The short answer
NHS England’s guidance asks the organisation using an AI scribe to complete a DPIA, complete the DCB0160 clinical safety documents with a named Clinical Safety Officer, make sure clinicians review every output, tell patients, and keep checking accuracy.
Below are Squte’s data flows and a hazard-log starter to copy into your own documents. They are a starting point: your practice owns the assessment and its conclusions.
What NHS England asks of your practice
NHS England’s guidance on ambient scribing products (version 3, updated 29 July 2026) covers health and care settings in England. It doesn’t mention dentistry, but it applies to any organisation deploying these tools (NHS England AVT guidance). It asks you to:
- Do a DPIA. NHS England’s IG guidance says a DPIA is “highly likely to be a legal requirement”, and offers a template (NHS England, IG guidance).
- Name a Clinical Safety Officer and complete DCB0160. That means a safety case, a hazard log and a way of monitoring the tool. DCB0160 is the NHS standard for organisations that deploy health IT (NHS England Digital).
- Review every output. Users should “review and approve any product outputs” before anything else happens with them.
- Train the team on approved use, including how microphone position affects results.
- Tell patients at the start of each appointment, and in your privacy notice. See the consent kit.
- Keep checking accuracy through audits, and watch for bias with accents, dialects and speech impairments.
- Report incidents through your usual local system. NHS England also encourages Yellow Card reports to the MHRA.
Pilots are allowed, but time-limited to four months at most, and they can’t be used to skip these steps.
What to ask any supplier
The same guidance lists what the supplier should have or provide:
- A completed DCB0129, the manufacturer’s clinical safety standard, and its safety case report.
- A Digital Technology Assessment Criteria (DTAC) assessment.
- The Data Security and Protection Toolkit (DSPT) and Cyber Essentials, for you and the supplier.
- Its medical device status, and MHRA registration where that applies.
- Integration with your patient record system.
- Where data is stored, who can access it, how long each kind is kept, and whether it is used for anything else.
Where Squte stands today. Squte does not yet hold a DCB0129 safety case, a DTAC assessment, DSPT or Cyber Essentials, and it is not on NHS England’s AVT supplier registry. We will list each here, with its date, once we have it. Squte has no direct integration with practice systems: the clinician copies the signed note in. On device status, see the MHRA guidance, explained.
Squte’s data flows, for your DPIA
Copy these into the description of processing in your DPIA. Check each line against how your practice uses Squte.
| Whose data | Patients, the clinician, and anyone else who speaks in the room, such as a nurse or a parent. |
|---|---|
| What data | Audio of the appointment; the transcript; the draft and signed note; the consent record (wording, method, time); and the clinician’s short voice sample, used to tell their voice from the patient’s. |
| Purpose | Drafting the clinical record of the appointment, for the patient’s direct care. |
| Controller and processor | Your practice is the controller (NHS England, IG guidance). Squte processes the data for you under a data processing agreement. |
| Lawful basis | Your practice decides. NHS England names UK GDPR Article 6(1)(e) and Article 9(2)(h) as most likely for direct care; a practice treating patients privately should check its Article 6 basis. Confirm with your data protection officer. |
| Storage | Stored encrypted on AWS servers in London. |
| Speech recognition | Deepgram’s EU service, with model improvement switched off on every request. |
| Note writing | Google Gemini on Vertex AI, through Google’s EU endpoint. |
| Use for AI training | Not used to train AI models. |
| Retention | Audio is deleted 30 days after the note is signed. The signed note and transcript stay as the clinical record. If the patient withdraws consent, the recording is deleted straight away. |
| Security | Encrypted in transit and at rest. Each practice’s data is kept apart at the database level. |
| Human review | Nothing is filed until the clinician checks and signs the note. Every change to a note is logged with who made it and when. |
| Decisions about patients | None. Squte drafts the record; the clinician makes every clinical decision. |
| Practice software | No direct integration. The clinician copies the signed note into the practice system. |
| Points to weigh | Whether the clinician’s voice sample counts as biometric data in your assessment, and how long you need the transcript, since NHS England notes that recordings and transcripts could be deleted once the note is signed off. |
More detail on each provider, with links to their terms, is on where your patients’ recordings go.
