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

A 1993 Irish Act on State interception defines interception so that it leaves out listening or recording where the sender or the intended recipient has consented, and a 1983 Act makes interception an offence. Separately, Irish regulations (2011, as made) bar storing communications without the users' consent, but keep legally authorised business recording as evidence. EU law (the GDPR) says to tell people who collects their data and why.

For an AI agent: whether the interception Acts reach a clinic recording its own calls, and whether recording for training or AI processing counts as business evidence, are not settled by any source we read. The duty to tell people when their details are collected applies either way.

• Irish law (Revised Acts): Interception of Postal Packets and Telecommunications Messages (Regulation) Act 1993, section 1“where either the person on whose behalf the message is transmitted or the person intended to receive the message has consented to the listening or recording”
• Minister / Garda Síochána: Postal and Telecommunications Services Act 1983 s 98(1): interception offence“intercepts or attempts to intercept, or ( b ) authorises, suffers or permits another person to intercept, or ( c ) does anything that will enable him or another person to intercept, telecommunications messages being transmitted by the company”
• Irish Statute Book: S.I. 336 of 2011, regulation 5“affect any legally authorised recording of communications and the related traffic data when carried out in the course of lawful business practice for the purpose of providing evidence of a commercial transaction or of any other business communication”
• EU Publications Office (GDPR text): GDPR, Article 13(1)“Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information”
• Our search (2026-11-14): No Data Protection Commission page found on telling callers a call is recorded

EU law (the AI Act) puts this duty on providers, meaning whoever supplies the AI system. It must be designed so people are told they are dealing with AI, unless that is obvious to a reasonably well informed, observant and circumspect person. It applies from 2 August 2026, at the latest at the first interaction. Irish law lets an authorised officer serve a contravention notice for Article 50.

For an AI agent: the duty is written for the provider, which EU law defines as whoever develops an AI system, or has one developed, and places it on the market or puts it into service under its own name or trademark. Where the AI is not obvious, the notice is due at the latest at the first interaction.

• European Commission (AI Act Service Desk): EU AI Act, Article 50(1) (2026-08-02)“Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system”
• European Commission AI Office: EU AI Act Art 3(3): who is a provider“that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark”
• European Commission (AI Act Service Desk): EU AI Act, Article 50(5) (2026-08-02)“The information referred to in paragraphs 1 to 4 shall be provided to the natural persons concerned in a clear and distinguishable manner at the latest at the time of the first interaction or exposure”
• European Commission (AI Act Service Desk): EU AI Act, Article 113: dates of application (2026-08-02)“It shall apply from 2 August 2026.”
• Irish Statute Book: Regulation of Artificial Intelligence Act 2026: commencement table (2026-07-31)“31 July 2026 Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026 (S.I. No. 403 of 2026), art. 2”
• Oireachtas: Regulation of Artificial Intelligence Act 2026, section 71 (2026-07-31)“An authorised officer who reasonably suspects that a person is infringing or has infringed a provision of the Artificial Intelligence Regulation to which this section applies may serve a notice”

Irish regulations (2011, as made) need consent for unsolicited marketing by automated calling machine or by electronic mail, which includes texts, and for marketing calls to a mobile. Other marketing calls are barred if the person opted out or is on the National Directory Database register. A conditional exception covers emails and texts to customers within 12 months of a sale. A service text must not carry marketing without consent.

For an AI agent: whether an AI voice agent that holds a live conversation counts as an automated calling machine is not decided by any source we read, and marketing calls must say who is calling and on whose behalf.

