
Proportionality-by-design: A pathway to responsible mental health apps
Designing ethical AI mental health apps
As AI-powered technologies become more deeply embedded in healthcare, mobile mental health and wellbeing applications are gaining traction as tools for supporting emotional and psychological resilience. But alongside their promise, these apps raise important ethical and legal questions, particularly in relation to the long-term collection and use of sensitive personal data.
In a external page recent publication, Dr Hui Yun Chan proposes a proportionality-by-design approach for the development of AI-integrated mobile mental health apps. This approach aims to strike a balance between user benefit and data protection by integrating proportionality principles into app design from the outset.
Current regulatory frameworks often rely on risk-based models, which may not fully address the unique challenges posed by the continuous data collection and algorithmic decision-making inherent in mental health apps. Users may remain vulnerable to harms, such as privacy intrusions, surveillance risks, and data security breaches, many of which fall outside their control or awareness.
By embedding the principle of proportionality directly into the app development process, Dr Chan argues that developers and regulators can better mitigate these risks. A proportionality-by-design approach encourages the minimisation of excessive data collection, reduces surveillance harms, and fosters more transparent, ethical, and accountable technology use.
Crucially, regulatory oversight has a role to play in incentivising and supporting this design paradigm by guiding industry practices while upholding public trust in digital mental health tools.
This research highlights the importance of rethinking governance models for emerging technologies, especially in sensitive areas like mental health. As mobile apps become an integral part of health and wellbeing strategies, proportionality-by-design offers a promising pathway toward more ethical and user-centred innovation.
Chan, H. Y. (2025). A proportionality-by-design approach for mobile mental health and wellbeing applications. Law, Innovation and Technology, 1–26. external page https://doi.org/10.1080/17579961.2025.2469343