Guide · Clinics, therapists & health practices

Can clinics and therapists use ChatGPT with patient notes? HIPAA and Alberta's HIA

Short answer: not in a consumer account. Identifiable patient information needs a tool your privacy law allows, which in the US means one covered by a business associate agreement (BAA). For everyday drafting, the safer habit is to keep identifying details out of the prompt altogether.

Updated October 13, 2026

General information, not legal or professional advice. Check your own regulator's rules and your firm's policies.

United States: HIPAA and the BAA question

Under HIPAA, a vendor that handles protected health information for you needs a BAA. OpenAI's help centre lists which services can get one:

OpenAI serviceBAA available?
API PlatformYes, self-serve once eligible
ChatGPT Enterprise and EduYes, through OpenAI's sales team
ChatGPT for cliniciansYes, separate in-product sign-up for eligible clinicians
ChatGPT BusinessNo
Free, Plus and ProNot listed as covered

Masking details helps, but it doesn't automatically make text "de-identified" under HIPAA. HIPAA's standards cover more than names and numbers, including most dates and small geographic areas. If you need to send patient information, use a BAA-covered tool; use masking on top of it, not instead of it.

Alberta: what the privacy commissioner expects

The Office of the Information and Privacy Commissioner of Alberta's guidance for small custodians under the Health Information Act says:

Other provinces have their own health privacy laws and commissioners; check yours.

A safer everyday workflow

  1. For referral letters, summaries and patient handouts, work from a version with the patient's name, health number, address, date of birth and contacts removed or tagged.
  2. Keep clinical facts general enough that they don't identify someone on their own.
  3. Restore the real details in your own system, not in the AI tool.
  4. Review every clinical statement before it leaves your hands.
Patient: Sarah Lindqvist, PHN 88213-4  →  Patient: [PERSON_1], PHN [HEALTH_ID_1]

Stand-In's Health pack catches health card and patient ID numbers along with names and contact details. It's a way to reduce what leaves your device, not a substitute for a BAA or a privacy impact assessment.

Do this in one step with Stand-In

Drop in a PDF, scan, Word or Excel file. Stand-In swaps every name, SIN/SSN, account number and address for a tag like [PERSON_1], then puts the real details back in the AI's answer. It runs on your device; nothing is uploaded.

Try it free

Sources: OpenAI, Getting a business associate agreement · OIPC Alberta, Guidance for small custodians on the use of AI (Nov 2023)