With the informed consent of the client, Arran Rose Psychology may use NovoNote to produce session notes and summaries only.

Practice details and roles

Practice name: Arran Rose Psychology

AI governance, documentation auditor, incident contact: Arran Rose

Default patient consent period: per session

Transcript retention: 7 years

Use by non-clinical staff: none

AI tool: NovoNote for session notes and summaries

Purpose

Our practice is committed to the lawful, ethical, and responsible use of artificial intelligence (AI) to support — not replace — human-delivered psychological care. This policy governs how AI tools may be used in our clinical and administrative work, to protect patient privacy, uphold our professional obligations, and preserve the quality and safety of care. AI tools are adopted only where they support clinical workflows (such as documentation) and improve patient outcomes, and always under the accountability of a qualified practitioner.

Core Principles

1. Patient consent is required for the use of AI tools with their personal or health information, and may be withdrawn at any time without affecting their care.
2. Clinical decisions always remain with the practitioner. AI is an assistant, never a decision-maker. Practitioners understand how their AI tools work, and their limitations and biases.
3. Patient data is never used to train AI models. We use only tools whose providers contractually guarantee this.

Who this applies to

This policy applies to all practitioners and clinical staff at our practice. The user of any AI tool covered by this policy is always a qualified practitioner (or clinical staff acting under a practitioner’s direct accountability) — never the patient.

Regulatory and ethical framework

We use AI consistently with the privacy and data-protection law and the professional standards that apply to our practice. These are set out for our jurisdiction and are reviewed whenever the law or professional guidance changes.

Approved, restricted and prohibited uses

Approved uses (with patient consent and clinician review).

1. AI scribes / ambient documentation for session transcription and note summarisation.
2. Drafting, summarising, and grammar-checking of clinical notes and correspondence.

Restricted uses (permitted only with enhanced safeguards and mandatory independent verification by the clinician):

1. Tools offering differential-diagnosis support or pattern analysis, which must always be independently verified and never relied on alone.

Prohibited uses:

1. Using AI as the sole basis for any diagnosis or any suicide or violence risk assessment.
2. Entering identifiable patient information into free, public, or non-approved AI systems (for example, consumer-tier ChatGPT, Gemini, or Copilot).
3. Using any AI tool that has not been approved.
4. Any additional tools or uses prohibited by our practice.

Privacy, security and vendor due diligence

Before any AI tool is approved, we confirm that:

1. A binding data agreement is in place, data processing agreement, or equivalent before any patient data is shared.
2. The vendor contractually guarantees that patient data is never retained or used to train its own or any third-party AI models.
3. Data is encrypted in transit and at rest, and stored in a known, compliant location.
4. Cross-border transfers are accounted for. Where a vendor processes data outside our jurisdiction, we apply the cross-border safeguards required by law and understand we remain accountable for the data.
5. De-identification or redaction is used wherever practical to minimise identifiable data sent for processing.
6. Retention is deliberate. Where the tool allows transcripts or other artifacts to be retained, we set a retention period consistent with our professional record-keeping and legal obligations, rather than defaulting to indefinite storage without a reason.

Informed consent and patient transparency

1. Consent is obtained before AI use — and, for any tool that records or processes a consultation, before recording begins. Consent is tool-specific: we explain which tool, what it captures, where data is stored and who can access it, the privacy risks, and the right to withdraw. A blanket “we use AI” consent is not sufficient.
2. Consent is recorded — we note the patient’s consent (and any withdrawal) in their clinical record, for the consent period (per session).
3. Withdrawal is honoured immediately and without any reduction in the quality of care provided.
4. Authorship is transparent — AI-assisted documents are clearly labelled in the record.

Human review and accountability

1. AI output that becomes clinical documentation — session summaries, notes, letters, and reports — must be reviewed, edited, and approved by the responsible clinician before it is saved to the record.
2. Session transcripts are a verbatim source artifact, not clinician-authored documentation. Where our tool and retention settings keep a transcript, it is stored as a source record — useful for later review and insight — and does not require line-by-line clinician review; the clinician remains responsible for any summary or note drawn from it.
3. The clinician retains full professional, ethical, and legal accountability for every clinical decision and for the accuracy of the final documentation. AI never carries that accountability.

Risk management and quality assurance

1. We acknowledge AI’s limitations — hallucinations, bias, and the absence of contextual clinical judgement — and train staff to watch for them.
2. The Documentation Auditor regularly reviews a sample of AI-assisted documentation for accuracy and completeness.
3. Incident reporting. Any suspected data breach, AI-generated inaccuracy, or use of an unapproved tool is reported to the Incident Contact without delay and recorded in our incident register.

Training and governance

1. All clinical staff complete training on the capabilities, limitations, and privacy boundaries of any approved AI tool before using it.
2. Approval process. No new AI tool may be used until approved by the AI Governance Lead.
3. Ownership and review. This policy is owned by the AI Governance Lead and reviewed at least annually, or sooner if the law or professional guidance changes.

Last updated – October 2026