AI Policy

1. Cara Crothers Psychology Pty Ltd’s commitment to the legal, ethical and responsible use of AI:

1.1. Cara Crothers Psychology (“us”, “we” or “our”) is committed to using AI to improve the health outcomes of clients, in a way that is legal, ethical and responsible.

1.2. The purpose of this AI Policy is to create a set of guiding principles that comply with the legal and ethical obligations that govern the responsible use of AI tools by clinicians.

1.3. Cara Crothers Psychology Pty Ltd takes the privacy of clients’ information seriously, and our Privacy Policy sets out how we collect and treat your Personal Information and Sensitive Information. Our Privacy Policy and this AI Policy operate together.

1.4. This AI Policy deals with both the general principles Cara Crothers Psychology Pty Ltd is committed to in order to ensure the legal, ethical and responsible adoption and use of AI tools, as well as guidelines for the AI tools used by Cara Crothers Psychology Pty Ltd to ensure the use of those tools is of benefit to clients and promotes client health outcomes while protecting client data and information.

2. Definitions

In this Policy:

2.1. “AI” stands for artificial intelligence and refers to the capability of a machine to imitate intelligent human behaviour.

2.2. “AI tool” describes any software program that uses AI to perform tasks.

2.3. “Large language model” or “LLM” is a type of artificial intelligence model designed to understand, generate or manipulate human language. They are trained on very large amounts of text data and use statistics and machine learning techniques to generate text based on the input they receive.

2.4. “Generative AI” is a type of machine learning model that generates new content (for example, text, images, videos etc) as outputs.

3. Cara Crothers Psychology Pty Ltd’s Statement of Values and Ethics in the use of AI

3.1. Cara Crothers Psychology Pty Ltd believes that with appropriate policies in place, AI can support the delivery of healthcare outcomes.

3.2. Cara Crothers Psychology Pty Ltd believes that human-delivered care must never be replaced by AI, but that AI has the potential to assist in care delivery and improve client outcomes. AI is seen by Cara Crothers Psychology Pty Ltd as a means to achieving the goal of improved healthcare but can only support the psychologist and client to reach this goal.

3.3. Improved client health and well-being will always be the primary and guiding focus of the adoption of all AI tools by Cara Crothers Psychology Pty Ltd. AI tools will only be adopted by Cara Crothers Psychology Pty Ltd where this will genuinely contribute to improving health outcomes of clients.

3.4. The adoption and implementation of all AI tools by Cara Crothers Psychology Pty Ltd will be client-centred and used to benefit clients’ health and well-being.

3.5. AI must never compromise the clinician’s clinical independence or professional autonomy.

3.6. A registered health practitioner or otherwise appropriately qualified clinician must always be ultimately responsible for decisions and communications and should have meaningful involvement at all stages of the client journey.

3.7. All AI tools implemented by Cara Crothers Psychology Pty Ltd must uphold and support the clients’ rights to make their own informed healthcare decisions.

3.8. It is important to Cara Crothers Psychology Pty Ltd to be accountable and transparent to clients, the health profession and the wider community about the use of AI in supporting clients’ healthcare outcomes.

3.9. The application of AI in health care must never lead to greater health inequalities for any population.

3.10. Clients have the right to refuse to be involved in the use of AI at any time

3.11. AI tools will only be adopted by Cara Crothers Psychology Pty Ltd after first establishing robust and effective frameworks for managing risks which ensure client safety and guarantee the privacy for all involved. These frameworks will be bespoke to the AI tool being adopted, and regularly and vigorously reviewed.

3.12. Cara Crothers Psychology Pty Ltd will never establish protocols where the clinical independence of the clinician is undermined by AI or the final decision is made by a person in a non-clinical role with the aid of AI.

3.13. AI tools will not be used by administrative (non-clinical) staff.

4. Use of clients data and information

4.1. As outlined in our Privacy Policy, Cara Crothers Psychology Pty Ltd may receive and store your Data.

4.2. Cara Crothers Psychology Pty Ltd is committed to the protection of the privacy of client health information.

4.3. Cara Crothers Psychology Pty Ltd will always use AI in accordance with the Privacy Policy in place at the relevant time.

4.4. Cara Crothers Psychology Pty Ltd will only adopt and use AI tools following a careful review of that tool’s approach to privacy and has adopted a protocol of regular checking the tool to ensure there has been no material change to the way client data and information is stored, used and deleted.

