Solutions · Dental clinics

AI voice agents for dental clinics.

Taking and initiating calls, with configured sources and actions. This page places the service mechanism alongside the rules that apply in dental clinics — without claiming a project we have not done.

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Starting point

What dental clinics look like before any software

The phone rings while someone is holding an instrument in their hand. In a small practice, the person who answers is often the same one who sterilises, takes payment and leads the patient to the chair. The missed call leaves no trace anywhere: there is no line in a system that says someone called at 14:20 and was not answered. The patient calls on to the next practice. This is not a politeness problem, it is an architecture problem — there is nowhere for the request to wait.

The patient file is not in one place, although everyone speaks about it in the singular. There is the actual clinical record, kept by the doctor on paper or in a practice programme. There is the appointment diary, often in an online booking service, with the name, phone number and procedure name. And there is the messaging thread in which the patient sent a photo of the tooth and described since when it has hurt. The third is the one nobody declares as processing, although it contains exactly the same data as the first.

Between what is covered by compulsory insurance and what is paid out of pocket runs a line that reception is obliged to explain by phone, dozens of times a day. The answer depends on the patient’s insured status and the exact service, not on its general category. A price list published without that distinction does not spare any call — it reproduces it, because it raises exactly the question it does not answer.

Reception is not the doctor, and that boundary is legal, not one of politeness. The person who answers knows the schedule, the address, the list of services and who is free on Thursday at 16:00. They do not know and are not allowed to say whether the tooth needs to be extracted. Any system built for reception inherits the boundary: it can say when there is a slot, it cannot say what the patient has. A system that crosses the line does not become more useful, it becomes something else — processing without a basis.

Dentistry works with images. Orthopantomograms, periapical X-rays, intraoral photographs, before-and-after comparisons. Images circulate through messaging, reach presentations and social media pages, and the signed consent for treatment is not the same as the consent for publication. These are two different decisions, taken at different times, and in practice only the first is taken.

The order of a call, with the branch that costs nothing

Regulile

What applies in dental clinics, with the article it comes from

Each rule below carries the normative act that imposes it. Verification does not require you to take our word for it.

The dental record is a special category of data, not ordinary data

The law starts from a prohibition, not a permission: processing data concerning health is prohibited, and what makes it lawful are the exhaustively listed exceptions. The definition is broad — “data related to the physical or mental health of a natural person, including the provision of healthcare services which reveal information about that person’s state of health”. In a practice, this covers the anamnesis, diagnosis, treatment plan, radiographs and, in many cases, even the name of the scheduled procedure. The practical difference from ordinary data: it is not enough to identify one of the six general grounds, you also need an exception from the special categories article.

SourceLaw 195/2024, art. 9 para. (1) and art. 4 (definition of “health data”); Regulation (EU) 2016/679, art. 9 para. (1)

The medical exception stops at the reception desk

The exception on which any practice relies — processing necessary for establishing a diagnosis, providing care or treatment — comes with a condition that is rarely read: data may be processed for this purpose only by or under the responsibility of a professional subject to the obligation of professional secrecy. The exception is linked to the person and the purpose, not to the institution. An appointment is not a diagnosis, so it cannot be based on it; for an appointment, the natural basis is the performance of a contract or steps taken at the person’s request before the contract. The design consequence is simple and firm: the appointment flow must not request clinical information, because it has nothing to support it with.

SourceLaw 195/2024, art. 9 para. (2) lit. h) and para. (3); art. 6 para. (1) lit. b)

Medical secrecy is a second layer, with different limits from data protection

Above data law stands an older and stricter obligation. All data concerning the patient’s identity and state, the results of examinations, the diagnosis, prognosis and treatment are confidential and must be protected even after the patient’s death. Doctors, other medical and healthcare workers and pharmacists are obliged to maintain the secrecy of information concerning the illness and the intimate and family life of the patient. Disclosure without consent is allowed only in the cases listed — the involvement of other specialists in the treatment process, to the extent necessary for the decision; a real risk of spread of infectious diseases; a reasoned request from the criminal investigation authority or the court, and the others in the same article. The difference that matters in design: data law concerns natural persons, medical secrecy does not end at death.