• Irish Statute Book: S.I. 336 of 2011, regulation 13(1)“( a ) an automated calling machine, ( b ) a facsimile machine, or ( c ) electronic mail”
• Office of the Attorney General (Irish Statute Book): S.I. 336 of 2011 reg 2: electronic mail includes SMS“means any text, voice, sound or image message including an SMS message sent over a public communications network”
• Irish Statute Book: S.I. 336 of 2011, regulation 13(6)“the person has been notified by that subscriber or user that he or she consents to the receipt of such communication on his or her mobile telephone”
• Office of the Attorney General (Irish Statute Book): S.I. 336 of 2011 reg 13(5): marketing calls and opt-out“the subscriber or user has notified the person that the subscriber or user does not consent to the receipt of such a call”
• Office of the Attorney General (Irish Statute Book): S.I. 336 of 2011 reg 13(11): existing customers“the sale of the product or service occurred not more than 12 months prior to the sending of the direct marketing communication”
• Irish Statute Book: S.I. 336 of 2011, regulation 13(7)“shall not use or cause to be used any publicly available electronic communications service to send to a subscriber or user an SMS message for a non-marketing purpose which includes information intended for the purpose of direct marketing unless”
• Irish Statute Book: S.I. 336 of 2011, regulation 13(10)“include the name of the person making the call and, if applicable, the name of the person on whose behalf the call is made”

EU law (the GDPR) says a vendor that handles data for you needs a binding contract. Sending data to a third country (outside the EU area) needs a Chapter V route (an adequacy decision or safeguards). A breach must be reported to the Data Protection Commission, where feasible within 72 hours of becoming aware, unless unlikely to risk people. We found no Irish rule that data must stay in Ireland.

For an AI agent: the vendor behind it needs a binding contract with the clinic and must tell the clinic of a breach without undue delay.

• EU Publications Office (GDPR text): GDPR, Article 28(3)“Processing by a processor shall be governed by a contract or other legal act under Union or Member State law, that is binding on the processor with regard to the controller”
• EU Publications Office (GDPR text): GDPR, Article 46(1)“In the absence of a decision pursuant to Article 45(3), a controller or processor may transfer personal data to a third country or an international organisation only if the controller or processor has provided appropriate safeguards”
• EU Publications Office (GDPR text): GDPR, Article 33(1)“In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority”
• EU Publications Office (GDPR text): GDPR, Article 33(2)“The processor shall notify the controller without undue delay after becoming aware of a personal data breach”
• Our search (2026-11-14): No Irish rule found requiring call or health data to be stored in Ireland

EU law (the GDPR) gives people the right not to be subject to a decision based solely on automated processing with legal or similarly significant effects, with exceptions. AI used to recruit staff is high risk; those duties start on 2 December 2027. We found no Irish guidance on AI in hiring. Top tier GDPR fines run up to 20 million euro or 4 percent of turnover, whichever is higher.

For an AI agent: whether turning away or triaging a caller has a similarly significant effect is not settled by any source we read.

• EU Publications Office (GDPR text): GDPR, Article 22(1)“The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her”
• European Commission (AI Act Service Desk): EU AI Act, Annex III, point 4 (2027-12-02)“AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications, and to evaluate candidates”
• Our search (2026-11-14): No Irish guidance found on AI in recruitment
• EU Publications Office (GDPR text): GDPR, Article 83(5)“be subject to administrative fines up to 20 000 000 EUR, or in the case of an undertaking, up to 4 % of the total worldwide annual turnover of the preceding financial year, whichever is higher”

EU law (the GDPR) bars processing health data unless a condition applies, and one condition is providing health or social care. Irish law (Data Protection Act 2018, section 52) makes processing lawful where necessary for medical care, with suitable and specific measures, if done by or under the responsibility of a health practitioner or someone with an equivalent duty of confidence. Practitioners include registered doctors and dentists.

For an AI agent: processing health details needs a listed condition, and care related processing sits under a health practitioner's responsibility or an equivalent duty of confidence.

• EU Publications Office (GDPR text): GDPR, Article 9(1)“data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited”
• EU Publications Office (GDPR text): GDPR, Article 9(2)(h)“processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment”
• Law Reform Commission (revised Acts): Data Protection Act 2018, section 52(1)“(c) for medical diagnosis, (d) for the provision of medical care, treatment or social care”
• Law Reform Commission (revised Acts): Health Identifiers Act 2014, section 2“a registered medical practitioner within the meaning of section 2 of the Medical Practitioners Act 2007”

Medical Council guidance, written for doctors and not law, says doctors remain responsible for clinical decisions, that patients should be informed when AI tools are used in the diagnosis, treatment and delivery of their care, and the treating doctor stays responsible for informed consent even if part is delegated. In Irish law a minor aged 16 or over can consent to treatment; the rule does not cover under 16s.

