Can You Use AI Note-Takers in the Workplace?

Understanding the Risks and Compliance Considerations

Artificial Intelligence (AI) is transforming the workplace, streamlining operations, and improving efficiency. One of the growing trends is the use of AI-powered note-taking tools, such as Otter.ai, Fireflies, and Microsoft Copilot, which automatically transcribe and summarise meetings. While these tools can be useful, they introduce significant data protection and compliance risks, particularly under the UK GDPR (General Data Protection Regulation).

At Data Protection People, we have taken a firm stance against using AI note-takers in our Data Protection Made Easy podcast sessions, and in this article, we explore why organisations need to carefully assess their use of AI transcription tools before implementing them.

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How Do AI Note-Takers Work?

AI note-taking tools record, transcribe, and summarise spoken conversations in real-time, often using machine learning and natural language processing (NLP) to generate accurate transcripts. Some tools go further by analysing speech patterns, identifying key topics, and even suggesting action points from a discussion.

While this technology is valuable for capturing meeting minutes, it raises serious data protection concerns, particularly when sensitive or personal information is being processed.

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The Legal and Compliance Risks of AI Note-Takers

1. Lawful Basis for Processing Under UK GDPR

Under UK GDPR, organisations must have a lawful basis for processing personal data. When using AI note-takers, the tool may collect and process:

• Employee and client names
• Sensitive business discussions
• Personally identifiable information (PII)
• Potentially confidential or regulated data

For any processing of personal data to be compliant, businesses must determine whether their use of AI transcription tools falls under legitimate interest, contractual necessity, legal obligation, or consent. In most cases, explicit consent is required before recording or transcribing a meeting.

2. Lack of Transparency and Informed Consent

UK GDPR places strong emphasis on transparency—all meeting participants must be fully informed that an AI note-taker is being used, what data it collects, where it is stored, and how it will be processed. Many AI note-taking tools automatically capture meeting content without explicit permission, which could be a breach of data protection laws.

Organisations must ensure that all individuals involved:

• Are clearly informed that an AI tool is being used.
• Have the option to opt-out before the tool begins recording or transcribing.
• Understand where their data is being stored and how it may be used.

Without clear communication, the use of AI note-takers could lead to complaints, legal challenges, or even regulatory fines.

3. Data Storage and Security Risks

AI note-taking tools often store recordings and transcripts on cloud servers, sometimes in jurisdictions outside the UK or European Economic Area (EEA). If personal data is being transferred internationally, organisations must ensure they comply with UK GDPR international data transfer rules.

Key concerns include:

• Where is the data stored? Many AI services operate on US-based servers, which may not offer the same level of data protection as UK or EU regulations.
• Who has access? Some AI providers retain transcripts for machine learning purposes, which may expose confidential conversations to external parties.
• Is the data encrypted? Organisations should check if AI note-takers provide end-to-end encryption to protect sensitive information from breaches.

4. Accuracy and Bias in AI Transcriptions

AI-generated transcriptions are not always 100% accurate. If used for official record-keeping, misinterpretations could lead to miscommunication, errors, or even legal disputes. AI can also introduce bias, misrepresenting statements based on speech patterns, accents, or contextual misunderstandings.

Organisations must ensure that:

• AI-generated transcripts are reviewed and corrected before being used for official records.
• Employees do not rely solely on AI for meeting minutes or critical documentation.

5. Employee and Client Privacy Concerns

The use of AI note-takers raises ethical and privacy concerns, particularly if employees or clients feel they are being monitored without proper justification. Covertly recording meetings without explicit permission can damage trust and expose businesses to reputational risks.

To avoid this, businesses must:

• Justify the need for AI transcription tools.
• Ensure employees and clients feel comfortable with how data is processed.
• Allow participants to opt-out if they prefer not to be recorded.

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Why Data Protection People Does Not Allow AI Note-Takers

At Data Protection People, we have chosen to prohibit AI note-takers from our Data Protection Made Easy podcast discussions due to the risks outlined above. Our concerns are particularly focused on:

• The capture of participant names and faces without consent.
• Uncertainty around how data is stored and used by AI providers.
• The risk of unauthorised access or future use of our conversations for AI training models.

While AI tools offer convenience, they must be used responsibly and in full compliance with data protection laws.

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Best Practices for Organisations Considering AI Note-Takers

If your organisation is considering using AI transcription tools, here are some best practices to follow:

1. Conduct a Data Protection Impact Assessment (DPIA): Assess the risks and benefits of using AI note-takers in your organisation.
2. Obtain explicit consent: Inform all meeting participants before recording or transcribing.
3. Check where data is stored: Ensure AI providers comply with UK GDPR data storage and transfer rules.
4. Limit access and retention: Only store transcripts as long as necessary, and prevent unauthorised access.
5. Use alternative, GDPR-compliant tools: Consider using on-premise solutions or tools with strong encryption and security measures.

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Final Thoughts: Should Your Business Use AI Note-Takers?

AI note-taking tools can be a powerful productivity tool, but organisations must balance convenience with legal and ethical responsibilities. Before implementing AI transcription in the workplace, businesses should carefully assess compliance risks, ensure transparency, and take proactive measures to protect personal data.

For expert guidance on data protection, AI governance, and compliance strategies, get in touch with Data Protection People today.

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Need Help Navigating AI and Data Protection?

If you have concerns about AI tools, GDPR compliance, or data security, our expert consultants are here to help. Contact us today or tune into the Data Protection Made Easy podcast for insights from leading industry professionals.

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By following best practices and ensuring compliance with UK GDPR, organisations can make informed decisions about whether AI note-takers are suitable for their business.