SourceLaw 263/2005 on patients' rights and responsibilities, art. 12 para. (1)–(4); Law on Healthcare Protection no. 411/1995, art. 14 para. (1)

Informed consent for treatment is not consent to data processing

There are two different consents, required by two different laws, and they are almost systematically confused. The patient’s consent to the medical intervention is completed by entry in the medical documentation, and for interventions with increased risk — invasive or surgical — it is mandatory in writing, on an informed consent form, which describes the purpose, methods, risks, consequences and alternatives. Consent to data processing, when used, is something else: it must be explicit for special categories, presented in a form that clearly distinguishes it from the other aspects of a written statement, in clear and simple language, and its withdrawal must be as simple as giving it. A form that mixes them does not meet either requirement.

SourceLaw 263/2005, art. 13 para. (1)–(3); Law 195/2024, art. 9 para. (2) lit. a), art. 7 para. (2) and (3)

The record of processing activities is mandatory regardless of the size of the practice; the data protection officer is not necessarily so

The exemption for organisations with fewer than 250 employees falls away if the processing includes special categories of data — which is the case for any dental practice. Therefore, the record of processing activities, with the purposes, categories of data subjects and data, recipients, retention periods and description of security measures, is kept even in a practice with three people. Appointing a data protection officer is another question: it becomes mandatory when the main activities consist of large-scale processing of special categories. And “large scale” has an explicit benchmark — processing should not be considered large-scale when it concerns the data of a single doctor’s patients or those of another healthcare professional. A small practice does not automatically qualify, a network of clinics is a different matter.

SourceLaw 195/2024, art. 30 para. (5) and para. (1); art. 37 para. (1) lit. c); Regulation (EU) 2016/679, recital (91)

Any provider who sees the record is a processor and needs a contract

The online booking service, hosting, the surgery schedule, the messaging channel through which photos move — all process data on behalf of the surgery, so they are processors. The law requires a written contract that sets out the subject matter, duration, nature, purpose, type of data and categories of data subjects, and that provides that the provider works only on documented instructions, keeps staff under confidentiality, does not subcontract without the surgery’s authorisation, helps with replies to patients and breach notifications, and at the end deletes or returns the data. Where the server is located matters separately: transfers to states within the European Economic Area do not need special authorisations, while the rest need an adequacy decision or adequate safeguards, such as standard data protection clauses.

SourceLaw 195/2024, art. 28 para. (3), (4) and (8); art. 44 para. (2); art. 46 para. (2) lit. c)

Mecanica

What AI voice agents actually do

The same capabilities that appear on the service page, where each has its own file and back-end line.

The session is requested from the platform, not from the voice provider

The page sends `POST /functions/v1/widget-voice-session` with the widget's public identifier and receives a signed URL back. It never has the agent identifier or any key. The wrong variant — `startSession({ agentId })` directly in HTML — completely bypasses the platform's session, credit and log layer, and exposes the agent to anyone who opens the page source. It is the first check we make on any implementation we take over.

The microphone is requested before the session, so a refusal costs nothing

The order is fixed and it matters: request the microphone with `getUserMedia({audio:true})`, and only if the person accepts request the session. If the visitor refuses, no signed URL is issued and no minute is consumed. The microphone request is made inside the button press, before any wait that could outlast the gesture — otherwise the browser ignores the request.

The agent can be interrupted, and this is adjusted with numbers

On OpenAI Realtime: semantic speech detection, threshold 0.5, 300 ms cushion, 500 ms of silence, interruption enabled by default. On ElevenLabs: the `interruption` event is passed to the controller to stop playback. On top of that, per-agent `turn_timeout` decides after how much silence the agent considers it is their turn — 15 seconds by default, tightened to 12 on a sales agent. And a client-reported “I can’t interrupt it” often has another cause than the thresholds: responses that are too long. We address that in the prompt and in the token limit, not in speech detection.

Call tools during the conversation

The agent is not trapped in what it knows. It can call server functions while speaking — to read availability, write an appointment, send an SMS, or query a catalogue. Tools are declared per agent, with typed parameters and their own execution timeout, so a slow tool does not block the conversation.

Handing off to a human is part of the scenario, not an exception

In messaging, handover to a colleague has its own state on the thread — `handoff_status`, handover time, reason, who is assigned, resolution notes — implemented in a dedicated 619-line module. On the phone, the transfer is handled by the switch: blind transfer via `##` and assisted transfer via `*2`, with the call landing in a dialplan context written for that purpose. These are two different mechanisms because they are two different channels; we write both into the scenario.

