Abstract
Artificial intelligence (AI) is the use of digital technology to create systems capable of performing tasks commonly thought to require human intelligence. AI is likely to be something we use in our non-professional life, such as face recognition on mobile phones, and voice-based AI assistants on home devices. AI is being used by some health and care organisations and may become more commonplace in the future. Dr Hana Patel will discuss how registrars can decide where they sit in the current debate on the use of artificial intelligence in primary care in the UK.
What are the current regulations around artificial intelligence in primary care?
On 19 June 2025 the Data (Use and Access) Act (DUAA) became law in the UK. As many are aware, artificial intelligence (AI) has the potential to make healthcare safer, faster and more personalised. It could help National Health Service (NHS) staff work more efficiently and support the growth of health technology companies in the UK. However, AI also brings new challenges for how the government regulates and oversees these technologies (Ardic and Dinc, 2005).
All NHS-funded GPs are considered as public authorities and are required to appoint or have in place a data protection officer (DPO). The DPO must have proven expert knowledge of data protection law and practice. They will need to keep up to date with any changes and clarifications (for example from the Information Commissioner’s Office [ICO]) and understand how these changes impact the practice.
What potential complaints do the primary care team need to be aware of?
The UK General Data Protection Regulation (UK GDPR) is a UK law, that took effect on 1 January 2021 and governs how personal data is used by organisations, including the NHS. It regulates the processing of information, to ensure it is handled legally, fairly and transparently. The UK GDPR law sets strict rules on data security, accountability and individual privacy rights.
It is important to be aware that people have the right under UK GDPR Article 22 not to be subject to automated decision making, where the outcome produces a legal or similarly significant effect on them. In primary care, this means that patients have the right not to be subject to decisions based solely on automated processing (including profiling) that significantly affect them. An example might be automated medication changes or risk profiling. If such systems are used, patients have the right to request ‘human intervention’ in that a clinician reviews this decision, rather than relying solely on computer algorithms, as patients have the right to understand the logic behind an automated decision-making process.
The patient can express their viewpoint and contest the decision. Not only should patients give their explicit consent for their health information to be used for profiling; but this is also required to protect the clinician from legal effects.
What do colleagues in primary care think about artificial intelligence?
In a study carried out by Kharko et al. (2025), the team explored GPs’ opinions on AI. They found GPs anticipated a variety of benefits from AI, including aiding in documentation, patient information gathering and diagnosis.
However, concerns among GPs were also prominent, including legal risks, patient harm and increasing healthcare inequities because of using AI.
Your practice may have an information governance (IG) lead, Data Protection Officer (DPO) and Caldicott Guardian who should be involved in any discussions or concerns regarding AI. Several AI tools are already being used in the NHS, such as ambient scribes in GP consultations, AI-assisted discharge summaries and AI interpretation of radiological imaging.
If colleagues are concerned about AI, they should report inaccuracies, false outputs or data gaps to the practice’s Clinical Safety Officer (CSO) or Digital Lead as mentioned previously.
Final thoughts
The General Medical Council (GMC), as with other medical devices, state that they expect doctors, physician associates and anaesthesia associates to use their professional judgment to apply the principles in their guidance for the use of innovative technologies or AI tools. The GMC also advises that doctors, physician associates and anaesthesia associates are responsible for the decisions they take when using new technologies like AI, and the principles in the professional standards continue to apply. For example, it is important to discuss the use of innovative technologies with patients, what other options may be available and any uncertainties and limitations, so that informed decisions can be made. The GMC highlights the need for ongoing training for doctors to properly evaluate and safely use AI systems and has advised that if doctors are unsure of the safety of a new technology, they should not use it until they are satisfied it is safe, and they must speak up about any errors the technology makes.
