AI Policy
1. Purpose
This policy outlines the responsible use of artificial intelligence (AI) tools, specifically Owl Practice’s Smart Notes feature, within this psychotherapy practice. It ensures compliance with applicable legislation, regulatory standards, and professional ethics, while safeguarding client privacy, confidentiality, and trust.
2. Scope
• Applies to all psychotherapy services delivered by the practice.
• Covers the use of Owl Practice’s Smart Notes AI tool for recording, transcribing, and summarizing sessions into case notes.
• Applies to all client information collected, stored, and processed through AI systems.
3. Relevant Legislation and Standards
This policy is guided by:
• Federal: Personal Information Protection and Electronic Documents Act (PIPEDA).
• Provincial (Ontario): Personal Health Information Protection Act (PHIPA).
• IPC Guidelines: Best practices for safeguarding personal health information and ensuring transparency in digital health tools.
• Professional Standards: Ontario College of Social Workers and Social Service Workers (OCSWSSW) Code of Ethics and Standards of Practice, including requirements for confidentiality, informed consent, and accurate record-keeping.
4. AI Use in Practice
• Smart Notes Functionality: AI is used to transcribe and summarize psychotherapy sessions into draft case notes. These notes are intended to support clinical documentation but do not replace the clinician’s professional judgment.
• Clinician Oversight: All AI-generated notes must be reviewed, edited, and approved by the clinician before being finalized in the client record.
• Accuracy and Integrity: The clinician is responsible for ensuring that case notes are accurate, complete, and reflective of the therapeutic process.
5. Privacy and Confidentiality
• Data Handling: Client information processed by Smart Notes is considered personal health information (PHI) under PHIPA. It must be protected with appropriate safeguards.
• Storage and Security: Owl Practice is a PHIPA-compliant platform. AI-generated notes are stored securely within the system, with encryption and access controls.
• Third-Party Processing: Clients are informed that AI tools may process their information. The practice ensures that Owl Practice and its AI features comply with PHIPA and PIPEDA requirements.
6. Informed Consent
Client Disclosure: Clients are informed, at intake, that AI tools may be used to assist with documentation. They are advised that:
• AI-generated notes are drafts, not final records.
• The clinician reviews and validates all notes.
• Their confidentiality is protected under PHIPA and professional standards.
• Right to Decline: Clients may request that AI tools not be used for their sessions. In such cases, the clinician will rely solely on manual note-taking.
7. Professional Responsibility
• Clinical Judgment: AI tools are supportive, not decision-making. The clinician retains full responsibility for assessment, diagnosis, treatment planning, and documentation.
• Ethical Standards: Use of AI must align with OCSWSSW standards, including respect for client dignity, autonomy, and confidentiality.
• Transparency: The clinician must be clear with clients about how AI is used and ensure that its use does not compromise therapeutic trust.
8. Risk Management
• Bias and Errors: AI outputs may contain inaccuracies or biases. Clinicians must critically evaluate and correct notes before finalizing.
• Audit and Review: The practice will periodically review AI use to ensure compliance with legislation, IPC guidelines, and professional standards.
• Incident Response: Any breach of privacy or misuse of AI tools will be reported to the IPC as required under PHIPA and addressed promptly.
9. Policy Review
This policy will be reviewed annually, or sooner if:
• Legislation or regulatory standards change.
• Owl Practice updates its AI features.
• New risks or ethical concerns emerge regarding AI in psychotherapy.
10. Summary Statement
AI tools such as Smart Notes are used to enhance efficiency in documentation but do not replace the clinician’s professional expertise. The practice is committed to protecting client privacy, ensuring informed consent, and maintaining compliance with Ontario’s legal and ethical standards.