The engine and the voice are chosen explicitly, not implicitly

Four supplier positions: `elevenlabs`, `openai-realtime`, `gemini-live` and `auto`. For speech synthesis in languages other than English, the default is `eleven_flash_v2_5` — 32 languages, around 75 ms; the higher-quality version, `eleven_turbo_v2_5`, is around 250 ms. On OpenAI Realtime there are ten voices and engines up to `gpt-realtime-2.1`. The choice is a field in the agent configuration, not an assumption on our part.

The service, in detail

The data

What every system in the industry addresses

The classes of data held by dental clinics, with the legal basis for retention where the law provides one.

The patient’s clinical record: Identity, medical history, dental condition at presentation, diagnosis, treatment plan, procedures performed and progress. It is the core of the special category and, at the same time, the medical documentation that patient law requires to be signed at consent. The patient has unrestricted access to their own medical data and can obtain a copy of any part of their own dossiers, in the manner established by the ministry — a system that cannot produce that copy is an operational problem, not just a legal one.Keep: Unverified for the sectoral term. The general principle is retention for a period that does not exceed what is necessary for the purpose. The specific archiving term for medical documentation is established by acts of the Ministry of Health, which we could not open today — the consolidated official source returned 403.SourceLegea 195/2024, art. 5 alin. (1) lit. e), art. 15; Legea 263/2005, art. 11 alin. (4), art. 13 alin. (2)
Dental imaging and clinical photographs: Orthopantomograms, retroalveolar radiographs, intraoral photographs, before-and-after sequences. These are health data by content, not by label. Their use outside treatment — on the site, in social media, in a presentation — is a different purpose from the one for which they were collected, and the compatibility of a new purpose is assessed against explicit criteria, including the nature of the data and the possible consequences for the person. In practice, for publication the realistic basis remains explicit consent, given separately and retractable.Keep: How long the clinical purpose lasts for the original in the record. For the published copy, until consent is withdrawn — withdrawal does not affect the lawfulness of the earlier publication, but it stops any continuation.SourceLaw 195/2024, art. 4 (the definition of “health data”), art. 6 para. (5), art. 9 para. (2) lit. a), art. 7 para. (3)
Appointment data: Name, phone number, date and time, doctor, requested service. They look like administrative data and often they are. They become a special category the moment the service name reveals the condition — a field such as “extraction” or “endodontic treatment” next to a name is information about that person’s health. The regime changes because of the content of the field, not the system in which it is kept, and that matters when the diary is held by an external provider.Keep: Regarding the purpose of the appointment and the contractual relationship that follows. The anticipated deletion periods by category are entered in the record of processing activities.SourceLegea 195/2024, art. 6 alin. (1) lit. b), art. 9 alin. (1), art. 30 alin. (1) lit. f)
Insured status and policy number: Reception needs insured status in order to answer correctly to the cost question. The national identification number — including the identity document series and number — has its own regime: it is processed in the situations provided for any basis, but when legitimate interest is used, the controller must put in place specific safeguards — technical and organisational measures to minimise the data and for security, retention periods set according to the nature of the data, and periodic training of the persons who process them.Keep: How long is necessary for settlement and the related accounting obligations. Specific retention or review periods for the purpose of deletion are expressly required when the basis is legitimate interest.SourceLaw 195/2024, art. 53 para. (1) and (2); art. 4 (the definition of “national identification number”)
The messaging thread with the patient: Tooth photo, pain description, follow-up question after the procedure. The content is identical to that of the record, but the place is not the clinic’s: it is the infrastructure of a channel provider, often in another state. Three consequences follow from this — the provider is an authorised person and requires a contract, the storage location falls under the transfer regime, and the patient’s information about recipients and the intention to transfer must be given at the time of collection.Keep: Undefined in practice — the threads remain in the application. Exactly for this reason, the term must be decided explicitly and written into the record, not left to the application’s implicit behaviour.SourceLaw 195/2024, art. 28 para. (3), art. 13 para. (1) lit. e) and f), art. 44 para. (2), art. 30 para. (1) lit. f)
The minor patient’s data: Two different thresholds, for two different things, and both apply in a clinic treating children. For information society services — an online booking, for example — processing based on consent is lawful if the minor is at least 14 years old; under 14, consent is given or authorised by the legal representative. For medical information, the patient law provides for disclosure to legal representatives in the case of persons under 18, while informing the patient to an extent appropriate to their discernment.Keep: As with the clinical record. The fact that the person becomes an adult does not change the term, but it does change who exercises the rights.SourceLaw 195/2024, art. 8 para. (1) and (2); Law 263/2005, art. 11 para. (6), art. 12 para. (4) lit. d)

Limbajul

The words people there use

An agent that says “programming” where the industry says otherwise is immediately heard as foreign. That is why vocabulary goes into configuration, not into the glossary at the end.

