Ontario's dental college asks dentists to tell people when they are dealing with AI, and the physicians' college asks for consent before AI records a conversation. The health privacy law makes the clinic the custodian and the AI vendor its agent.
Recording notice
Yes
AI disclosure
Partly
Dental regulator statement
Yes
This is a guide for clinic owners, not legal advice. Every line points to the law or the regulator's own page, checked on 2026-10-20. Where we could not confirm something, the page says so.
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.
No statute requires it, but the dental college's 2025 AI guidance lists informing people when they interact with AI rather than a human. The guidance says it sets out no new professional requirements. Ontario's job-posting AI disclosure rule applies to employers, not to callers.
A dentist or group practice is a health information custodian. An AI vendor that handles patient information for the practice is its agent, and the custodian stays responsible for what the agent does. If information is stolen, lost, or used or disclosed without authority, the custodian must notify the person at the first reasonable opportunity, and the Commissioner in the prescribed cases. PHIPA governs disclosure to people outside Ontario; it has no section that bans keeping records on servers outside the province. The privacy commissioner's January 2026 guidance on AI scribes says consent is generally required for an AI scribe to collect personal health information, and that PHIPA may apply to the scribe's developer as the custodian's agent or service provider. That guidance covers scribes, not phone agents.
The federal rule applies here; nothing specific to this place was found.
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.
The Royal College of Dental Surgeons of Ontario published AI guidance effective 2025-09-18. Item 11 asks dentists to inform people when they are interacting with AI rather than a human.
The College of Physicians and Surgeons of Ontario says physicians need to tell patients how AI will be used and obtain consent before recording conversations with AI. It notes tools that contact patients to book follow-ups and send reminders.
Ontario's accessibility law (AODA) has a customer service standard; whether and how it binds a private clinic's phone line is being checked.
The dental college's guidance names a virtual assistant chatbot that simulates human conversation as the example of when to inform people they are interacting with AI. A clinic deciding whether its phone agent should say it is AI should read item 11 of that guidance.
Aida opens every call with the recording notice your province or state needs, and says it is the practice's AI agent wherever you want it to. Request a demo with your clinic's rules in mind.
Notice
in the opening line
Approved
answers only
Staff
keeps control