PORTUGAL CONTEXT
Artificial intelligence for doctors in Portugal
Artificial intelligence for doctors in Portugal can help prepare documentation, organize medical history, and consult evidence. Its use must preserve the clinical process and professional control.
The Portuguese framework combines rights to health information, duties of confidentiality, European data protection, and digital services shared by the SNS.
🇵🇹 Portugal
Central document: clinical process.
Health information: It belongs to the person.
Custody: It corresponds to the health units.
SNS Exchange: Electronic Health Record.
What a clinical process in Portugal must preserve
The Law No. 12/2005 defines the clinical process as any record, computerized or not, containing health information of patients or family members. The information belongs to the individual; the system units act as custodians.
| Available information | The process must gather the relevant medical information about the person and their care. |
| Authorship and supervision | The information is recorded by the physician or computerized under their supervision by another professional bound by confidentiality. |
| Need for access | Professional access is limited to what is strictly necessary to provide care. |
| Confidentiality | The unit must prevent unauthorized access and protect systems, equipment, and backups. |
| Separation and Traceability | Systems must apply access levels and separate health and genetic information from other personal data. |
An AI tool can prepare text, but it does not change the ownership of the information or the duty of confidentiality. The clinical documentation guide with AI for Portugal turns these principles into an operational review.
Marco de Portugal
Health information, GDPR and NHS digital services
Portugal combines specific national rules on clinical information with the GDPR and Law No. 58/2019. SPMS services facilitate access and exchange, but each unit maintains responsibilities for its clinical process.
Law 12/2005
Define health information, ownership, custody, professional access, and clinical process requirements.
GDPR
Treat health data as a special category and require a legal basis, minimization, security, and accountability.
Law 58/2019
Enforces the GDPR in Portugal and develops national rules for the processing of personal data.
RSE
The Electronic Health Record allows authorized professionals to consult shared information within the SNS.
University and reference hospital centers in Portugal
The recent reorganization of the SNS groups hospital and primary care into Local Health Units. Among the reference centers for complexity, teaching, or research are:
ULS in Santa Maria
Lisbon. It includes the Hospital de Santa Maria, a high-complexity university center and medical training facility.
São João Local Health Unit
Porto. University hospital serving as a reference center for the north of the country.
Portuguese Institute of Oncology of Lisbon
Lisbon. Specialized institute for cancer care, research, and education.
Portuguese Institute of Oncology of Porto
Porto. Oncological reference center with clinical, scientific, and educational activities.
Non-exhaustive selection of benchmark public institutions. This is not a ranking nor does it indicate affiliation with Itaca.
Clinical Process, CSR, and Support Application
The ESR facilitates access to shared information, but it does not replace the complete process maintained by each unit. An AI application occupies a third level: it helps with a specific task.
| Element | Main function | Responsibility |
|---|---|---|
| Clinical process | Complete medical and healthcare record maintained by the health unit. | The person is the owner of the information; the unit acts as the custodian. |
| RSE | Electronic service for consulting health information shared by authorized systems. | SPMS operates the infrastructure and the units control the data they generate. |
| Support application | Tool that prepares documentation, organizes information, or assists with a clinical consultation. | It must be integrated under unit controls and professional review. |
What to review when incorporating clinical AI in Portugal
The evaluation must begin with the purpose: summarizing a conversation is not the same as recommending a diagnosis. The level of risk, the legal basis, and the technical obligations can change depending on the actual function.
In all cases, the unit must restrict access, know where the data is processed, maintain traceability, and allow the professional to correct or reject the result before incorporating it into the clinical process.
Scope: The GDPR, Portuguese legislation, professional rules, applicable European requirements, and the policies of the ULS or private entity must be reviewed.
Five questions to evaluate a tool
- Are the purpose and risk level defined?
- Does the professional retain review and final decision?
- Do accesses follow the need-to-know principle?
- Does the unit control storage, backups, and traceability?
- Does the result reach the correct clinical system?
Where AI can contribute to Portuguese clinical practice
AI is beneficial when it reduces repetitive writing and helps locate context without separating the professional's work from the clinical process and unit systems.
Documentation
Prepare draft notes, summaries, and reports for professional review.
Normalization
Facilitate shared structures between services without replacing clinical judgment.
Evidence
Synthesize medical sources for specific questions and display references.
Continuity
Organize longitudinal history to retrieve relevant information in the next contact.
AI does not solve interoperability, document quality, or data protection on its own. It is a support layer that must fit into the institution's controls and systems.
ITHACA IN PORTUGAL
Itaca prepares clinical drafts. Its unit preserves the official clinical process.
Itaca helps turn conversations, documents, and quick notes into structured clinical drafts. It also allows working with templates and longitudinal context depending on the contracted functions.
The professional reviews and approves the content. The unit retains responsibility for the clinical process, access, custody, and integration with its systems.
Official sources for further reading
- Law No. 12/2005: health information and clinical process.
- Law No. 58/2019: Enforcement of the GDPR in Portugal.
- Guidelines of the National Data Protection Commission on health.
- Electronic Health Record Manual — Professional Area.
- Security and privacy in clinical notes with AI.
Editorial and source review: Itaca team. Updated: September 11, 2026. This content is informational and does not replace legal, regulatory, or security advice. Always verify the current version and the obligations applicable to your institution.
Frequently asked questions about medical AI in Portugal
Who owns health information in Portugal?
Law No. 12/2005 establishes that information belongs to the person and that health units are custodians.
Does the EHR contain the entire clinical process?
Not necessarily. It allows querying shared information, while each unit keeps additional records in its systems.
Can AI record information without medical supervision?
Medical information must be recorded by the physician or computerized under their supervision by another authorized professional.
Does complying with the GDPR suffice to use any clinical AI?
No. The purpose, health and professional rules, safety, integration, and other applicable European requirements must also be reviewed.
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