely on Canadian servers — processing, storage and the AI models themselves. Consultation audio is processed in memory and never written to disk, and patient identifiers are encrypted at rest.

Compliant systems send the AI only what it needs. Before any AI step, DoctorScribe anonymises patient identifiers — the model sees a pseudonym, never a real name. This data-minimisation principle runs through PHIPA, PIPEDA and Law 25 alike.

Law 25 in particular raised the bar for Québec: stronger consent, breach reporting, and the right to data portability and erasure. A scribe serving Québec must meet it — the same scribe that produces a bilingual clinical note must also honour Law 25.

Regulators expect a trail. Every access and change should be logged, and a patient should be able to request an export or an erasure of their data. Compliance is not a feature you add at the end — it is the architecture. That is why DoctorScribe was built compliance-first; see the features page for the full picture, or open a free account to review it yourself.