For an AI agent: the guidance on telling patients about AI is written for doctors, the source on delegating consent does not mention AI agents, and the age 16 rule does not cover younger patients.

• Medical Council: Medical Council position statement on AI in medicine“Doctors ultimately remain responsible for their clinical decisions in the treatment of their patients”
• Medical Council of Ireland: Medical Council Position Statement on AI: patients should be told“patients should be informed when AI tools are used in the diagnosis, treatment and delivery of their care”
• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 16.3“as the treating doctor, if you delegate all or part of the consent process, you remain responsible for ensuring that the patient has given informed consent”
• Law Reform Commission (revised Acts): Non-Fatal Offences against the Person Act 1997, section 23(1)“The consent of a minor who has attained the age of 16 years to any surgical, medical or dental treatment”

We found no Irish rule written for AI scribes. The Medical Council's guidance tells doctors to keep accurate, up-to-date records, and says a doctor using an AI tool to record consultations would need to give patients more information about how it works. EU law (the GDPR) lets a person ask for confirmation of processing and access to their data.

For an AI agent: guidance for doctors asks for more patient information when AI records consultations, and whether that reaches reception calls is not settled.

• Our search (2026-11-14): No Irish rule found written for AI scribes
• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 38.1“You must keep accurate and up-to-date medical records either on paper or in electronic form”
• Medical Council: Medical Council position statement on AI in medicine“if a doctor is using an AI tool to record consultations, they would need to provide more information about how the AI works”
• EU Publications Office (GDPR text): GDPR, Article 15(1)“The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed”

EU law (Medical Devices Regulation) can treat software as a medical device where its maker intends a medical purpose, such as diagnosis; not all healthcare software is one. Irish law (Equal Status Act 2000) treats failing to do all that is reasonable to accommodate a person with a disability as discrimination where a service would otherwise be impossible or unduly difficult to use, with a nominal cost limit.

For an AI agent: where an automated decision rests on contract necessity or explicit consent, the person must be able to get human intervention, give their view and contest it.

• EU Publications Office (Medical Devices Regulation text): Medical Devices Regulation, Article 2(1)“means any instrument, apparatus, appliance, software, implant, reagent, material or other article intended by the manufacturer to be used, alone or in combination, for human beings”
• Health Products Regulatory Authority (HPRA): HPRA guide to standalone software“Not all standalone software used in the healthcare sector are medical devices”
• Law Reform Commission (revised Acts): Equal Status Act 2000, section 4(1)“discrimination includes a refusal or failure by the provider of a service to do all that is reasonable to accommodate the needs of a person with a disability by providing special treatment or facilities”
• EU Publications Office (GDPR text): GDPR, Article 22(3)“at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision”

The Dental Council is the statutory body for dentists in Ireland, under the Dentists Act 1985. Its Code of Practice (March 2022) says a breach may lead to fitness to practise proceedings. We found no Dental Council code, notice or news item on AI, and the Code does not mention artificial intelligence.

For an AI agent: with no AI statement found, the Council's general Codes on records, consent, delegation, confidentiality and remote care are the written standards we found for dentists.

• Dental Council: Dentists Act 1985, section 6“the general concern of which shall be to promote high standards of professional education and professional conduct among dentists”
• Dental Council: Code of Practice on Professional Behaviour and Ethical Conduct (March 2022)“If you do not comply with this guidance, it may result in Fitness to Practise proceedings against you under the Dentists Act 1985.”
• Our search (2026-11-14): No Dental Council guidance on AI found

The Dental Council Code says to keep accurate, current records: adults' for at least eight years after the patient was last seen, children's and young adults' until at least the 25th birthday (26th if aged 17 when last seen). Consent is needed before treatment, from a parent or guardian for under 16s. Irish law (S.I. 256 of 2018) allows an X-ray only on a referral from a referrer.

For an AI agent: whether an automatic call summary counts as a record is not stated, though the Code lists information about a patient's communication with the practice among record contents.

