The Sovereign profile of Tonia runs transcription models (Whisper, Whisper-large-v3, equivalents) locally on-site installed in your clinic: no consultation byte crosses the border. The P-9.0001 Act and LSSSS art. 19 are respected by design. The Frontier profile remains available for medical-literature research (guidelines, published findings) without patient information. The Collège des médecins publicly recommended on-premises execution for transcription; that is exactly what the Sovereign profile delivers.
The private medical clinic — GMF, specialized clinic, multi-specialty clinic — operates under the densest regulatory stack of the six covered sectors: Bill 25 as a private entity, LSSSS (CQLR, c. S-4.2) for medical secrecy, Act P-9.0001 for health-information sharing, and the Code of professional conduct of physicians.
The practical consequence is known to every clinic that has deployed a transcription tool since 2022: Wispr Flow, Dragon Medical Cloud, and U.S.-hosted Whisper-as-a-service integrations transmit raw audio or transcripts to U.S. servers. Each of these transfers is, on its own, a potential breach of LSSSS art. 19, of Act P-9.0001, and of Bill 25 art. 17.
(Whisper, Wispr Flow, Dragon Medical). The most massively deployed case since 2023, and the most problematic. The consultation contains health information targeted by Act P-9.0001 and LSSSS art. 19 (patient name, complaints, history, working diagnosis, treatment plan). Any transmission of this audio or transcript to a server outside Québec requires an art. 17 para. 2 assessment — which no private clinic conducts as standard practice.
(structured summary, ICD-10 / SNOMED coding). Less sensitive if the transcript was tokenized first; still problematic because the summary contains the clinical elements (symptoms, diagnosis, plan) that constitute health information under LSSSS art. 19.
(literature review, guideline verification, published clinical precedent search). Low sensitivity: the request does not touch patient information. Case where generative AI adds value without engaging medical secrecy.
The Whisper model (or equivalent) runs on the on-site tonia in the clinic. Audio goes from microphone to on-site tonia, is transcribed locally, and the transcript stays on-site for integration into the patient record. No outbound request. This is the strongest Sovereign-profile test case in health — it closes three sectoral laws simultaneously.
Same posture. The structured note is produced on-site; the physician reviews and integrates it via the EHR; no note leaves the clinic.
The Frontier profile routes approved requests to a frontier-model provider. The request ("What are the 2025 Canadian guidelines on atrial fibrillation?") contains no patient information. This profile gives access to a larger-capacity model than the one loaded locally.
Multi-specialty clinic on Montreal's north shore, ~15 family physicians + 5 specialists + 12 nurses and administrative staff, replaced a U.S. cloud transcription service with Tonia — Sovereign profile in Q1-2026. Collège des médecins validation desirable but not mandatory for publication.
The clinic had been using Wispr Flow for consultation transcription since 2024 — adopted for its French-language transcription quality. The 2026 publication of the Collège des médecins Position on AI in clinical practice and a CAI communiqué on cloud transcription tools triggered an internal review. December audit: systematic transfer of consultation audio to U.S. servers, without a documented art. 17 assessment, without a health-adapted contractual framework.
Switch in Q1-2026: on-site tonia installed in the clinic's technical room, capacity sized for 20 simultaneous consultations at morning peak. Whisper-large-v3 loaded locally. Policy configured by the clinic's PRPRP with help from a medical-infrastructure consultant. 2-h physician training + 1-h staff training.
BLOCK event count (PII patterns detected by the DLP engine — monitors accidental leaks toward the Frontier profile)Want to see how this applies to your clinic? Start with the free Loi 25 audit, then request a 30-min consultation. We will review your clinical use cases, LSSSS and P-9.0001 obligations, and on-site tonia sizing if your context calls for it.
Disclosure notice: this page is editorial and reflects Tonia's commercial position. Regulatory references are verifiable at the indicated links. Before acting, validate the obligations specific to your organization with your counsel.