What Canadian clinics must do when an AI agent answers the phone.

Recording is lawful with one party's consent under the Criminal Code, so the clinic's own agent may record. The Privacy Commissioner's guidance adds the privacy duty: tell the caller the call is recorded, say why, and get consent. A caller who continues after that notice has consented, unless the recording keeps a voiceprint, which may need express consent.

• Justice Laws (Government of Canada): Criminal Code, section 184(2)(a) (current to 2026-09-30)“has the consent to intercept, express or implied, of the originator of the private communication or of the person intended by the originator thereof to receive it”
• Office of the Privacy Commissioner of Canada: Recording of Customer Telephone Calls (updated 2026-10-08)“The organization must inform the customer that they are recording a call, clearly state the purpose of the recording and obtain consent.”
• Office of the Privacy Commissioner of Canada: Recording of Customer Telephone Calls (updated 2026-10-08)“if the customer proceeds with the call knowing that the conversation is being recorded and why, their consent is implied. However, if the recording involves biometric voiceprints... express consent may be required.”

No law in force in Canada requires a business to tell a caller they are speaking with an AI. The Artificial Intelligence and Data Act never passed. Bill C-34 (2026) has a chatbot clause about not posing as a human, written for services that simulate a sustained relationship; a clinic phone line is probably outside it, and it is still a bill.

• Parliament of Canada, LEGISinfo: Bill C-27 (Artificial Intelligence and Data Act) (last activity 2023-04-24)
• Parliament of Canada: Bill C-34, Safe Social Media Act, first reading (introduced 2026-06-10)

PIPEDA requires an organization to report to the Privacy Commissioner any breach of security safeguards that creates a real risk of significant harm to an individual. The breach regulations have been in force since 2018-11-01. Which clinics fall under PIPEDA rather than a provincial law depends on the province; each province page says what its own law covers.

• Justice Laws (Government of Canada): PIPEDA, section 10.1(1)“the breach creates a real risk of significant harm to an individual”

The CRTC telemarketing rules do not apply to calls that do not solicit, and the Do Not Call List exempts calls to people with an existing business relationship. The rules for automatic dialing-announcing devices still cover calls that play a pre-recorded or synthesized voice, including non-sales calls: the caller must be identified, and such calls may not be made to healthcare facilities. Whether a conversational AI agent counts as such a device is unsettled. Texts and emails fall under the anti-spam law, which implies consent for two years after a purchase and six months after an inquiry.

• CRTC: Unsolicited Telecommunications Rules (crtc.gc.ca/eng/trules-reglest.htm, read from a web.archive.org copy) (page modified 2014-03-31, read 2026-10-20)“a pre-recorded or synthesized voice message”
• National Do Not Call List: Exemptions (2018-04-09)
• Justice Laws (Government of Canada): Canada's Anti-Spam Legislation, section 10(9) and (10)

We found nothing from the Canadian Dental Association on AI agents; its position-statements page was not reachable when checked. Each province page gives its own dental regulator's position.