Locums and 'Bring your own Tech'

Across the NHS and wider health sector, locums and temporary clinicians are often essential to keeping services running. They move between organisations, adapt quickly, and bring a wealth of experience. But increasingly, my customers tell me, they’re also bringing their own technology.

That might mean the familiar dictation software they use in their main practice, a personal transcription app, or even an AI-powered scribe that listens, writes, and structures their notes. While these tools help clinicians work faster, they also create a significant data protection and contractual challenge that most healthcare organisations aren’t fully addressing.

From Dictation to Digital Assistants: “Bring Your Own Tech” Goes Clinical

For years, many locums have relied on their own non-AI dictation tools, the kind installed on personal laptops or smartphones and tied to individual licences. Now, newer AI scribes and digital assistants are entering the mix, and tend to be integrated with the clinician’s main employer or personal account.

This means a locum working at Practice A might be dictating or transcribing data into systems managed by Practice B, or by an entirely separate technology provider outside the host organisation’s control.

In other words, sensitive patient information can be transferred, inadvertently, into an environment that the host organisation never authorised, never contracted, and cannot audit.

Why It Matters: Governance, Contracts and Accountability

Healthcare data governance frameworks are built around a simple assumption: that patient data stays within the systems and contractual boundaries defined by the host organisation. “Bring Your Own Tech” compromises that.

1. Data Protection Law: The host organisation becomes responsible for processing that it may not even know is happening. There’s often no lawful basis or data-sharing agreement in place.

2. Information Security: Locums’ devices and tools may not meet NHS DSPT or equivalent security standards.

3. Contractual Liability: Standard locum contracts rarely cover secondary systems or third-party AI tools, leaving gaps if data is mishandled.

4. Clinical Record Integrity: Notes created via personal tools may not integrate properly with official systems, leading to fragmentation or missing data in patient records.

5. Information Rights: If the patient asks for a copy of the record created, the host organisation may not be able to obtain it easily.

The result is shadow technology, unclear accountability, and potential reportable breaches.

AI Makes It Harder and Easier

The shift to AI-enabled transcription amplifies both the risk and the opportunity. On one hand, AI scribes and voice-to-text systems can dramatically reduce admin time but, in many cases, these AI tools are hosted on global cloud platforms that store or analyse data outside the UK. A locum might simply be “using the same tool they always use,” unaware that it’s transferring sensitive information across borders or retaining transcripts for model improvement.

What Organisations Can Do Right Now

1. Review Policies and Locum Contracts: Update data handling, information governance, and acceptable-use policies to include all third-party technology, both AI and traditional software. Make sure locum and agency contracts explicitly restrict use of unapproved systems.

2. Provide Safe, Approved Alternatives: Offer centrally managed, compliant dictation or transcription tools so clinicians have no need to rely on their own accounts.

3. Raise Awareness Across Clinical Teams: Many locums assume their own tools are harmless. Clear communication and training can help them understand the risks to patient data and organisational accountability.

   
   

A Cultural Shift, Not Just a Compliance Task

This isn’t about catching people out, it’s about recognising how fast technology habits are changing in clinical work. Tools that were once personal productivity aids are now powerful, networked systems capable of processing vast amounts of patient data.

The challenge for healthcare organisations is to create an environment where innovation and compliance coexist, where clinicians can use efficient tools safely, within proper governance frameworks.

Because as helpful as “Bring Your Own Tech” can seem on a busy clinic day, it can cause untold issues for governance and accountability.

Accessibility and Reasonable Adjustments

A final note of caution: some locums and clinicians use specific software or hardware as a reasonable adjustment for a disability or health condition, for example, assistive dictation or speech-recognition tools.

Organisations should not prohibit these automatically. Instead:

• Ask locums to declare any assistive technologies they rely on.

• Conduct a quick risk and DPIA review to understand how the tool handles data.

• Where the tool cannot be safely approved, aim to provide an equivalent, accessible alternative.

1. Asking only after a locum is booked removes the risk of discrimination or perceived bias in selection.

2. Framing the question around technical requirements rather than personal conditions keeps the focus on operational readiness, not on the person’s health status.

   
   

Perhaps something like

“Do you require any specific technology, equipment, or configuration to support with health, access, or support needs?This information helps us assess compatibility with our security and interoperability standards.”

This approach respects both data protection and equality obligations, ensuring that clinical safety and inclusivity move forward together. Do confirm the approach with your HR advisor.

Emma Kitcher, AI and Privacy Nerd