Unadhi Guides

AI note-takers in your meetings: a fill-in set-up sheet and meeting notice for small EU businesses (GDPR and EU AI Act)

Updated 20 Oct 2026 · Disclosure: the EURO AI Register mentioned below is an Unadhi product with a free edition. This guide is for information only, not legal advice.

What you get: a finished AI note-taker set-up sheet: 17 decisions to fill in once for each meeting assistant or transcription bot you use, each with the GDPR or EU AI Act article it supports. Plus a paste-ready meeting notice (calendar line, spoken line, privacy-notice paragraph), a never-record list, a meeting-type sheet, a 30-second check before each call and a short list of what to do this week. Built from the GDPR, the consolidated AI Act on the Commission's AI Act Service Desk, the Commission's guidelines on prohibited AI practices and the Spanish data protection authority's note on AI voice transcription.

The short answer

An AI note-taker records or listens to a meeting and turns it into a transcript or summary. Voices, names, what people said and the call metadata are personal data, so the GDPR applies in full: a legal basis (Article 6), a notice before it starts (Article 13), processor terms with the supplier (Article 28), and keeping the material no longer than needed (Article 5(1)(e)). A DPIA is likely to be expected where you record staff regularly, record job interviews, or the meeting touches health or other special category data (Article 35).

The EU AI Act does not ban transcription or summaries. It adds one hard line that already applies: since 2 February 2025 it is prohibited to use AI to infer the emotions of people in the workplace, including job candidates, from biometric data such as voice or facial expressions, except for medical or safety reasons (Article 5(1)(f), read with the definition in Article 3(39)). The Commission's guidelines on prohibited practices give "AI systems monitoring the emotional tone in hybrid work teams by identifying and inferring emotions from voice and imagery of hybrid video calls" as a prohibited example, and say inferring emotions from written text alone is outside the ban. Fines for prohibited practices go up to EUR 35 million or 7% of worldwide turnover; for SMEs, the lower of the two applies (Article 99(3) and (6), see our fines guide).

AI note-taker set-up sheet (fill once per tool)

