In the era of digital dentistry, ambient scribe technology is transforming how we document patient care. By using AI to listen to consultations and draft clinical notes, dentists are getting back hours in their day.
However, not all AI tools are created equal. At Kiroku, we’ve made a strategic decision to never store audio recordings. We immediately transcribe the audio and delete the recording.
While recording a conversation might seem helpful, the long-term data liabilities for a dental professional and practice can be significant. Here is why "no storage" is the safest choice.
Why Should Dental AI Scribes Delete Audio Recordings?
The primary reason dental AI scribes should delete audio immediately after transcription is Data Minimisation, a core principle of GDPR. When a patient speaks to you, they are sharing sensitive health data, but they are also sharing their voice, a unique biometric marker.
By transcribing audio into text and immediately deleting the raw audio recording, we ensure that the patient’s digital footprint is minimised. Only the necessary clinical information remains. Kiroku ensures that sensitive biometric data (the patient's voice) is not sitting on a server.
This approach reduces the risk for you, your practice, and for Kiroku. In the unlikely event of a data breach, a text-based clinical note is far more secure and less identifiable than a high-fidelity audio recording of a private medical discussion. With deep fake technology getting increasingly sophisticated and voice spoofing a new trend for scammers, anything that minimises risks for yourself and patients is worth taking seriously.
Is an Audio Recording Part of a Patient's Legal Medical Record?
Yes. If a clinician records a consultation and stores that file, it legally becomes part of the patient’s permanent medical record. This has two major implications for your practice:
Subject Access Requests (SARs)
Under UK GDPR, if a patient requests their records, you are legally obligated to provide the audio file, as well as other data relating to them that may not be stored in their clinical record or inside the practice management system.
When this includes audio recordings, it can be technically difficult to manage and share securely.
Retention Periods
You must store that audio for the same duration as your clinical notes (typically 11 years in the UK). Managing a decade’s worth of massive audio files is a significant storage and security burden that most dental practices are not equipped to handle.
By using a tool that doesn't store audio, the "record" remains what it has always been: a written summary of the clinical facts.
What are the GDPR Risks of Storing Clinical Audio?
Under the UK GDPR and GDC standards, the rules for "recording" are far stricter than the rules for "note-taking."
Storing audio introduces "High-Risk" data processing under GDPR because voice data can be classified as biometric data used for identification. If you store an audio file, that file becomes part of the patient’s permanent clinical record. This means you must be able to produce it for a Subject Access Request (SAR) and store it securely for years.
To store this legally, clinicians often need to meet a higher threshold of "Explicit Consent" rather than just "Informed Consent." Furthermore, audio recordings capture "unfiltered" data. A patient might mention their partner's health, their financial situation, or other third-party information that has no place in a clinical record.
If you are not storing audio and are simply using a tool to assist in contemporaneous note-taking, the legal basis for processing often shifts toward "Direct Care," making the workflow much smoother for the clinician.
A patient is likely to see you wearing a microphone to help you take notes using Kiroku, so we’d encourage you to let them know that you’re using new technology to help you do this. You can also download a poster we’ve created to put up in your practice.
Kiroku’s AI acts as a professional filter. It extracts the relevant dental facts into your templates and discards the digital noise, keeping your data clean and compliant.
How to Choose an Ambient Scribe for Your Practice
Before implementing any AI note-taking tool, practice owners and clinicians should ask these three compliance questions:
- Where is the audio processed? Ensure the data stays within compliant jurisdictions (like the UK or EEA) and is encrypted during the seconds it exists.
- Is the audio deleted instantly? Confirm the provider does not use your patients' voices to "train" their general models without specific, separate consent.
- Does it integrate with my workflow? The goal is to reduce admin, not add a new task of managing audio libraries and consent forms.
A Note on Clinical Safety from our CSO
"At Kiroku, we believe that clinical efficiency should never come at the cost of patient trust or regulatory risk.
As a dentist, I know that our notes are our greatest protection, but the data behind them must be handled with extreme care.
That is why we have gone beyond simple encryption. We have rigorously audited our systems to ensure we are as compliant as possible, achieving Class 1 Medical Device status and fully meeting the DCB0129 clinical risk management standards.
By choosing not to store audio recordings, we aren’t just protecting patient privacy; we are protecting the clinician from the immense burden of managing biometric data.
Our goal is to provide a 'Privacy by Design' environment where you can focus on the patient, knowing the underlying technology meets the highest safety standards in digital health."
Dr. Hannah Burrow, Clinical Safety Officer at Kiroku
The Clinical AI Compliance Checklist
1. Data Privacy & "No-Storage" Policy
- Immediate Deletion: Does the software delete the raw audio file as soon as the transcript is generated?
- Biometric Handling: If audio is stored, does the practice have a specific legal basis for storing "biometric" voice data?
- Data Minimisation: Does the tool filter out non-clinical "noise" (e.g., chat about family) before saving the note?
- Anonymisation: Is the data de-identified before being sent to the AI processing engine?
2. Legal & Regulatory Requirements
- DPIA Completed: Has the practice performed a Data Protection Impact Assessment for this new software?
- DPO Consultation: If you provide NHS care, has your Data Protection Officer reviewed the tool?
- DSP Toolkit: Does the software provider comply with the NHS Data Security and Protection Toolkit?
- Location of Servers: Is the data processed and stored within the UK or EEA (or a country with an adequacy decision)?
3. Patient Consent & Transparency
- Privacy Policy Update: Has your practice's Privacy Notice been updated to include AI data processing?
- Patient Information: Is there a clear sign or leaflet in the surgery explaining how AI supports your note-taking?
- Verbal Script: Do clinicians have a standard "script" to inform patients (e.g., "I'm using an AI assistant to help me stay focused on you while it drafts our notes").
- Opt-Out Procedure: Is there a clear process for patients who do not wish to be recorded?
4. GDC & Clinical Accountability
- Human in the Loop: Is the clinician aware they must review and "sign off" every AI-generated note?
- Accuracy Audit: Is there a plan to periodically audit AI notes against the actual consultation to assess the accuracy of notes?
- Contemporaneous Entry: Does the system timestamp the notes to prove they were created at the time of the appointment?
Why Your AI Dental Scribe Matters
Dental indemnity and defence organisations (like our partner, Densura) emphasise that the clinician is always responsible for the record. If an AI scribe makes a mistake and you sign it off, that mistake is legally yours.
At Kiroku, we believe that technology should support the clinician, not complicate their legal obligations. By refusing to store audio, we protect the patient's privacy, simplify your compliance, and let you focus on what matters most: the person in the chair.
To find out more about how we handle your data, check out our compliance page. If you're ready to try out AI voice technology for your dental notes, sign up for a free 14-day trial of Kiroku now.