Health service provider: The legal term in the patient law for medical-sanitary and pharmaceutical institutions, regardless of the form of ownership. It is the word the law uses when addressing the clinic — not “clinic”, not “provider”.
Patient record: The medical documentation in which the anamnesis, condition, diagnosis, plan and procedures are entered. Consent to the intervention is also completed in it. When people in the clinic say “the record”, they mean this document, not the booking in the online diary.
Informed consent: The mandatory written form for interventions with increased risk — invasive or surgical. It states the purpose, expected effect, methods, potential risk, possible consequences and alternative options. It is not a data protection form and does not replace one.
Meeting: The actual unit of work for a treatment that stretches over several visits. A patient does not have “an appointment for root canal treatment”, they have the first session in a plan. A system that counts only isolated appointments loses precisely the thread.
Recall for a check-up: The planned return after treatment or for prophylaxis. It is a communication linked to care already started, not a campaign — the distinction matters, because direct marketing has its own objection regime.
OPG / orthopantomogram: The panoramic X-ray of both jaws. In clinic speech it is the “panoramic”. As data, it is medical image, so special category.
Charging unit: What exactly is counted in the price: the tooth, the canal, the jaw, the extraction, the session, the visit, the consultation or the treated case. Two clinics may have the same displayed price and very different invoices, because they count something else. Any list of services published without a unit is an incomplete list.
Insured / uninsured: The status that decides whether a service is covered from compulsory insurance funds or paid in full. It is not a property of the service, it is a combination of service and person — which is why the question comes back over the phone no matter how detailed the price list is.

Where it breaks down

What goes wrong when dental clinics digitalise in a hurry

The messaging channel becomes a medical file without anyone deciding so

No one decides in a meeting that intraoral photographs will be kept in a chat app. It happens because it is the shortest route between patient and doctor. The result is a second record, held by a provider with whom there is no data processing agreement, in a place that may be outside the European Economic Area, with no deletion period and no log of who read what. When an access request or a breach comes, the practice cannot even say what it contains.

Digitising the appointment diary without addressing the question of cost

Online bookings are moved and a drop in calls is expected. The calls remain, because their reason was not the booking, but the question of whether the service is covered by insurance for the person calling. As long as the published information does not link the service to insured status and the billing unit, every visitor with that question will still ask it by phone. The new system takes over the easy part of the work and leaves the hard part untouched.

One shared account at reception

Three people log in with the same password because it is simpler. From that moment on, there is no attribution: it cannot be said who opened a patient’s record and when. That hits two obligations at once — appropriate technical and organisational measures for the risk, and documenting breaches so that the authority can verify what happened. It is not a problem that appears at audit; it is one that appears when someone complains of a disclosure and the practice cannot prove anything, in any sense.

Consent ticked together with the terms and conditions

A single box for “I agree to the processing of data and to the terms” seems economical. The law requires that, in a written declaration which also concerns other matters, the request for consent be presented in a form that clearly distinguishes it from the other matters. And consent is not freely given when the provision of the service is conditional on processing that is not necessary for that service. The single box does not produce weak consent — it produces no consent at all, and with it falls the legal basis on which the publication of photographs and marketing messages relied.

Back-ups and photographs on the personal device

The X-ray sent to the doctor’s phone stays there, synchronises to a personal cloud account and survives any deletion made in the practice software. The storage limitation principle and the security obligation do not stop at official systems — they apply to the data, wherever it ends up. A deletion plan that covers only the database describes a reality that does not exist.

Questions

What someone in dental clinics asks before buying software

Can an automated system answer the patient what they have and what treatment they need?

No, and not out of commercial caution, but because it lacks the legal basis. The exception that allows the processing of health data for diagnosis and treatment requires that the processing be carried out by, or under the responsibility of, a professional subject to a duty of professional secrecy. An appointment system is not in that regime. It can say what services exist, when there is availability, where the practice is and what documents the patient should bring. It cannot establish or suggest a diagnosis.

Do I need a data protection officer for a practice with two doctors?

