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Clinic AI in Hamburg, what private clinics and health systems should know in 2026

By the wai teamOctober 15, 20269 min read

Reviewed by The Wellness Clinical Team, October 5, 2026

A clinician at ease in a vast, light-filled private clinic in Hamburg, the city beyond the glass

Key points

Summary

A Hamburg practice can use AI for notes and patient messages in 2026 when the patient knows about the recording, the vendor and its staff are bound to medical secrecy and every draft and signature can be shown to the patient on request. The HmbBfDI supervises the data, the Ärztekammer Hamburg represents every doctor in the city and the ePA links the practice to the patient's statutory record.

Hamburg practices on wai open the day with the evening's messages already drafted in each patient's language and close it with every letter signed. The rules behind that work come from the HmbBfDI, the federal criminal and civil codes and the ePA, and the figures come from Hamburg's own statistics office and medical chamber.

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1,869,473
residents of Hamburg on 31 December 2025, up 6,908 in a year 1
41.9%
of Hamburg residents had a migration background at the end of 2025, about 828,000 people 2
5,928
doctors working in ambulatory care in Hamburg at the end of 2025 3

Follow a Winterhude mother's 21.30 WhatsApp and a Blankenese missed call through to approved replies and a paid dermatology slot, in a fifteen-minute call with a clinician on wai.

The rules at a glance for a Hamburg practice
Body or ruleWhat it requiresWhat to askHow wai meets it
HmbBfDI discussion paper on language models, July 2024GDPR applies to AI system output, and data subject rights attach to input and outputCan every draft about a patient be found and correctedEvery message, draft, approval and signature is logged and exportable
Criminal Code section 203(4)Contributing persons are bound to secrecy, and the doctor must ensure they areIs the secrecy duty written into the contract for every subcontractorSubprocessors named, with 30 days notice before any change
Civil Code section 630gInspection without delay, electronic copies, first copy without a feeHow fast can the full record be producedFull export of the signed record and its history
Ärztekammer HamburgProfessional body for every doctor in HamburgWho signs each AI-drafted noteNotes stay drafts until the doctor signs
ePA, the electronic patient recordOpen to statutory and private patients, readable in treatment unless the patient objectsHow signed letters reach the ePABuilt to connect to the ePA, set up with each practice

The private care market in Hamburg

Hamburg had 1,869,473 residents on 31 December 2025, 6,908 more than a year earlier.1 In 2025, 91,309 people moved to the city and 82,777 left, and that net gain of 8,532 drove the growth.1

The Ärztekammer Hamburg counted 19,953 doctors at the end of 2025, of whom 15,484 were working.3 Of the working doctors, 7,493 were in hospitals and 5,928 in ambulatory care, including 3,150 in their own practice.3 Internal medicine was the largest specialty, with 2,026 working doctors, and 905 general practitioners worked in ambulatory care.3

The rules a Hamburg practice works under

The Hamburg Commissioner for Data Protection and Freedom of Information, the HmbBfDI, set out its reading of language models in a discussion paper in July 2024.4 It holds that storing a model is not itself processing of personal data, that processing inside an AI system must still meet the GDPR, especially its output, and that rights of access, erasure and correction attach to the system's input and output.4 For a practice that means every draft and every reply must be findable and correctable, which is why wai logs each message, draft, approval and signature for export.

Medical secrecy reaches the vendor's own staff. Under section 203(4) of the Criminal Code, a person who contributes to a doctor's work and discloses a patient's secret without authority faces up to one year in prison or a fine, and the same penalty applies to a doctor who did not ensure that person was bound to secrecy.5 wai names its subprocessors and gives 30 days notice before any change.

Patients may see what was written about them. Section 630g of the Civil Code gives the patient a right to inspect the complete record without delay and to ask for copies, including electronic copies, with the first copy without a fee.6 An AI-drafted note becomes part of that record once the doctor signs it.

Every doctor in Hamburg, more than 20,000 of them, is a member of the Ärztekammer Hamburg, the public body for the profession in the city.7 Recording a consultation starts with the patient's agreement, and the consent form template gives the words.

Privately insured patients can use the ePA as well as statutory ones, and in a treatment context the practice can read it without a fresh release unless the patient has objected.8 wai is built to connect to the ePA. We set up your clinic's connection with you.

wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic. wai is compliant with these rules and built for clinics in Hamburg. A Hamburg practice keeps its records in Germany.