A hazard-log starter for DCB0160
Seven hazards an AI scribe can introduce, with the controls Squte builds in and the controls your practice adds. Rate severity and likelihood with your Clinical Safety Officer, and add hazards from your own setting.
| Hazard | What could happen | Squte’s controls | Your practice’s controls |
|---|---|---|---|
| Wrong tooth number | A finding or treatment is charted against the wrong tooth. | Writes tooth positions in UK notation (UR6) from what is said. The note stays a draft until signed. | Say tooth numbers clearly. Check every tooth number before signing. |
| Words put in the wrong mouth | Something the patient said is written as the clinician’s finding, or the other way round. | A voice sample tells the clinician from the patient. The transcript shows who said what. | Each clinician records their own voice sample. Check attributed history and findings. |
| Something left out | A finding, risk or piece of advice is missing from the record. | Sections the appointment didn’t cover are left empty, not filled with stock text. | Read the note against what you did. Add anything missing before signing. |
| Something added that wasn’t said | The note records a finding, diagnosis or discussion that didn’t happen. | Instructed to record only what was said, with no stock lines. A diagnosis appears only when the clinician states it; Squte never suggests diagnoses or treatment. | Check every line. Include AI-drafted notes in your record-keeping audits. |
| Recording without agreement | A patient is recorded without being told or given the chance to say no. | The server refuses to record or transcribe until the patient’s answer is saved with the visit. If the patient withdraws, one tap stops processing and deletes the audio. | Train the team. Posters and booking texts tell patients in advance. |
| Note filed unchecked | An unreviewed draft becomes part of the record. | Squte never writes into your practice system. Copy is available only after the clinician signs; a signed note can’t be changed, only amended, and every change is logged. | Only signed notes are pasted into the record. Spot-check this in audits. |
| Note on the wrong patient | A note is pasted into another patient’s record. | Each visit is tied to the patient chosen before recording. | Check the patient’s name and date of birth before pasting. |
| A note the AI didn’t write | A rough or partial draft is mistaken for a finished AI note. | If the AI or transcription service fails, the visit shows as failed with a Retry button and an alert goes to Squte. No substitute draft is presented as an AI note. | Retry, or type the note. Report repeated failures to Squte. |
| Audio kept or seen by the wrong person | A recording outlives its purpose or is opened on a shared device. | Audio is deleted 30 days after signing, after 60 days if a note is never signed, and at once if consent is withdrawn. Audio waiting on the device is encrypted and cleared at sign-out. Squte staff can never access recordings. | Sign notes promptly. Each person signs in to their own account on shared iPads. |
Checking accuracy after you start
NHS England asks for ongoing audits of clinical documentation. One way to do it: each month, pick a few signed notes per clinician and compare them with what happened, looking at tooth numbers, who said what, and anything missing. Include clinicians and patients with a range of accents. Keep the results with your hazard log and review it when the tool changes.
Documents we can send you
Before your practice starts with Squte, we sign a data processing agreement with you and send our list of the companies that process data for us and where, with answers to your security questionnaire. Squte does not make a practice compliant on its own; these help you complete your own assessment.
Read next
- Patient consent for AI scribes →A consent kit for UK dental practices: what to say, when to tell patients, recording a refusal, poster and privacy-notice wording.
- Patient data →Where recordings and notes are kept, every company that handles them, and how long audio is kept.
- The MHRA’s AI scribe guidance, for dentists →What the MHRA’s July 2026 guidance means for dental practices: which scribes are medical devices and why.
Try it on your own appointments.
Squte is an AI dental scribe for UK dentists. It asks the patient’s consent, records the appointment and drafts a UK 17-section clinical note for the dentist to check, change by voice and sign.
14 days or 100 visits, whichever comes first. Card required, and nothing is charged during the trial. Then from £25 a month, no VAT to add. Cancel before the trial ends and you pay nothing.
General information, not legal, clinical or tax advice. Squte makes AI dental scribe software, so we have an interest in this subject; every fact above links to its source. How we write. Found an error? Email hello@squte.co.uk and we correct verified errors within five working days.