Patient Consent for Using Harmy: Notice and Acceptance
Harmy works with a photo of the patient's face, which places the use of the app under LGPD (Brazil's General Data Protection Law) and your informed consent routine. This page separates what the app does, what it asks of you and what remains the clinic's responsibility. It is not legal advice: check with your professional council and, if needed, with a lawyer.
What does Harmy do with the photo?
In short, the flow is this: the frontal photo is captured or picked from the gallery, the app calculates the face contours on the device itself and doesn't store them, and the photo is sent to a third-party AI to generate the projection. The result is saved in your account, in History, linked to the name you typed.
What you should agree on with the patient
The app's acceptance is yours. The patient's consent is a separate record, which the clinic must obtain before photographing. It is worth covering four topics in plain language.
| Topic | What to explain |
|---|---|
| Face photo | What it will be used for and who will have access |
| Third-party AI | That the photo is sent to an AI service to generate the simulation |
| Simulation | That it is an illustrative image, with no promise of results |
| Publishing | That the image will not be published without specific authorization |
Suggested step by step
- Before opening the app, explain the use of the photo and of the simulation.
- Record the consent in the patient chart or in the clinic's own form.
- Open New projection, type the patient's name and take the photo.
- At the moment of Create projection, confirm the app's acceptance.
- Share the image only with the patient themselves.
What the projection consent does not cover
Consent to generate the projection does not cover posting, using in an ad or sending to third parties. For any use beyond the consultation, ask for specific authorization and check the advertising rules in what you can advertise under CFO and CONAR rules. For the full topic of photos, read consent and LGPD for photos and how to explain the informed consent form.
Tips
- Ask for consent before picking up the phone. Photographing first and explaining later breaks trust.
- Use the fictional patient when you just want to demonstrate the app to someone who hasn't decided yet.
- Keep the record where the clinic already keeps the patient's other documents.
- Respect deletion requests. If the patient asks, remove the data according to your internal procedure and data protection rules.
Common errors
| Situation | How to fix it |
|---|---|
| Photo taken without telling the patient | Explain, ask for consent and record it |
| Image sent to third parties of the patient | Send it only to the patient themselves |
| Projection used on social media | Take it down and review the advertising rules |
Frequently asked questions
Do I need the patient's consent to use Harmy?
A photo of the face is sensitive personal data, so the ideal is to obtain and record consent before photographing. Follow your professional council's rules and LGPD (Brazil's data protection law), with legal advice if needed.
Does Harmy ask for any acceptance about AI?
Yes. Because the photo is sent to a third-party AI to generate the image, the app requires your acceptance first, with a fixed notice on the create projection screen.
Does the app's acceptance replace the patient's informed consent?
No. The app's acceptance is yours, as a user. The patient's consent is a separate document, which your clinic is responsible for obtaining and keeping.
Does consent for the projection cover publishing the image?
No. Publishing requires specific consent and compliance with advertising rules. The projection is consultation material.