4.5. AI tools will not be used, disclosing a client’s personal or sensitive information, without written consent from the client.

4.6. The disclosure of Health Information must be limited to initiatives that exclusively aim to provide the health service to the client and/or improve the clients health outcomes.

5. Complaints about our AI policy

5.1. If you have any complaints about our AI practices, please feel free to send in details of your complaints to:

cara@caracrotherspsychology.com.au

5.2. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

6. Changes to our AI policy

6.1. Our AI Policy is subject to change.

6.2. Cara Crothers Psychology Pty Ltd may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website caracrotherspsychology.com.au, or through distribution by email. Please check back from time to time to review our AI Policy.

7. Current AI tools in use

7.1. Cara Crothers Psychology Pty Ltd will maintain a list of AI tools in regular use by its clinicians.

7.2. At present, Cara Crothers Psychology Pty Ltd uses:

- Heidi Health Trading Pty Limited (hereinafter referred to as ‘Heidi Health’).

7.3. A summary of each AI tool adopted and how it is used is set out below.

Important Info

  • Heidi Health is an AI scribe tool that produces an AI generated note or report from a live or recorded client session/s with a psychologist. By utilising ambient listening technology, Heidi Health ‘sits-in’ on client sessions and transcribes the conversation. The practitioner can then prompt the scribe to automatically generate structured clinical documents such as progress notes, using structured templates and preferences.

  • Heidi Health will assist the practitioner by ensuring that the focus will be on the client and not note taking, or technology. Heidi Health will enable the practitioner to focus on engaging with the client and on the conversation, and less on manual note taking, enhancing the quality of care received and leading to better client outcomes. Heidi Health will also reduce the time spent by the practitioner preparing records following the consultation, which will instead be allocated to a larger focus on treatment planning and preparation for the psychological intervention.

  • Heidi Health will assist the practitioner by transcribing a live client session and producing an AI generated note or report upon completion. Heidi Health will only be used by practitioners.

  • Heidi Health cannot and will not be used to make decisions in relation to client care. Heidi Health will not be used by administrative (non-clinical staff). Notes generated by Heidi Health will not be adopted as a part of the client’s file without a review by the practitioner.

  • Heidi Health will only be used with clients who have provided written consent for the use.

  • The practitioner using Heidi Health will be responsible for finalising the notes made by Heidi Health. That is, the notes will not be automatically saved to the client’s file but will be reviewed for accuracy and completeness by the practitioner, who is responsible for the client’s records.

  • During the consultation, the practitioner will make note of the key points that must be included in the client’s records. The practitioner will use these key points when reviewing the note prepared by Heidi Health, to ensure that the note is both accurate and complete. In this way, each note will have an independent human lead review to ensure that case notes created by Heidi Health are at least as good as the notes that would have been recorded by the practitioner during the client consultation.

  • For internal record-keeping purposes, content created with the assistance of Heidi Health will be labelled as such, by including a note like the following: “Session notes created with the use of Heidi Health and reviewed and adopted by Cara Crothers.”

  • Heidi Health uses ambient listening technology to transcribe conversations in real time, but the audio itself is not retained. Heidi Health processes the recordings to create temporary draft records that practitioners can use to generate notes, and only the practitioner has access to these temporary records. Once deleted, they cannot be recovered by Heidi Health or any other party. Although the data can be stored for longer periods of time, Cara Crothers Psychology Pty Ltd will set a mandatory timeframe for all data to be deleted within 4 weeks of the consultation.  Heidi Health has been carefully selected by Cara Crothers Psychology Pty Ltd as it complies with the Australian Privacy legislation and the Australian Privacy Principles.

  • Only clinicians will have access to and use Heidi Health. Administrative staff will not use the tool and will not have access to the system.

  • Cara Crothers Psychology Pty Ltd is committed to a regular assessment and review of the adoption and use of Heidi Health. In addition to the contemporaneous review for accuracy and completeness conducted before the adoption of every single note created by Heidi Health, Cara Crothers Psychology Pty Ltd will conduct a comprehensive random audit every 6 months. The purposes of the random audit include confirmation that this AI Policy is being adhered to, that the information contained in the AI policy in relation to each AI tool adopted is correct and up-to-date, and that the notes generated after consultations are both accurate and complete.