The obligation arises when the main activities consist of large-scale processing of special categories of data. The European benchmark says explicitly that the processing of patients’ data by a single doctor or by another health professional should not be considered large-scale. A small practice does not automatically fall under the obligation. A network of clinics with high volume is assessed separately, and there the answer may change. What remains mandatory regardless of size is the record of processing activities, because the exemption for fewer than 250 employees does not apply to special categories.

Do I need a data protection impact assessment before I introduce a new system?

The assessment is required in particular for large-scale processing of special categories, for systematic and comprehensive evaluation based on automated processing that produces significant effects, and for systematic large-scale monitoring of a publicly accessible area. The same benchmark for “large-scale” applies here too. But the assessment remains required whenever the type of processing is likely to generate a high risk, and the Centre approves the list of types of operations that require it — the list is the benchmark that decides, not the software supplier’s impression.

Where do the data end up if I use an appointment service from another country?

Transfers to states in the European Economic Area do not need special authorisations. Outside it, either a decision by the Centre on the adequacy of the level of protection is needed, or adequate safeguards — standard data protection clauses approved by the Centre or adopted by the European Commission, binding corporate rules, a code of conduct or a certification mechanism with an enforceable commitment. The practical question for any provider is a single one, and it is asked in writing: in which state are the data stored, and on what safeguard does the transfer rely.

The patient requests deletion of the data. Do I have to delete the record?

The right to erasure does not apply to the extent that processing is necessary for compliance with a legal obligation which requires processing, for reasons of public interest in the area of public health, or for the establishment, exercise or defence of a legal claim in proceedings. Medical records typically fall into the first category. In contrast, what can almost always be deleted is what was added on top: marketing consent, the published photograph, the message thread kept without a retention period. The correct response to such a request is a separation, not a blanket refusal.

Do I need consent to send an appointment reminder by SMS?

A reminder of an appointment already made is linked to the performance of what the patient requested and relies on the contractual basis, not on consent. An offer, a promotion or a recall turned into a campaign is direct marketing, and there the person has the right to object at any time, and if they object, the data are no longer processed for that purpose. The right to object must be brought to attention explicitly, clearly and separately from any other information, at the latest at the first communication.

Can I publish before-and-after photos with the patient’s verbal agreement?

For special categories, the consent exemption requires explicit consent, for specific purposes. When given in the context of a written statement that also refers to other aspects, the request must be presented in a form that clearly distinguishes it from the rest, intelligible and easily accessible. And consent is not freely given if the provision of the service is conditional on processing that is not necessary for the service. The practical translation: publication needs its own document, separate from informed consent for treatment, and the treatment cannot depend on it.

How long do I have if patient data leak?

Notification to the Centre is made without undue delay and, where possible, no later than 72 hours from the moment the controller became aware, except where the breach is unlikely to generate a risk. Beyond 72 hours, the notification must be accompanied by a reasoned explanation for the delay. If the risk to individuals is high, the patient is informed as well, without undue delay. And the controller keeps documentation of all cases so that the authority can check. Which means that a system without an access log makes it impossible even to describe the breach.

What real risk is there if I do nothing this year?

The law enters into force on 23 August 2026, 24 months after publication. Fines go up to 1,000,000 lei or 1% of turnover for the controller’s obligations, and up to 2,000,000 lei or 2% for the principles of processing, data subject rights and transfers, taking the higher value into account. There is, however, an explicit phasing-in: from the first year 10% of the amount of the fine set applies, from the second 40%, from the third 100%. So the exposure increases, and this year is the cheapest year to make a mistake.

What we cannot claimWe do not have a measured result of our own for dentistry to place on this page, and we do not replace it with a borrowed figure. We are not a personal data protection officer service provider and we do not issue legal opinions — what is written here are rules cited with article, not advice for a specific case. We could not verify the retention period for medical documentation established by acts of the Ministry of Health: the consolidated official source returned 403 on the day of verification, and a period that I cannot show remains unverified. We do not have a code of conduct approved by the National Centre for Personal Data Protection and nor a certification within the meaning of the law. We do not make certified medical software as a device and we do not handle the clinical compliance of the medical act. We name no clinic and publish no information about anyone’s patients.

The service, in detail What we actually built All scenarios

The service, appliedWe have not yet delivered exactly this combination. What you read above is the mechanism of our service, verifiable on its page, set alongside the rules that govern clinici stomatologice — each with the article it comes from. What we have actually built sits on the service page and in the portfolio.

Sources 8 sources · verified on 2026-09-07

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