Short answer: TGV and EFVP are two different gates
TGV, short for the French trousse globale de vérification, is the product-level certification used in Quebec for the supplier and the specific technology being evaluated. EFVP is the French acronym for a privacy impact assessment. It is completed by the acquiring health organization for the real project, data flows and operating context.
A TGV does not replace the clinic’s EFVP.
Quebec’s current AI-transcription program presents both as required elements. It also states that an EFVP completed for Santé Québec is valid only for Santé Québec. A clinic, GMF or other acquiring organization must assess its own use.
What each review is designed to answer
PRODUCT GATE
TGV certification
- Completed by: the supplier for its product.
- Focus: the certified product, version, functions and applicable criteria.
- Includes: security, access controls, privacy, auditability, technology, interoperability and AI-specific requirements.
- Does not establish: that the product fits a particular clinic or that the clinic’s own implementation is authorized.
ORGANIZATION GATE
EFVP
- Completed by: the acquiring health organization.
- Focus: the actual purpose, workflow, people, information, systems and suppliers involved.
- Includes: necessity, consent, data flows, access, hosting, subprocessors, retention, deletion, risks and safeguards.
- Does not establish: product quality, clinical accuracy or operational fit by itself.
Who is responsible for what?
- The supplier must identify the exact product and version, support the TGV process, disclose the data path and provide evidence for the proposed contract.
- The clinic or acquiring organization must define the intended use, complete the applicable EFVP, verify consent and notice, assign access and incident responsibilities, and approve the pilot and production decision.
- The physician or other professional remains responsible for professional obligations, the clinical record and the final content. The current Quebec program and CMQ guidance both require human validation of generated documentation.
How to read the current Quebec table
The official program page was updated July 9, 2026. At that date, its main table grouped products as follows. This is a dated snapshot, not a substitute for checking the live source before a decision.
Being listed in a separate program, including the Canada Health Infoway program, does not by itself establish TGV certification. The table must be read by product, provider, status, date and footnote.
What an EFVP should make visible
Article 106 of Quebec’s health information law requires an EFVP for the acquisition, development or redesign of an information system or electronic service involving health information held by the organization. The assessment should be proportionate to the sensitivity, purpose, quantity, distribution and medium of the information.
Article 106 also contains a certification-related provision for defined circumstances. For the current AI-scribe program, the operational instruction remains explicit: the Santé Québec EFVP is valid only for Santé Québec, and other acquiring health organizations must complete the EFVP applicable to their own context and proposed product.
- The purpose and why the information is necessary.
- Every collection, recording, transfer, model provider, subprocessor and storage location.
- Who can access the information and how access is changed or removed.
- Consent, patient notice, withdrawal and an alternative when the tool is declined.
- Audio, transcript, prompt and generated-note retention and deletion.
- Secondary use, model training, incident response, audit evidence and contract exit.
- Risks, safeguards, accountable owners and unresolved conditions before launch.
This page explains the current operational framework and is not legal advice. The organization should involve its privacy lead and obtain qualified advice when required.
Consent and clinical responsibility for physicians
The CMQ tells physicians to obtain explicit patient consent before using an AI scribe. A waiting-room sign alone is not sufficient. Before first use, the physician should explain the capture, purpose, expected benefits, risks and limitations, data use, possible transfers and relevant server location. Later visits may use a reminder if the patient has a real opportunity to refuse or withdraw.
The physician must review, correct and sign the final note. The CMQ also recommends identifying the software in the record. Other professional orders may issue guidance for their members, so clinics should map the rule to each role in the pilot.
A practical clinic decision path
- Name the workflow: visit types, users, languages, note destination and problem being solved.
- Match the exact product: verify the provider, version, function and current official status on the decision date.
- Map the data: audio, transcript, prompts, generated note, EMR transfer, logs, models, subprocessors, hosting, retention and deletion.
- Complete the clinic’s EFVP and consent design: assign owners and document conditions that must be met before use.
- Pilot with controls: use test cases, human review, incident and downtime routes, measurable stop criteria and a production approval gate.
Common questions
Does TGV mean a clinic can start using the product immediately?
No. TGV addresses the product-level certification gate. The acquiring organization still needs its applicable EFVP and must address professional, consent, workflow, contract and implementation requirements.
Does a Santé Québec EFVP cover a private clinic or GMF?
The current Quebec program page says no. The Santé Québec EFVP is valid only for Santé Québec. Another organization must assess its own context and proposed use.
Does “Santé Québec EFVP: no” mean no clinic can use the product?
No. It means the public table does not record a Santé Québec EFVP for that product at that date. It does not remove the acquiring organization’s responsibility to complete and approve its own assessment.
Is program participation the same as certification?
No. A pilot, funded program, vendor statement and TGV certification are different statuses.
Continue the decision
Compare reviewed AI-scribe profiles and dated Quebec statuses, then use the Quebec clinic AI-scribe implementation guide to plan workflow, testing and adoption.
Evidence reviewed: August 26, 2026. Always verify the current official table and the exact contracted version before a decision.
