AI Reception Assistance in the Practice (PAIRA Avatar)

Privacy notice for the AI-supported reception kiosk in the practice rooms. The German version of this notice is binding.

1) Description

An AI-supported reception kiosk (internal name: PAIRA Avatar) may be used in the practice rooms. A digital avatar is shown on a screen in the reception area; it can greet you, record your request and forward it to the practice team. Input is provided by voice or via a tablet/control panel used by staff.

2) Data Processed

  • Audio stream during the interaction for real-time processing; no persistent audio recording is made.
  • Spoken request or text input on the tablet/control panel.
  • Raw transcript of the interaction, where technically necessary to handle and verify the request.
  • For identified existing patients: name, date of birth and patient number from the local Tomedo practice management system, only where necessary.
  • Tool and forwarding events, e.g. hand-off to staff or creation of a task.

3) Purposes and Legal Basis

Processing serves reception organisation, recording your request and initiating or performing the treatment contract (Art. 6(1)(b) GDPR). Where health data is processed, processing is based on Art. 9(2)(h) GDPR (health care). PAIRA does not provide medical diagnoses, health triage or treatment decisions; treatment-related decisions are made exclusively by licensed practitioners.

4) Processors and Sub-Processors

  • BodoTech UG (haftungsbeschränkt), Dortmund: software operation and maintenance on behalf of the practice (DPA pursuant to Art. 28 GDPR).
  • Google Cloud (Google Ireland Ltd.): Vertex AI Gemini Live for speech processing in the europe-west1 region (Belgium), with zero-data-retention configuration and no use of audio or transcript data for model improvement.

5) Retention Period

  • Audio stream: real-time processing without persistent audio recording.
  • Raw transcript: no more than 24 hours.
  • Local Gemma summary: a local Gemma LLM may, where medically or operationally necessary, store a purpose-bound summary as a note in Tomedo or in the patient record. This note is not raw transcript retention and follows the rules for treatment documentation or patient records.
  • Tool and audit metadata without conversation content is stored for purpose-bound audit and documentation obligations.

6) Data subject rights

Applicable data protection law grants you the following data subject rights vis-à-vis us with regard to the processing of your personal data, with reference to the cited legal basis for the respective conditions of exercise:

  • Right of access pursuant to Art. 15 GDPR;
  • Right to rectification pursuant to Art. 16 GDPR;
  • Right to erasure pursuant to Art. 17 GDPR;
  • Right to restriction of processing pursuant to Art. 18 GDPR;
  • Right to notification pursuant to Art. 19 GDPR;
  • Right to data portability pursuant to Art. 20 GDPR;
  • Right to withdraw consent given pursuant to Art. 7(3) GDPR;
  • Right to lodge a complaint pursuant to Art. 77 GDPR.

A data protection impact assessment (DPIA) pursuant to Art. 35 GDPR is available and can be inspected with the practice management.