Hilbi IQ · one question, answered

Who is responsible when AI touches a patient case?

Under the AI Act, whoever puts an AI system to work in a professional process carries the duties. Paste a case into a general assistant and the practice owns that. IQ arrives the other way round, as a processor under a written agreement.

  • Deployer duties, explained
  • Signature gate before filing
  • Architecture not published
Who is responsible when AI touches a patient case?

Deployer duties

carried by the processor, not by you

Art. 50(4)

transparency recorded on every output

Two ways of working, side by side

The comparison is between two situations, never between named products.

A general-purpose assistant used outside the clinical systemHilbi IQ
Who is the deployer under the AI ActThe practice, by putting the system to useAllocated in writing, with Hilbi as processor
Contractual relationship for the dataConsumer terms; usually no Art. 28 agreementArt. 28 processing agreement per market
Where the data is processedDetermined by the vendor's terms; often outside the EUEU for SK and CZ; India for IN (contractual)
Use for model trainingGoverned by the vendor's terms, changeableExcluded contractually
Transparency toward the patientNothing records that text was machine-generatedArt. 50(4) disclosure carried with the draft
Human oversightA habit, not a gateSignature gate: §21 SK, §12 CZ
Record of what happenedOutside the record; not auditable by the practiceImmutable trail, exportable by you
What reaches the clinical recordCopy-paste, unattributedStructured FHIR R4 resources, signed
Status keyIn forceIn progressReadiness

In force: applies today and can be evidenced. In progress: under way and dated. Readiness: the position is prepared and the market opens next.

What is published, and what is not

Enough to assess responsibility. Not enough to rebuild the system.

Processing location
Stated per market and contractual.In force
Legal roles
Provider as controller, Hilbi as processor under Art. 28 GDPR, with the AI Act deployer duties allocated in writing.In force
Transparency mechanism
Machine-generated clinical text is disclosed under AI Act Art. 50(4) and carries the clinician who signed it.In force
Oversight mechanism
A signature gate before filing, not a review recommendation.In force
Intended purpose
Generates a structured draft report for clinician review and suggests service codes. It does not diagnose and it does not decide.In force
Classification
Assessed against MDCG 2019-11 and AI Act Art. 6(1) on the stated intended purpose, so a reviewer can re-run the assessment.In force
Audit evidence
What was generated, what was edited, who signed, when: immutable and exportable.In force
What is not published
Model routing, prompt construction, retrieval design and the vendor mix are not published. Responsibility can be assessed without them, and publishing them would not make the answer more checkable.In force
Independent verification
Under agreement a reviewer receives the audit report, the penetration test summary and the sub-processor list.In force

The follow-up questions

Is it actually forbidden to use a general assistant on a patient case?

It is not automatically unlawful, but it moves the duties onto the practice: a lawful basis for the disclosure, a processing agreement with whoever receives the data, a transfer basis if it leaves the EU, the AI Act transparency duty toward the patient, and an audit trail the practice does not have. Most practices discover the gap when they are asked to evidence it.

What changes if the assistant is used with data that is not identifiable?
Who is liable if the draft contains an error?
Does the AI Act make IQ a high-risk system?
Why will you not publish the architecture?

Reading this as part of a shortlist?

The processing detail, the legal basis and the retention rules are on the IQ data page. The platform position is on the security page.

Where your data is processed

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