For decades, medico-legal experts and doctors have handed their dictations to external transcription services. Tippiti transcribes your dictations in the same way, using AI rather than a typist. It can also turn assessment recordings into structured written documentation. Like a transcription service, Tippiti does not introduce medical findings, diagnoses or an expert opinion of its own.
In Germany, the 2017 reform of professional secrecy under section 203 of the German Criminal Code (StGB) introduced rules for external contributors to the work of professionals bound by secrecy. Involving an external service is permitted where disclosure is necessary and the provider is bound to confidentiality. The explanatory memorandum to the reform (Bundestag printed paper 18/11936) gives transcription work (“Schreibarbeiten”) as an example. Under EU data protection law, processing on behalf of a controller is governed by Article 28 GDPR. Professional secrecy itself remains a matter of national law in each member state.
For Tippiti’s technical workflow, including correction[TOOLTIP] Correction means identifying and fixing transcription and dictation errors. [/TOOLTIP], fact-checking[TOOLTIP] The fact-check verifies details that can be checked against a source, including proper names, medication names, ICD codes and place and postcode combinations. Clinical findings and diagnoses come from the clinician or medico-legal expert. [/TOOLTIP], plausibility checks[TOOLTIP] The plausibility check looks for clear logical errors, further reducing transcription and dictation errors. [/TOOLTIP] and a final independent AI validator[TOOLTIP] A different model runs a separate check for defined types of error, including spellings, place and postcode combinations, ICD plausibility and contradictions within the text.
Clinical judgements come from the clinician or medico-legal expert. The validator checks the text against the defined transcription and consistency criteria. [/TOOLTIP], see What problem does Tippiti solve?
Tippiti provides ready-made supplementary privacy information as a PDF in your account for any questions from your data protection officer.
When you register, you accept our Data Processing Agreement (DPA) under Article 28 GDPR, including a confidentiality obligation. Where § 630f BGB applies, the doctor’s duty to maintain treatment records remains unchanged. Medico-legal experts remain responsible for their own case records. Tippiti processes the recording into written documentation but does not introduce medical findings, diagnoses or an expert opinion of its own.
Your privacy notice under Article 13 GDPR must explain the use of external processors. Most practices already cover this for practice software, appointment services or IT support. If your notice includes a category such as “external service providers”, a service such as Tippiti will generally already be covered, just like an external transcription service.
If you run a transcription service and use Tippiti, this creates a subprocessing chain. Your client (for example a medico-legal expert) is the controller, you are the processor and Tippiti is the subprocessor.
You accept the DPA when you register. In Germany, the required confidentiality obligations must extend through the chain from your client, through your service, to Tippiti. You remain responsible for arranging the use of subprocessors with your client.
Whether consent is required depends on the legal basis for the processing. Using a processor does not in itself create a separate consent requirement. You must, however, enter into a Data Processing Agreement under Article 28 GDPR and meet the applicable transparency obligations. If your privacy notice already covers external service providers or processors, it may already provide the required information.
Tippiti acts as a processor when it transcribes your recording. Whether a transcription provider uses a medical typist or AI makes no difference to the legal requirements. In Germany, the explanatory memorandum to the 2017 reform of Section 203 of the Criminal Code (StGB) gives “transcription work” as an example of permitted external involvement.
The 2017 reform of Section 203 of the German Criminal Code (StGB) permits disclosure to external service providers where it is necessary and they are bound to confidentiality. That is exactly what our Data Processing Agreement governs. Cases like this are one of the reasons the reform was introduced.
Your data is used exclusively to process your recordings. It is not used to train AI models or disclosed to unrelated third parties, and it is processed in accordance with the GDPR. You can permanently delete your recordings at any time.
For more information, see Privacy & AI.
Tippiti's server infrastructure is hosted in certified data centres within the EU. Your recordings, the resulting texts and their version histories are stored in the EU.
AI processing uses models from several providers. A Data Processing Agreement is in place with each provider, and processing is carried out in accordance with the GDPR. The current providers and their processing locations are documented in Annex 2 of our DPA (German). The up-to-date list is available in the customer area.
Tippiti uses several independent models as part of its multi-stage process. It is model-agnostic and selects the best-suited model from leading providers for each task. The current providers are listed in Annex 2 of the DPA (German). The up-to-date list is available in the customer area.
All providers are contractually prohibited from using your data for model training. Tippiti does not train models with your data either.
A web search is not performed for every recording. It is used selectively for individual terms whose spelling or existence cannot be verified reliably from the model's knowledge, such as new medicines, rare active ingredients or unusual proper names.
Only the isolated term is submitted, without the surrounding recording or document, information about the speaker or client, or any reference to the patient. For example, the search query would be “carbamazepine”, not “patient has been taking carbamazepine for three years”.
In addition to the Data Processing Agreement (DPA), Tippiti provides a regularly updated document titled “Supplementary Privacy Information”, available as a PDF download in the customer area. It is intended specifically for data protection officers and answers the typical follow-up questions about the DPA.
For each AI subprocessor, the document describes the legal basis for transfers, the prohibition on using data for model training, potential human access, provider-side retention, encryption and certifications, with references to the relevant DPA. It also explains deletion, how compliance can be demonstrated to data subjects and the support available for a data protection impact assessment.
The download is available in the customer area on the “Annex 2: Subprocessors” page.
You remain in control of your data and can permanently delete recordings, resulting texts and all associated versions at any time.
Details of retention and deletion after the contract ends are available in the DPA (German).
This information is provided for general guidance and does not constitute legal advice. It does not replace individual review by a data protection officer or lawyer. While every care has been taken, we cannot guarantee that it is complete, accurate or up to date. Our services operate under EU law and are primarily designed for controllers based in the EU. Processors and controllers in other jurisdictions should verify local requirements.
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