The languages Hamburg patients write in

About 828,000 Hamburg residents had a migration background at the end of 2025.2 The most common countries of reference were Turkey at 12.2%, Poland at 8.5% and Afghanistan at 7.7%, and the share ranged from 89.1% in Billbrook to 9.8% in Spadenland.2

Because wai reads any language, a family can write in the language they speak at home, and the receptionist approves the draft before anything goes back.9

What a demo shows in Hamburg

The demo opens on two messages. One is a WhatsApp sent at 21.30 by a mother in Winterhude asking whether her son can see the dermatologist before term starts. The other is a missed call at 8.05 from a retired shipping broker in Blankenese, which wai turns into a drafted text offering to call back.

wai reads the dermatologist's busy times from Google Calendar, Outlook or Apple Calendar and drafts a reply in the mother's language with two open afternoons. The receptionist approves both drafts before the first patient arrives. The mother books with a euro deposit that settles in the practice's own Stripe account, the practice remains merchant of record, and the confirmation arrives with its receipt and intake form.

After the visit the dermatologist edits and signs the drafted note and the letter to the boy's paediatrician. If the mother later asks for a copy of the record, the signed note and its logged history are ready to export, as section 630g expects.6

For hospital groups, insurers and public bodies in Hamburg

Hospital operators, insurers and the city's public health services can commission their own system on wai, branded as theirs and run from Germany. A first project takes one care pathway and the numbers that will judge it, and ownership of data, configuration and models is written into the agreement, as the organisations page sets out.

Where to start

First, write the secrecy obligation for the vendor and its subcontractors into the contract next to the data processing agreement.5 Second, test how a patient's request for access or correction reaches every draft and reply, as the HmbBfDI paper expects.4

Third, set up the first copy of the record without a fee, including the electronic copy.6 Fourth, agree which letters reach the ePA for statutory and private patients alike.8 Sort last month's WhatsApps, emails and missed calls by the hour they came in, and bring that list to a Hamburg demo. The rules here were read on 15 October 2026 as general information, and the practice's lawyer should check them against its own set-up.

Bring a week of evening messages and missed calls, and we show the drafts your team would have approved the next morning.

Frequently asked questions

What does the HmbBfDI say about AI and patient data?

Its July 2024 discussion paper says processing in an AI system must meet the GDPR, especially its output, and that access, erasure and correction rights apply to the system's input and output.4

Can a vendor's staff be liable for leaking patient data?

Yes. Section 203(4) of the Criminal Code makes unauthorised disclosure by a contributing person punishable by up to one year in prison or a fine.5

Can a patient ask for a copy of an AI-drafted note?

Once signed, the note is part of the record, and section 630g of the Civil Code gives the patient the right to inspect it and receive copies, the first one without a fee.6

Can privately insured patients in Hamburg use the ePA?

Yes, privately insured patients can use the ePA too.8 wai is built to connect to the ePA. We set up your clinic's connection with you.

Does wai reply to Hamburg patients by itself?

No. wai drafts each reply in the practice's voice and a member of the team approves it before it is sent. Clinical questions go to a doctor.

Where are the records held?

wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic.

Sources

  1. 1Statistisches Amt für Hamburg und Schleswig-Holstein, 2026Statistik informiert Nr. 108/2026, Bevölkerung in Hamburg 2025Read 15 October 2026Read source
  2. 2Statistisches Amt für Hamburg und Schleswig-Holstein, 2026Statistik informiert Nr. 75/2026, Anteil der Menschen mit Migrationshintergrund leicht gestiegenRead 15 October 2026Read source
  3. 3Ärztekammer Hamburg and Bundesärztekammer, 2026Ärztinnen und Ärzte nach Gebietsbezeichnungen und Tätigkeitsarten, Hamburg, Stand 31.12.2025Read 15 October 2026Read source
  4. 4The Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI), 2024Discussion Paper, Large Language Models and Personal DataRead 15 October 2026Read source
  5. 5Federal Ministry of Justice, Gesetze im InternetStrafgesetzbuch, section 203, Verletzung von PrivatgeheimnissenRead 15 October 2026Read source
  6. 6Federal Ministry of Justice, Gesetze im InternetBürgerliches Gesetzbuch, section 630g, Einsichtnahme in die PatientenakteRead 15 October 2026Read source
  7. 7Ärztekammer Hamburg, 2026Ärztekammer Hamburg, homepageRead 15 October 2026Read source
  8. 8gematik, 2026ePA für alle, Informationen für LeistungserbringendeRead 15 October 2026Read source
  9. 9wai, 2026wai changelog, intake answered by voice in any languageRead 15 October 2026Read source
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