Are AI Transcription Tools GDPR Compliant?

This depends entirely on the tool and how you use it, rather than being something you can assume either way. Using an AI transcription tool in a meeting counts as processing personal data, since it captures voices, names and often sensitive discussion content, so UK GDPR applies from the moment recording starts. Your business will usually be the data controller, with the transcription provider acting as a processor, which means you need a written data processing agreement in place covering what the provider can and cannot do with that data, including whether it is used to train their own AI models.

You also need a valid lawful basis for the recording itself, and everyone in the meeting should be told, before it starts, that transcription is taking place and why. Relying on consent can be difficult in an employment context, since the ICO notes that consent given by an employee to their employer is rarely considered freely given, so legitimate interests is often the more appropriate basis provided you can justify the necessity and balance it fairly against attendees' expectations. It is also worth checking where the transcript data is stored and processed, since many popular tools transfer data outside the UK or EEA, which brings international transfer safeguards into play.

Given how many AI applications the ICO considers likely to trigger high-risk processing, it is sensible to carry out a Data Protection Impact Assessment before rolling transcription tools out widely, and to build in a habit of reviewing transcripts for accuracy before they are relied upon or shared further.

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