Industry

9 AI Governance Questions Medical Affairs Teams Should Answer in Asian Markets

AI is already part of medical affairs work, whether or not it has been formally approved. Good governance is not about slowing that down. It is about knowing what you use, where the risks sit, and who is accountable, across markets that each set their own rules.

Suhina Singh
Suhina Singh
Founder & CEO, Jonda Health
October 18, 2026
·
11 min read
The guide at a glance

Three steps, nine questions. Step 1 gives you the picture, step 2 sorts uses by risk, and step 3 puts the right controls around each one.

The three steps at a glanceThree steps: step 1 map, questions 1 and 2; step 2 assess, questions 3 to 5; step 3 control, questions 6 to 9. STEP 1 · QUESTIONS 1 AND 2 Map What AI we use Which rules apply STEP 2 · QUESTIONS 3 TO 5 Assess Regulatory status Data flows Risk tier STEP 3 · QUESTIONS 6 TO 9 Control Accountability Oversight and transparency Monitoring and vendors
 
How to use this guide
  1. Work through it with a small group: a medical affairs lead, and colleagues from legal or compliance, privacy, pharmacovigilance and IT.
  2. Answer each question for your function as a whole first, then for each significant AI use.
  3. Use the tips and pitfalls to test your answers, and the table at the end to see where you stand.
  4. Revisit it at least once a year, and whenever you add a new market, a new use or a new vendor.

This guide is practical, not legal advice. Rules across the region are changing quickly, so confirm current requirements with your legal and regulatory colleagues in each market.

 

Medical affairs teams across Asia are using AI in more ways than most governance frameworks yet reflect: summarising literature, drafting medical information responses, preparing for scientific exchanges, theming field insights, translating materials, and analysing real-world data. Some of this is formally approved. Some of it happens quietly, through general-purpose tools on personal accounts.

At the same time, the rules are moving. Countries across the region are updating data protection laws, publishing AI guidance for healthcare, and in some cases passing dedicated AI legislation. Global companies must also consider rules with reach beyond their borders, such as the EU AI Act. For a regional medical affairs team, the challenge is not a single regulation. It is holding a consistent standard across many markets while respecting what each one requires. These nine questions help you do that.

 

Step 1

Map

Who to involveMedical affairs leads from each market, legal or compliance, IT
What you will have at the endAn AI use inventory and a market-by-market view of the rules

 

1. What AI are we actually using, approved or not?

Governance starts with an honest inventory. List the AI tools and features in use across the function: dedicated platforms, AI built into existing systems such as CRM or literature databases, and general-purpose assistants. For each, note what it is used for, who uses it, and what information goes into it. Expect to find uses nobody formally approved; they usually reflect real needs that deserve a safe route.

TipFrame the inventory as a way to support teams, not catch them out. People share more when they know the aim is to find safe ways to keep using helpful tools.
Common pitfallCounting only formal projects and missing the AI features switched on inside tools the team already uses.
Ask your teamIf we listed every AI tool or feature used in our function last month, what would be on it, and what information went into each?

 

2. Which rules apply in each market we work in?

For each market, you will usually need to consider three layers: data protection law, AI-specific laws or guidance (including healthcare-specific guidance), and medical device rules for software that could influence clinical decisions. On top of these sit your company's global AI and data policies, industry codes of practice, and any rules with international reach. The table below gives a starting point for some of the region's main markets.

MarketExamples of instruments to check
SingaporePersonal Data Protection Act; AI in Healthcare Guidelines (AIHGle 2.0); Model AI Governance Framework; HSA guidance on software medical devices
MalaysiaPersonal Data Protection Act, as amended in 2024; national guidelines on AI governance and ethics
ThailandPersonal Data Protection Act
PhilippinesData Privacy Act of 2012
IndonesiaPersonal Data Protection Law of 2022
VietnamPersonal data protection rules, which have been significantly updated in recent years
South KoreaPersonal Information Protection Act; AI Basic Act
JapanAct on the Protection of Personal Information; AI Promotion Act
Global groupsEU AI Act and GDPR where they apply; company global AI policy; industry codes

Illustrative and not exhaustive, as of September 2026. Requirements change frequently; confirm the current position in each market.

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TipBuild one regional baseline that meets the strictest common requirements, then add market-specific conditions only where needed. It is far easier to run than nine separate rulebooks.
Common pitfallAssuming a global policy written for Europe or the US automatically covers local requirements such as data localisation or cross-border transfer conditions.
Ask your teamFor each market we operate in, do we know which data, AI and device rules apply to the uses on our inventory?

 

You are ready for step 2 when you have an inventory of AI uses and a market-by-market list of the rules that apply to them.

 

Step 2

Assess

Who to involveRegulatory affairs, privacy, pharmacovigilance, medical
What you will have at the endEach AI use sorted into a risk tier, with its data flow understood

 

3. Could any use count as a medical device or influence clinical decisions?

Most medical affairs uses of AI are not medical devices. But a tool that interprets patient data, supports diagnosis or recommends treatment for individual patients may fall under software medical device rules in some markets, even if it began as a patient support or educational tool. This question is worth asking early, because the answer changes the entire regulatory path.

TipAsk regulatory affairs to review the intended purpose statement of any patient-facing or clinically oriented tool before it is built, not after.
Common pitfallA patient support tool gradually adds features that interpret individual results, crossing into device territory without anyone noticing.
Ask your teamDoes any AI use on our inventory interpret individual patient data or influence clinical decisions, and has regulatory affairs reviewed it?

 

4. What data goes in, and where does it go?

For each use, trace the data: whether it includes personal or health information, where it is stored and processed, whether it crosses borders, how long it is kept, and whether a vendor can use it to improve or train models. Health data is treated as sensitive in most of the region, and some institutions and governments expect it to stay in country. Pseudonymising data before it reaches an AI tool, or processing it in country, can remove many obstacles.

TipDraw a simple data flow for each higher-risk use. It makes privacy reviews faster and often reveals easy fixes, such as removing identifiers before processing.
Common pitfallPasting enquiry details, case narratives or patient documents into general-purpose AI tools without knowing where the data is processed or retained.
Ask your teamFor each AI use, can we say what data goes in, where it is processed, whether it leaves the country, and whether it trains anyone's model?

 

5. What could go wrong, and for whom?

Not every AI use needs the same level of control. A tool that helps staff summarise internal documents carries different risk from one that drafts content for healthcare professionals, and both differ from anything patients interact with directly. Sorting uses into tiers lets you apply proportionate controls: light for low-risk productivity, rigorous for anything external, clinical or patient-facing.

 

Three risk tiersThree risk tiers. Tier 1, internal productivity such as summarising internal documents: standard controls. Tier 2, content for healthcare professionals such as medical information drafts: human review, sources and audit trail. Tier 3, patient-facing or clinical influence such as patient chat or tools interpreting patient data: rigorous validation, oversight, regulatory review and monitoring. TIER 1 · INTERNAL PRODUCTIVITY Summarising internal documents, meeting notes, literature scans Standard controls TIER 2 · CONTENT FOR HEALTHCARE PROFESSIONALS Medical information drafts, scientific slide support Review, sources, audit trail TIER 3 · PATIENT-FACING OR CLINICAL INFLUENCE Patient chat, tools interpreting patient data Validation, oversight,regulatory review,monitoring

Controls grow with risk. Most uses sit in tier 1; the effort belongs in tiers 2 and 3.

 

TipPublish a short list of pre-approved tier 1 uses and tools. It gives teams a safe, fast route for everyday work and reduces unapproved use.
Common pitfallApplying the same heavy approval process to every use, which pushes low-risk work onto unapproved tools and slows down what matters.
Ask your teamHave we sorted our AI uses into risk tiers, and are the controls for each tier proportionate?

 

You are ready for step 3 when each AI use has a risk tier, a known data flow, and a clear answer on regulatory status.

 

Step 3

Control

Who to involveA cross-functional AI governance group, business owners, procurement
What you will have at the endNamed owners, oversight rules, monitoring and vendor standards

 

6. Who is accountable for each use?

Every significant AI use needs a named business owner who is accountable for how it is used, and a cross-functional group that sets standards and reviews higher-risk uses. In medical affairs, that group usually brings together medical, legal or compliance, privacy, pharmacovigilance, quality and IT. Clear accountability is what turns a policy into practice.

