For your clients

Effective 24 May 2026. Plain-English notice for clients of clinicians who use Cogent Clinic. Designed for a clinician to hand to a client on request or to attach to a clinic's privacy pack.

Your clinician uses a piece of software called Cogent Clinic to help with the writing side of their practice. This notice explains, in plain language, what that means for you. It is written for clients, not for clinicians or lawyers.

If you would like the longer legal version, the Clinician Privacy Policy and the Data Processing Agreement on this Trust Centre describe the same arrangements in more detail.

Who is responsible for your information

Your clinician is responsible for your information. They decide what to record, how it is used, and how long to keep it. Cogent Clinic Ltd is a company that provides software to your clinician and acts on your clinician's behalf.

In data-protection language: your clinician is the controller of your information. Cogent Clinic Ltd is a processor, which means it follows your clinician's instructions.

If you have a question about your record, ask your clinician first. They are the person who holds your record. They can also pass on questions that are about how the software works.

What Cogent Clinic does, in plain English

Three things, mainly:

1. Helps your clinician write notes faster. Your clinician types or dictates what they want to say. The software produces a draft. Your clinician then reviews, edits, and approves the draft before anything is saved as a note.
2. Helps your clinician organise their work. Each client has a folder. The folder holds the clinician's notes, the clinician's working formulation, and reminders for the next session.
3. Listens to your session if your clinician chooses to use that feature. With your consent and your clinician's, the software can listen to a session in the clinician's browser and produce a written transcript. The clinician then uses the transcript to help draft a note.

The software is a writing tool. It does not diagnose you. It does not make treatment decisions. It does not predict anything about you. Your clinician is the person in charge of your care.

How your information is protected

A few specific things happen behind the scenes that you may care about:

• Names and identifiers are removed before AI sees them. When your clinician writes about you and uses the drafting feature, your name and any phone numbers, NHS numbers, dates of birth, email addresses, or postcodes are replaced with placeholders before the text is sent to the AI. The AI sees text like "the client" or "PERSON 1" rather than your real name. The link between the placeholder and your real name stays on your clinician's device.
• Session transcripts are encrypted before they leave the clinician's browser. If your clinician uses the live-transcription feature, the transcript is locked with a key derived from the clinician's password. Cogent Clinic stores the locked version. Nobody at Cogent Clinic can read your session transcript.
• Your information stays in the UK for the writing and storage parts of the service. The piece of the service that turns spoken words into written words (the live transcription) is provided by a partner based in the European Union, under the standard UK contractual arrangements that protect your information when it crosses a border. Audio goes directly from the clinician's browser to that partner; it does not pass through Cogent Clinic's systems.
• Two-factor authentication is required. Every clinician who uses Cogent Clinic must sign in with both their password and a second proof of identity (typically a code from their phone). Without that, the account cannot be opened.
• The AI does not learn from your information. The AI providers that Cogent Clinic uses are contractually prevented from using your clinician's content to train their models.

What categories of information are involved

The categories of information that may be processed about you while your clinician uses Cogent Clinic include:

• the text your clinician writes or dictates about you, with your name and other direct identifiers replaced by placeholders;
• the spoken audio of a session, where your clinician uses the live-transcription feature and you have consented to it being recorded for that purpose;
• the encrypted transcript of that audio, which Cogent Clinic stores but cannot read;
• the clinician's working notes, formulation, and treatment plan, which mention you by placeholder rather than by name where possible.

The categories of information that are not routinely processed include your address, your full date of birth, your NHS number, your full email or phone number, and your full name. Where these appear in the clinician's input, they are replaced with placeholders before the AI sees them.

Your rights

You have legal rights about information held about you under UK GDPR and the Data Protection Act 2018. These rights include:

• the right to be informed about how your information is used (this notice is part of that);
• the right of access to a copy of the information held about you;
• the right to correction if something is wrong;
• the right to erasure in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to object to certain types of processing;
• the right to data portability for the parts of the record that are held electronically.

The right place to start is with your clinician. Your clinician is the person who decides what is in your record, who can access it, and how long it is kept. They are best placed to respond, and they will involve Cogent Clinic if a request needs us to do something on their behalf.

If you are unhappy with how a request has been handled, you can raise a concern with the Information Commissioner's Office at ico.org.uk/concerns or by phone on 0303 123 1113.

When your clinician shares something prepared with AI

If your clinician shares with you a note, summary, diagram, or printed document that was drafted with the help of Cogent Clinic, they will tell you that AI helped prepare the first draft. The final version is your clinician's. They have reviewed and approved it. You can ask them any question about it, and they remain responsible for what it says.

You are also free to ask your clinician, at any time, whether a document they are sharing was drafted with AI assistance. Many clinicians will mention this routinely; if yours does not and you would like to know, asking is appropriate.

If you do not want your session transcribed

The live-transcription feature is optional. Your clinician will explain it to you and ask for your consent before using it in a session. You can refuse, and you can withdraw consent at any time without it affecting your care.

If a session has been transcribed and you would like the transcript deleted, ask your clinician. They control the transcript and can delete it from their workspace.

If something goes wrong

If Cogent Clinic becomes aware of a security incident that may affect your information, we will tell your clinician within 72 hours of becoming aware of it, with the information we have at that point. Your clinician will then decide whether and how to tell you, based on their clinical and ethical obligations.

If your clinician makes a clinical decision based on a Cogent Clinic draft, the responsibility for that decision is theirs. Cogent Clinic is a writing tool. It does not make clinical decisions and is not a substitute for your clinician's judgement.

Who to contact

For anything about your record, contact your clinician.

For anything about how Cogent Clinic works as a piece of software:

Cogent Clinic Ltd Mearns Castle Golf Academy, Waterfoot Road, Glasgow G77 5RR Privacy email: [email protected] General contact: [email protected] Company number: SC887432 ICO registration: ZC132394

For independent advice or to make a complaint about how your information is handled:

Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Web: ico.org.uk/concerns Phone: 0303 123 1113

If we change anything in this notice that matters to you, we will update it here and tell your clinician.