AI Usage Policy

Effective Date: February 2026

1. Overview of AI Features

The Lumina platform includes optional AI-assisted features designed to improve efficiency in dental practice operations.

Current AI features may include:

• Clinical note generation assistance
• Appointment scheduling suggestions
• Automated communication drafts
• Data analysis and reporting assistance
• Form completion assistance

AI features are optional and must be explicitly enabled by the Customer. They can be disabled at any time.

AI features are available subject to the usage limits of the Customer's subscription tier.

2. How AI Processes Data

• When a user initiates an AI feature, relevant context (such as appointment details or clinical notes) may be included in the prompt sent to the AI model
• Before processing, prompts are sanitised on a best-effort basis to remove or minimise identifiable patient information
• Prompts are stored encrypted using AES-256 encryption in our UK-based infrastructure (AWS eu-west-2, London region)
• Prompts are automatically and permanently deleted after 24 hours
• Only metadata is retained beyond 24 hours: specifically, the identity of the user who initiated the request and the timestamp. This metadata is retained for audit and compliance purposes.

3. Data Protection and AI

• All AI processing occurs within UK-based infrastructure. No Customer Data is transmitted outside the United Kingdom for AI processing.
• No identifiable patient data is used for AI model training, fine-tuning, or improvement
• AI data processing falls within the scope of the Data Processing Agreement between Lumina and the Customer
• The Customer remains the Data Controller for any Personal Data that may be included in AI prompts or outputs
• Lumina processes such data as a Data Processor, in accordance with the Customer's instructions

4. What AI Features Are Not

• AI features are NOT clinical decision support systems
• AI features are NOT medical devices under UK or EU medical device regulations
• AI-generated outputs are NOT a substitute for professional clinical judgment
• AI features do NOT diagnose conditions, recommend treatments, or provide clinical advice
• Lumina does NOT position AI features as regulated clinical software

5. Customer Responsibilities

• All AI-generated outputs must be reviewed, verified, and approved by a qualified dental professional before use
• The Customer is responsible for the accuracy and clinical appropriateness of any AI-generated content that is incorporated into patient records
• The Customer must ensure that its staff understand that AI outputs are assistive tools, not clinical recommendations
• The Customer should implement internal policies governing the review and approval of AI-generated content
• The Customer is responsible for informing patients about the use of AI-assisted tools where required by applicable law or professional guidance

6. Limitations and Disclaimers

• AI-generated content may contain inaccuracies, omissions, or inappropriate suggestions
• Lumina does not warrant the accuracy, completeness, reliability, or fitness for purpose of any AI-generated output
• Lumina accepts no liability for any clinical decision, action, or omission based on AI-generated content (whether wholly or partly)
• AI model capabilities and availability may change over time. Lumina reserves the right to modify, suspend, or discontinue AI features with reasonable notice.
• AI usage is subject to monthly limits which vary by subscription tier. Usage beyond the included allowance may require additional purchases.

7. Transparency and Audit

AI usage is logged as part of Lumina's comprehensive audit trail.

Logs record:

• The user who initiated the request
• The timestamp
• The feature used
• Metadata about the request

Actual prompt content is deleted after 24 hours and is not available in audit logs beyond that period.

Audit logs are available to the Customer's administrators for compliance and internal review purposes.

8. Compliance Position

• Lumina's AI features are designed in alignment with emerging UK guidance on AI in healthcare, including principles published by the Information Commissioner's Office (ICO) and the NHS AI Lab
• Lumina is committed to transparency, fairness, and accountability in its use of AI
• We monitor developments in UK AI regulation and will update this policy and our practices as the regulatory landscape evolves

9. Contact

For questions or concerns related to our AI features, please contact us: