Disclosures
Waterway builds Tributary, a documentation tool for behavioral health clinicians. It listens to a session, drafts the clinical note, and keeps track of a client's treatment goals across the whole course of care.
If you are deciding whether to let this near your clients' records, this page is what you need: where the data goes, who handles it, and what we do not do with it.
Where clinical records live
Your electronic health record holds the clinical record. Tributary is a drafting tool: it reads treatment plan information from your record system, drafts the note, and the clinician puts the finished note into the chart. Nothing we hold is the only copy of something your practice has to keep.
The drafting material itself — transcripts in unfinished drafts, generated notes, session summaries, goal progress — is stored in Google Cloud Storage, in infrastructure Waterway operates, encrypted at rest and in transit.
Access is strictly individual. Each clinician's material is reachable only by that clinician. Not their supervisor, not the practice owner, not another clinician at the same practice, and not Waterway staff through the application. Supervision and oversight happen in your record system, where they belong. Every read and write is logged with the identity that performed it.
Thirty days after a clinician's seat is terminated, their material is destroyed, including every stored version. Nothing is exported, because the record is already in your chart system. A suspended seat is not a terminated one and loses nothing.
What happens during a session
- Session audio is sent to AssemblyAI and converted to text. The audio is not retained afterward.
- The transcript and the client's existing treatment goals are sent to a language model, which drafts the note.
- The clinician reads every section and marks it reviewed. Nothing reaches an EHR before that.
- The approved note is placed in the health record by the clinician, and the client's goal record is updated with what the session showed.
Subprocessors
| Vendor | Used for | BAA |
|---|---|---|
| AssemblyAI | Converting session audio to text, and drafting clinical notes | Signed |
| Sign-in, application data, and storage of drafting material | Signed |
This list is kept current. Practices under an active agreement are notified before a subprocessor is added.
What Waterway does not do
- We do not sell client data, and we do not use it for advertising.
- We do not use client data to train AI models. This is confirmed opted out with every vendor above.
- We do not read clinical content for our own purposes. Our audit records identify a client by code, never by name, and contain no clinical content.
- We do not write to your health record system. Tributary reads from it; a human puts the note in.
Accuracy is the clinician's
Tributary drafts. The treating clinician reviews, edits, and approves every note before it becomes part of a record. The software makes no clinical judgement and does not guarantee clinical accuracy.
Clients must be told that AI-assisted documentation is being used, and may decline it. We provide a consent form your clinicians can adapt.
Current status. Tributary is in use at a small number of practices. Our HIPAA risk analysis, policies, business associate agreement and client consent form are complete, and available on request to a practice evaluating the tool.
Questions before you evaluate it?
Write to privacy@waterway.health, or ask about the pilot.
