AI call recording and consent
Our approach to AI disclosure, call recording, consent, human alternatives, and location-specific review.
No live calls until this is reviewed
This policy sets the requirements for a service-specific call flow; it is not a ready-to-use call script. Recording and personal-data rules depend on the caller, the business, the locations involved, and the actual setup. The website demo is a fictional text conversation and does not make or record calls.
Tell callers what is happening
An opening notice should identify the business, explain that the caller is speaking with an AI assistant, state whether audio or transcripts are stored, explain the purpose, and describe a human alternative. A recording notice must match the actual recording settings.
Where consent is required, obtain it before recording or other consent-dependent processing. If consent is refused, use the reviewed non-recording or human route. Do not silently continue recording.
US calls, including two-party-consent states
US recording requirements vary by state and can involve more than one jurisdiction on the same call. Some states require all parties to consent in relevant circumstances. Have counsel assess the locations involved, the exact notice and consent sequence, and the rules for calls that cross state lines. Do not assume one-party consent applies to every caller.
UK GDPR
For UK personal data, identify and document an appropriate lawful basis and give clear privacy information. Consent is not automatically the only possible lawful basis; if relied on, it must meet the applicable standard. Review data minimisation, retention, rights handling, processor contracts, security, and international transfers for the actual service.
UAE PDPL
For UAE operations, review the federal Personal Data Protection Law, applicable exceptions, sector rules, and any relevant free-zone regime. The government describes consent requirements with exceptions and controls on cross-border sharing. A UK or US script should not be reused without local review.
Illustrative wording for counsel to adapt
“You are speaking with an AI assistant for [business]. With your permission, we would like to record this call and keep a transcript for [specific purpose]. You can ask for [human or non-recording route]. Do you agree to the recording?”
This example does not establish valid consent by itself. Counsel must decide whether it is appropriate, what information must be supplied first, how consent is recorded without premature recording, and how a refusal is handled.
Sensitive information and access
Collect only the details needed for the agreed task. Do not invite medical histories, confidential case narratives, or card details through a generic assistant. Define access roles, retention, deletion, vendor permissions, and whether model training is permitted before launch.
Medical, legal, and other regulated use cases need their own assessment. Emergency response and human escalation must be approved by the business and tested independently of routine booking.
Reference sources.
Reporters Committee: introduction to US recording laws