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

The private care market in Toronto

Toronto had 2,794,356 residents on Census Day 2021, 7.6% of Canada's population, inside a Greater Toronto and Hamilton Area of 7,281,694.⁵ Of the 2,761,285 people in private households, 1,286,140 were immigrants, or 46.6%, and 342,360 of them arrived between 2011 and 2021.⁶

Every physician practising here is licensed by the College of Physicians and Surgeons of Ontario, which welcomed over 9,000 newly registered doctors and over 700 physician assistants in 2025.⁷ Ontario's public plan covers medically necessary care, and the Canada Health Act defines extra-billing as charging an insured person for an insured service beyond what the provincial plan pays.¹¹ Private clinics in Toronto therefore centre on services the plan does not insure.

The rules a Toronto clinic works under

Health records in Ontario fall under the Personal Health Information Protection Act, 2004 (PHIPA), overseen by the Information and Privacy Commissioner of Ontario (IPC). Physicians also answer to the CPSO.

In January 2026 the IPC published AI Scribes, Key Considerations for the Health Sector. It finds no PHIPA provision that explicitly permits a custodian to collect, use or disclose personal health information through an AI scribe without consent, so consent is generally required, and it calls express consent recorded in the patient's health record a best practice.¹ It also asks clinics to post a notice describing how the AI scribe uses that information and to let patients withhold or withdraw consent.¹

The same guidance requires every record created or altered by an AI scribe to be reviewed for accuracy before it is used or disclosed, and recommends review before it enters the EMR.¹ Where a scribe translates a record into another language, the custodian remains responsible for confirming the translation is accurate.¹

For vendors, the IPC expects a service agreement that bars any use of personal health information the custodian has not authorised, requires secure disposal on request and covers any subcontractors.¹ It also asks vendors to report when the scribe falls below agreed accuracy thresholds.¹

The CPSO's Advice to the Profession on using AI in clinical practice, last updated August 2025, encourages AI scribes for documentation. It makes physicians accountable for reviewing all AI output for accuracy and completeness, and asks them to tell patients how AI is used and obtain consent before recording conversations.²

Under section 184 of the Criminal Code, intercepting a private communication is an offence unless the person has the consent of the originator or the intended recipient.³ The IPC and CPSO expect more in a consultation, so a Toronto clinic asks the patient before the scribe starts.

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 Toronto. For a Toronto clinic that means records stay in Canada, and the IPC asks that patients be told whenever information is processed or stored outside the country.¹ Every message, draft, approval and signature is written to an event log the clinic can export, and every subprocessor is named, with thirty days notice before anything changes.¹⁰

The languages Toronto patients write in

In the 2021 Census, 1,244,555 Toronto residents, or 44.9%, spoke at least one language other than English or French at home, and 4.5% had no knowledge of either official language.⁴ Mandarin led the home languages after the official ones at 86,150 people, followed by Cantonese at 74,845, Tagalog at 51,355, Spanish at 46,355 and Tamil at 40,825.⁴ Tagalog speakers grew by 20.8% between 2016 and 2021.⁴

wai works in any language.⁸ A member of the team reads each drafted reply before it goes to the patient, and the clinician checks any translated note before signing it, as the IPC asks.¹

What a demo shows in Toronto

The demo opens on a WhatsApp message in Mandarin, sent at 10:15pm from North York, asking whether a woman and her mother can both be seen on Saturday morning. wai reads it in the patient's thread, checks the clinicians' busy times in Google Calendar, Outlook or Apple Calendar and drafts a reply in Mandarin offering two adjoining open slots. The coordinator reads it at 8am and approves it in one tap.

The booking link takes a deposit in Canadian dollars through the clinic's own Stripe account, with the clinic as merchant of record and no wai subscription or setup fee for Checkout.⁹ The patient receives a confirmation, a receipt and an intake questionnaire, and the clinic's AI scribe notice can be linked from each service description, so the patient has read it before the consult.⁹

In the consult, the clinician sees the drafted note and referral letter, edits them and signs. Bring one of last month's enquiries, untranslated, and watch the draft appear.

For hospitals, health systems and insurers in Toronto

Toronto hospital networks, clinic groups and insurers can have wai build a system under their own brand. It starts with one care pathway and the measures its clinicians agree, with data and model rights written into the contract, as the organisations page describes.

Where to start

First, write a one-paragraph AI scribe notice, post it where patients book and record each patient's express consent in the chart, using the consent form template as a base.¹ Second, ask every vendor for the contract terms the IPC lists, including the ban on unauthorised use and the list of subcontractors.¹

Third, name in the clinic's records policy who reviews and signs each AI draft, which is what the CPSO expects of physicians.² Fourth, count last month's enquiries by language and by hour, so the demo runs on the clinic's real mix. The Ontario and federal sources here were read on 15 October 2026, and the clinic's counsel should confirm how they apply.

Frequently asked questions