• Dental Council: Code of Practice (March 2022), paragraph 9.1“You must keep legible, accurate, comprehensive and up-to-date records for all your patients.”
• Dental Council (An Chomhairle Fiaclóireachta): Dental Council Code of Practice 2022, para 9.5: child and young adult records“you must keep records until at least the patient’s 25th birthday, or their 26th birthday if the young person was 17 when last seen”
• Dental Council: Code of Practice (March 2022), paragraph 7.1“You must get the informed consent of your patient before you begin any treatment.”
• Dental Council: Code of Practice (March 2022), paragraph 7.5“By law, you must get the consent of a parent or guardian when treating a patient under 16 years of age.”
• Irish Statute Book: S.I. 256 of 2018, regulation 4(2)“A person shall not carry out a medical radiological procedure on the basis of a referral from a person other than a referrer.”

Only a registered dentist may practise dentistry or hold themselves out as ready to, with listed exceptions. The Dental Council Code says a dentist is responsible for work delegated to staff, and that remote consultations are only for emergencies or exceptional circumstances. The Code speaks of staff and the dentist's own care and does not mention automated agents.

For an AI agent: the dentist stays responsible for delegated work, and whether an AI agent giving general dental information counts as practising dentistry is not decided by anything we read.

• Law Reform Commission (revised Acts): Dentists Act 1985, section 51(1)(b)“to represent or hold himself out, whether directly or by implication, as practising, or being willing and ready to practise, dentistry, unless such person is a registered dentist.”
• Dental Council: Code of Practice (March 2022), paragraph 13.4“You are responsible for any service or treatment that you have delegated to staff.”
• Dental Council: Code of Practice (March 2022), paragraph 4.13“Direct, face-to-face patient consultations must remain your normal practice. You must only do remote consultations in emergency situations or exceptional circumstances.”

The Dental Council Code says information a dentist publishes must be truthful, decent, factual and accurate, and must not mislead or raise unreasonable expectations. A dentist must not suggest a status other than the one on the register. A separate Code makes it mandatory to display private fees for certain treatments before the consultation. Rules on marketing calls and texts sit in the business section above.

For an AI agent: the Code does not say whether calls count as publishing, so we cannot say if its advertising rule reaches what an agent says.

• Dental Council: Code of Practice (March 2022), paragraph 15.5“Any information you publish must be truthful, decent, factual and accurate, and must not be misleading, raise any unreasonable expectations, or bring the profession into disrepute.”
• Dental Council: Code of Practice (March 2022), paragraph 15.6“You must not use any content which may reasonably suggest you have a professional status other than the status recorded for you in the register of dentists.”
• Dental Council: Code of Practice on Display of Private Fees“This Code of Practice makes it mandatory for dentists to display their private fees for certain treatments in a place where patients can read it before their consultation.”

The Medical Council protects the public by setting standards for registered doctors, including surgeons. We found no separate plastic surgery regulator. A general scheme for a Patient Safety (Licensing) Bill would license some higher-risk services, likely starting with cosmetic surgery; it is a proposal, not law, and HIQA's report of November 2025 says it was still being drafted. We found no enacted licence for private cosmetic clinics.

For an AI agent: only a registered doctor may advertise services as a medical practitioner, which matters for any title the agent gives a clinician.

• Medical Council: Medical Practitioners Act 2007, section 6“The object of the Council is to protect the public by promoting and better ensuring high standards of professional conduct and professional education, training and competence among registered medical practitioners.”
• Law Reform Commission (revised Acts): Medical Practitioners Act 2007, section 37(2)“a person shall not advertise his or her services as a medical practitioner unless he or she is a registered medical practitioner.”
• Department of Health: General Scheme of the Patient Safety (Licensing) Bill (a proposal, not law)“Designated activities are likely to initially relate to cosmetic surgery services but other services may be added over time as the licensing system becomes embedded in the health system.”
• HIQA: HIQA overview report 2024, status of the Licensing Bill (a bill, not an Act)“is currently actively progressed by the Department of Health.”
• Our search (2026-11-14): No enacted licence for private cosmetic clinics found

The ASAI code is self-regulation, not law. It says treatment adverts should take care not to minimise treatments or create unrealistic expectations, especially with photographs, and should not suggest success in every case. Irish law (S.I. 541 of 2007) bars advertising prescription-only medicines, except to people qualified to prescribe or supply. Medical Council guidance says doctors must not make claims they cannot substantiate.

