AI build policy

Version: 1.1 · Last Updated: 21 October 2026

Your information is protected before AI ever sees it. This page explains how NowPatient builds and governs AI, in plain language first, with the detail for healthcare organisations and procurement teams further down.

Our approach in brief

  • A governed layer, not shortcuts. AI in NowPatient runs through a purpose-built harness. We never paste patient data into public chat tools or wire model calls directly into application code.
  • Privacy first. Identifiable details are de-identified or redacted before they reach an AI model.
  • No training on your data without your permission. Our contracts prohibit third-party AI vendors from training their models on your data, and we only train or develop our own AI models with your health data if you have opted in, or if the data has been anonymised.
  • Everything is logged and checked. Every AI request and response is recorded in an audit trail, and outputs are checked against clinical-safety and content guardrails.
  • People stay in the loop. Human oversight is built in where it matters most.

1. What "the harness" means

The harness is a single governed layer that sits between NowPatient products and the underlying frontier AI models. Every AI feature we build uses it. That means access, data handling, safety checks and monitoring are managed in one place, rather than reinvented, and potentially weakened, in each product.

2. Privacy and data protection

  • De-identification before processing. Protected health information (PHI) and patient-identifiable data are de-identified or redacted before they reach a model.
  • Minimum necessary. AI features receive only the information they need to do their job.
  • Encryption. Data is encrypted in transit and at rest.
  • Jurisdiction. Processing is held within agreed jurisdictions: primary UK hosting (AWS London / eu-west-2) for clinical and application workloads; some supporting infrastructure also in other AWS regions including the US; HIPAA-aligned controls and clinician BAAs where US clinicians onboard.
  • No vendor training. Contractual terms prohibit third-party model providers from training on your data or keeping it after processing. Where PHI is processed by a provider, we maintain Business Associate Agreements / zero-retention arrangements.

2a. Training our own models and research

Infohealth develops some AI models of its own. When we do this:

  • Permission first. We use identifiable or coded health data to train or test our own models only with your explicit, opt-in consent, given separately from your care and from accepting our policies. Saying no never affects your care.
  • Coded, not named. Training data is held under a code. Names, contact details, NHS numbers and free-text notes are removed, and the key linking codes to people is held separately by a small number of named staff.
  • Secure environment. Researchers, including university partners, work inside our own secure environment, which lets analysis results and model files out but not row-level data.
  • Release protocol. Before any coded data is shared outside Infohealth, it passes a release protocol (for example age bands, date shifting and suppression of rare values) and is shared only under a contract that bans re-identification and onward sharing.
  • Fairness. Where you choose to tell us, we record characteristics such as skin tone so we can test and report whether a model works equally well for everyone.
  • Assessment first. We complete a data protection impact assessment and, for research, obtain research ethics approval before any training or research use of personal data starts.
  • Medical device rules. Any model intended for a medical purpose is developed under clinical risk management and is placed on the market only after it meets the UK medical device regulations and any other rules that apply where it is sold.
  • Withdrawal. You can withdraw at any time. We remove your data from active datasets and future sharing, but cannot remove it from a model already trained or from results already published.

3. Access control

Access to systems, prompts and data is role-based and follows the minimum-necessary principle. Permissions are managed centrally and reviewed at least every six months.

4. Audit and accountability

Every AI request and response is recorded in a tamper-evident audit trail. This supports HIPAA audit-control expectations and NHS expectations for transparency and accountability, and allows us to investigate and respond if something goes wrong.

5. Safety, guardrails and human oversight

  • Outputs are validated against clinical-safety and content guardrails before they reach you.
  • Human oversight is built into workflows where AI output could affect care or decisions.
  • AI features are tested before release and monitored after it. Models are evaluated before being adopted or changed, including on data that was not used to train them.

What our AI does, and does not do. NowPatient uses AI to support clinical care, not to replace it. AI does not diagnose, prescribe or make treatment decisions, and no AI output is acted on or shared with another healthcare professional until a registered clinician has reviewed it. Responsibility for every clinical decision remains with the clinician. We do not use AI to make automated decisions that have legal or similarly significant effects on patients. We tell patients when AI has been used in their care.

6. Built to adapt

Because models, prompts and permissions are managed centrally, we can evaluate, update or swap a model, apply policy consistently across every product, and respond quickly to emerging risks without rebuilding each product.

For healthcare organisations: standards and frameworks

NowPatient’s AI is designed around the following.

FrameworkRegionHow we approach it
HIPAA (Privacy, Security and Breach Notification Rules)USMinimum-necessary access, encryption, audit controls, de-identification before model processing, BAAs where applicable
NHS DTAC (Digital Technology Assessment Criteria)UKDesigned around DTAC’s clinical safety, data protection, technical security, interoperability and usability criteria. DTAC questionnaire completed; formal assessment at NHS / social care commissioning (NHS England DTAC guidance, May 2024)
NHS Information GovernanceUKGovernance, accountability and transparency controls. Role-based access, audit logging and clinical safety documentation under DCB0129
Data Security and Protection Toolkit (DSPT)UKInfohealth Ltd (P416): Standards exceeded for 2025–26 (v8), published 29 June 2026; https://www.dsptoolkit.nhs.uk/OrganisationSearch/P416
UK GDPR / Data Protection Act 2018UKInfoHealth Limited is controller; lawful bases and rights as in NowPatient Privacy Policy; rights via dpo@nowpatient.com; DPIAs where high risk, including before any AI training or research use of personal data; explicit opt-in consent for research and model training
DCB0129 / DCB0160 (clinical risk management)UKClinical Safety Officer: Navin Khosla; hazard logs and CSCR NowPatient NHS/Global baseline v1.2 (June 2026)
UK Policy Framework for Health and Social Care ResearchUKResearch involving our patients runs with research ethics committee approval (for example through academic institutions), informed consent and a published research privacy notice
UK Medical Devices Regulations 2002 (software as a medical device)UKAny AI model intended for a medical purpose follows the medical device route before it is supplied; models used only inside our own clinical workflows are covered by DCB0129

HIPAA does not offer a formal certification, and DTAC is an assessment rather than a badge. We describe our alignment accurately and are glad to share supporting documentation under NDA.

Your rights and questions

If you have questions about how AI is used in NowPatient, want to see supporting documentation, or wish to raise a concern, contact us:

  • To withdraw consent to research or model training: your account settings, or email the Data Protection Officer.
  • Email: dpo@nowpatient.com
  • Data Protection Officer: Amish Patel BPharm (Data Protection Officer / Compliance)

We review this policy every 6 months and whenever our AI practices materially change.