No. It is near impossible to not breach privacy regulations doing this. Below we list six ways privacy regulation violations often occur.
- There is no documentation of consent.
- Patient date may travel internationally through Apple, Google or your Telco's servers.
- You're storing clinical photos alongside personal content.
- De-identifying photos isn't/can't be done properly.
- Clinical photos may be accessible if you lose your phone.
- There is a question over the encryption used.
For a detailed discussion, please see the "Can't I just use the default camera app to take clinical photos?" FAQ. Also see the "Is sending patient data via WhatsApp safe?" FAQ.