For an AI agent: whether advertising a treatment counts as advertising the medicine is not decided by any source we read.

• Advertising Standards Authority for Ireland (ASAI): ASAI Code, section 11.7(b)“Marketing communications for individual treatments should take care not to minimise, trivialise or create unrealistic expectations, in particular in the use of photographs.”
• Advertising Standards Authority for Ireland (ASAI): ASAI Code, section 11.10“Marketing communications should not suggest that a product or treatment will achieve success in every case”
• Irish Statute Book: S.I. 541 of 2007, regulation 9“A person shall not issue an advertisement in respect of any medicinal product which, by virtue of the Medicinal Products (Prescription and Control of Supply) Regulations 2003”
• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 50.2.1“You must not make claims, that cannot be substantiated, for the effectiveness of treatments.”

We found no Irish cooling-off rule for cosmetic surgery. The Consumer Rights Act 2022 cancel rights do not apply to healthcare contracts, and whether a purely cosmetic procedure is healthcare is not decided. The treating doctor is responsible for consent, says the Medical Council guide. The consumer regulator CCPC says a business generally need not refund a deposit for a change of mind unless its terms say so.

For an AI agent: we found no set reflection period to point to, and the treating doctor stays responsible for consent.

• Our search (2026-11-14): No Irish cooling-off rule found for cosmetic surgery
• Irish Statute Book: Consumer Rights Act 2022, section 97(8)“Chapters 2 and 6 of this Part shall apply to a contract for the supply of healthcare concluded between a trader and a consumer”
• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 16.1“If you are the doctor treating the patient, it is your responsibility to ensure that the patient has given consent to the treatment”
• Competition and Consumer Protection Commission (CCPC): CCPC guidance on deposits (guidance, not law)“Generally, a business does not have to refund your deposit if you change your mind.”

Injectables: Irish law (S.I. 540 of 2003) puts medicinal products for injection under prescription control, with exceptions. We found no Act or regulation naming who may inject toxin or fillers, and the HPRA regulates filler products, not who administers them. Dentists who give them follow a Dental Council code asking for extra training and competence. Surgery: we found no enacted licence for private cosmetic clinics.

For an AI agent: we found no Irish rule naming who may inject and no licence for private cosmetic clinics, so these sources give it no register or licence to refer to.

• Irish Statute Book: S.I. 540 of 2003, regulation 5(1)“any medicinal product which is intended for parenteral administration;”
• Health Products Regulatory Authority (HPRA): HPRA on dermal fillers“We do not have a role in regulating the administration of dermal fillers”
• Our search (2026-11-14): No Irish Act or regulation found naming who may inject toxin or fillers
• Dental Council: Code of Practice on Non-Surgical Cosmetic Procedures (May 2023)“only provide these treatments if you have undertaken additional education and training, and you have achieved the necessary competence to provide these treatments safely;”
• Our search (2026-11-14): No enacted licence for private cosmetic surgery clinics found

Medical Council guidance says a doctor providing telemedicine must observe the same standards as in person, and defines telemedicine to include phones, websites, apps and software. A doctor consulting through an out of hours or telemedicine service who is not the usual doctor must update the patient's GP unless the patient does not consent. We found no specific aftercare duty for cosmetic surgeons in the Guide.

For an AI agent: the guide holds the doctor to the same standard for remote care as in person, and the doctor remains responsible for clinical decisions.

• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 37.1“If you provide telemedicine services to patients, you must observe the same standards of conduct and practice as would be expected if treating the patient in-person.”
• Medical Council: Guide to Professional Conduct and Ethics (9th edition), paragraph 33.9“If you have a consultation with a patient through an ‘out of hours’ or ‘telemedicine’ service, and are not the patient’s usual doctor, you must”
• Medical Council: Medical Council position statement on AI in medicine“Doctors ultimately remain responsible for their clinical decisions in the treatment of their patients.”