TipKeep the governance group small and meeting regularly, with a simple intake route for new uses. A fast, predictable process earns more trust than a thorough but slow one.
Common pitfallAccountability sits with "the AI team" or the vendor, rather than with the medical affairs owner who decides how the output is used.
Ask your teamDoes every tier 2 and tier 3 AI use have a named owner, and do we have a clear route for approving new uses?

 

7. How do we handle human oversight and transparency?

Decide where a qualified person must review AI output before it is used, and what they are expected to check. Consider transparency too: whether healthcare professionals or patients should be told when content was drafted with AI or when they are interacting with an AI system, as some guidance and laws in the region expect. Oversight and transparency are also what allow you to explain decisions if they are questioned later.

TipWrite a one-page oversight standard for each tier: who reviews, what they check, and what must be recorded. Reviewers need clarity, not a general instruction to "check the output".
Common pitfallReview becomes a formality under time pressure, with reviewers approving AI drafts without checking sources.
Ask your teamFor each tier, who reviews AI output, what do they check, and when do we tell the recipient that AI was involved?

 

8. How do we know it keeps working, for all our markets?

AI performance changes as models are updated, content changes and new types of input arrive. Performance can also differ by language and population: a tool tested in English may perform differently in Thai or Bahasa Indonesia, and models trained mostly on Western data may not reflect local clinical patterns. Monitoring should cover accuracy, errors reported by users, and performance across the markets and languages you serve.

TipKeep a small test set of real examples from each market and language, and rerun it whenever a model, prompt or content library changes.
Common pitfallValidating once at launch in one market, then rolling out across the region without further testing.
Ask your teamHow do we monitor accuracy after launch, and have we tested performance in each language and market we serve?

 

9. What do we require of AI vendors?

Many AI uses depend on vendors, and their practices become your risk. Due diligence should cover where data is processed and stored, whether it is used for training, security certifications, how models are validated and updated, what audit trail is available, how incidents are reported, and whether the vendor can meet in-country requirements where needed. These expectations are best written into contracts, not assumed.

TipCreate a short standard AI vendor questionnaire, aligned with your risk tiers, so procurement and business owners ask the same questions every time.
Common pitfallRelying on a vendor's marketing claims about compliance without checking contract terms on data use, retention and model training.
Ask your teamDo our AI vendor contracts cover data processing location, training use, security, validation, audit trail and incident reporting?

 

Your governance is in good shape when every significant use has an owner, an oversight standard, ongoing monitoring and a vendor who meets your requirements.

 

Where do you stand?

Use this table to check your current position. Most teams are further along on some questions than others, and that is a useful place to start.

QuestionIn good shapeNeeds attention
1. AI inventoryAll uses listed, including built-in featuresOnly formal projects known
2. Rules by marketRegional baseline plus market conditionsGlobal policy assumed to cover everything
3. Device statusClinically oriented tools reviewed earlyFeatures added without regulatory review
4. Data flowsProcessing location and training use knownSensitive data in general-purpose tools
5. Risk tiersProportionate controls by tierOne heavy process for everything
6. AccountabilityNamed owners; fast approval routeNobody clearly accountable
7. OversightClear review standard per tierReview is a formality
8. MonitoringTested per market and language, rerun on changeValidated once, in one market
9. VendorsStandard questionnaire; terms in contractsVendor claims taken on trust

 

How Jonda Health can help

Governance works best when it is designed alongside the way AI is actually used, and with a clear view of the data underneath. That combination of clinical, data and technology understanding is how our team works. You do not need to have every answer before talking to us. There are two ways we can support you.

Jonda Health Services
Put practical governance in place

Through our Digital Health Strategy work, we help medical affairs teams build their AI inventory, sort uses into risk tiers, map data flows, and design oversight, monitoring and vendor standards that are proportionate and workable across markets.

JondaX
Handle clinical data safely

When AI work depends on clinical data, JondaX turns records in PDFs, scans and mixed formats across more than 10 languages into structured, standardised information through a single API, with expert review and de-identification available. It is ISO 27001 certified, designed to comply with HIPAA, GDPR and PDPA, and can process data fully in country where required.

Book a free 30-minute AI governance conversation

Bring your current AI uses, or the market you are most unsure about, and we will talk through where the gaps are and what to put in place first.

Get in touch at hello@jonda.health

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