# What safeguards do we need before using an AI scribe in therapy sessions?

URL: https://tymirahealth.com/resources/faqs/what-safeguards-do-we-need-before-using-an-ai-scribe-in-therapy-sessions
For: Digital health teams | Digital health and technology | Reviewed by Independent clinical reviewer, Registered mental health clinician, Kenya | Last reviewed 8 November 2026

**Answer:** Get explicit, informed agreement from the client to record, with an easy way to decline. Complete a DPIA, and sign a processing agreement that bars the vendor from using session data to train models and sets audio deletion times. Check where data is processed: the Digital Health Act restricts sharing personal health information outside Kenya, and cross-border rules apply. The clinician must review and correct every draft, as AI can invent or omit content. Keep psychotherapy content out of summaries unless clinically needed.

Sources: World Health Organization: https://www.who.int/news/item/18-01-2024-who-releases-ai-ethics-and-governance-guidance-for-large-multi-modal-models - Kenya Law: https://new.kenyalaw.org/akn/ke/act/2023/15/eng@2023-11-24 - Office of the Data Protection Commissioner: https://www.odpc.go.ke/wp-content/uploads/2026/09/ODPC-%E2%80%93-Guidance-Notes-for-Cross-border-Data-Transfers.pdf - Office of the Data Protection Commissioner: https://www.odpc.go.ke/wp-content/uploads/2024/02/ODPC-Guidance-Note-on-Data-Protection-Impact-Assessment-1.pdf

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