DPIA summary
Our own assessment of Chronix Scribe, summarised under clause 15 of the data processing agreement. For patient data you are the controller and we, Chronix Health Group Ltd, are the processor. You remain responsible for your own assessment.
The processing
With everyone's consent, a clinician starts capture. Speech is transcribed in memory by a speech-to-text service in Europe. The transcript text goes to an AI service that drafts a note from what was said, each diagnosis, medicine, dose and plan linked to the transcript; anything that cannot be linked is removed with a visible marker. Every draft is labelled AI-generated: review before signing and stays a draft until the clinician reviews, edits and signs it.
- Purpose: faster clinical documentation, with the clinician in control.
- Data: transcript text, notes, summaries, documents, patient names or references, clinical images and consent records, including health data. Audio is never stored on our servers or by any provider (the mobile app's optional offline mode, once released, keeps it encrypted on the device until transcribed).
- People: patients and others present; clinicians and staff.
- Storage: London. Deleted items are restorable for 30 days, then purged.
Main risks and measures
Of 19 risks assessed, the main ones:
| Risk | Measures | Residual |
|---|---|---|
| A wrong medicine, dose or diagnosis enters the record | Source links; removal markers; AI label; clinician signs | Low |
| Capture without everyone's agreement | Capture blocked until consent is confirmed; consent scripts | Low |
| Audio kept and exposed | No audio storage, enforced by an automated check | Low |
| One clinic reads another's records | Row-level security per organisation | Low |
| Transcript text goes to a United States AI provider | Text only; contract bars training and other use; drafting planned to move to Amazon Bedrock in London | Medium |
| Data held by a Singapore provider is reachable under Singapore law | Stored in London; UK Addendum obliging the provider to notify, challenge and limit any public-authority request; transfer risk assessment completed | Low |
Residual risk
One risk is medium until drafting moves to London: transcript text going to a United States AI provider. The rest are low. None is high, so prior consultation with the ICO is not required.
Transfers outside the UK
By where each provider is established:
- Supabase Pte. Ltd. (database and files) is established in Singapore; your data is stored in London. The transfer relies on the UK International Data Transfer Addendum, with a transfer risk assessment.
- Anthropic Ireland, Limited (AI drafting and support) processes text in the United States.
- Vercel Inc. (hosting, in transit only) and Railway Corporation (photo scanning, in transit only) are established in the United States and rely on the UK–US data bridge.
Full list: sub-processors.
Review and questions
Reviewed six months after sign-off, or earlier on any significant change. To ask for more, email privacy@chronixhealthgroup.com.
Chronix Health Group Ltd · company number 16663224 · registered in England and Wales · registered office 11-13 Upper High Street, Epsom, Surrey, KT17 4QY · ICO registration ZB962513 · privacy@chronixhealthgroup.com