#DecisionWhat to write downWhy (source)
1Tool and ownerName of the note-taker, where it runs (built into your video-call app, a bot that joins the call, a phone app), who in the business decides when it is switched on, and whether it joins meetings automatically. Set automatic joining to off unless you have a reason.Accountability: GDPR Art. 5(2) and 24
2Meetings it may join, and never joinsWrite two short lists. A typical 'never' list: disciplinary, grievance and performance talks, health or sick-leave conversations, legal advice, works council or trade union matters, and client meetings where the client has not agreed.Data minimisation Art. 5(1)(c); special category data Art. 9
3What it capturesChoose the least you need: summary only, transcript, audio recording, or video. If a summary is enough, do not keep audio or video.Data minimisation Art. 5(1)(c); data protection by default Art. 25(2)
4Legal basis per meeting typeFor example: internal team meetings = legitimate interest (write down the short balancing test); calls with clients or suppliers = legitimate interest or consent; job interviews = think twice, because candidates and staff may not feel free to say no. The Spanish authority (AEPD) notes consent may be impaired in an employer-employee relationship. Check the official source and your national employment rules.GDPR Art. 6(1); Art. 7 (consent); Art. 88 (national employment rules)
5Notice before the meetingPaste the notice below into the calendar invite and say the one-line version at the start. Link to a fuller privacy notice.Information duty Art. 13
6How someone says noName the person who switches it off on request, and make it easy: one message before the call or one sentence at the start, no questions asked.Right to object Art. 21 (where you rely on legitimate interest)
7Emotion, mood, tone or 'engagement' featuresSwitch off any feature that reads emotions or intentions from voice, face or video for staff, contractors or job candidates. This is a prohibition, in force since 2 February 2025, not a setting preference. Text-only sentiment on a transcript is outside this ban but is still personal data; we suggest off.AI Act Art. 5(1)(f) and Art. 3(39); Commission guidelines on prohibited practices; dates Art. 113(a); fines Art. 99(3)
8Speaker scores used to judge staffTalk-time, interruption or 'performance' scores used to evaluate staff can turn a note-taker into a workplace monitoring tool. If you plan to use them for decisions about people, run the high-risk check first (duties apply from 2 December 2027). In Germany and some other countries a works council has a say before such tools are introduced.AI Act Annex III point 4(b); Art. 113(c)(i); for Germany § 87(1) no. 6 BetrVG
9Supplier termsSigned GDPR processor terms, the list of sub-processors, where recordings and transcripts are stored, and the legal basis for any transfer outside the EEA (for example the EU-US Data Privacy Framework adequacy decision for participating US companies, or standard contractual clauses). Ask the supplier to name it in writing.Processor contract Art. 28(3); transfers Art. 44-46; Implementing Decision (EU) 2023/1795
10Training on your meetingsIs the supplier allowed to use your recordings or transcripts to train or improve its models, and can people at the supplier listen to them? Turn this off in settings or get a written 'no'. The AEPD notes that a supplier who retrains on your data acts as a separate controller for that, with its own legal basis. This is a GDPR point, not an AI Act rule.GDPR Art. 5(1)(b), 28; AEPD blog, 14 Jan 2026
11RetentionWrite a number for each thing kept: audio/video [__] days, transcript [__] days, checked summary [kept with the project file]. Set auto-delete in the tool if it has one. The numbers are your choice; the law asks for no longer than necessary.Storage limitation Art. 5(1)(e)
12Who can see and shareLimit access to the organiser and named people. Turn off automatic sharing of full transcripts to every invitee, especially external ones; send a checked summary instead.Security Art. 32
13Human checkSomeone who was in the meeting reads the AI summary before it is sent or relied on. AI summaries can attribute words to the wrong person or miss a 'no'.Accuracy Art. 5(1)(d)
14Access and erasure requestsTranscripts and recordings that relate to a person are their personal data. Know how to search, export and delete one person's data in the tool before the first request arrives.Right of access Art. 15(3); erasure Art. 17
15Records and DPIA screeningAdd the tool to your record of processing activities and do a DPIA screening. The under-250-staff exemption from records does not apply to processing that is not occasional, which regular meeting recording usually is. Check your national authority's DPIA list.Art. 30(1) and (5); Art. 35(1), (4)
16Staff know how to use itShort briefing for anyone who switches it on: the 'never' list, the notice, the emotion-feature rule, how to delete. Keep a record of who was briefed.AI Act Art. 4 (AI literacy, as amended)
17Local recording and works council rulesSome countries treat recording a private conversation without authorisation as a criminal offence (in Germany § 201 StGB covers the non-publicly spoken word), and some give employee representatives a say on monitoring tools. Check the official source for each country where participants sit.National law, for example § 201 StGB and § 87(1) no. 6 BetrVG (Germany)

Keep the filled sheet with the tool's entry in your AI register, together with the supplier's written answers. If the supplier refuses a point (for example, will not stop training on your data), record the refusal and decide which meetings, if any, the tool may still join.

Never-record list (starting point)

Paste-ready meeting notice

Calendar invite line

This meeting will use [tool name], an AI note-taker, to [record audio and] produce a [transcript and] summary for [purpose, e.g. action points for the project file]. [Business name] is responsible for this. The [recording/transcript] is deleted after [30] days; the checked summary is kept [with the project file]. If you would prefer not to be recorded or transcribed, tell [name] before or at the start and we will switch it off. More information: [link to privacy notice].

Spoken line at the start

"Before we start: [tool name] is taking notes for us [and recording the audio]. If anyone would rather it didn't, say so now or message me, and I'll switch it off."

Saying this line is about transparency and giving people an easy way to object. It does not by itself make consent your legal basis; record the basis you actually rely on in row 4.

Privacy-notice paragraph

AI meeting notes. When we use an AI note-taker in a meeting, [business name, address, contact email] is the controller. We use it to [produce accurate notes and action points]. Our legal basis is [our legitimate interest in keeping accurate records of meetings / your consent / performing our contract with you]. The tool is provided by [supplier], which acts as our processor[, and may store data in [country] under [transfer basis]]. We keep recordings and transcripts for [__] days and checked summaries for [__]. You can ask for access to, correction or deletion of your data, object to this processing, or ask us not to use the tool in a meeting, by writing to [contact]. You can also complain to your data protection authority.

These are the main Article 13 items (who, why, legal basis, recipients, transfers, retention, rights). Check the official source for the full list and adapt the wording to your situation.

Meeting-type sheet (one row per kind of meeting)

Meeting typeNote-taker allowed?CapturesLegal basisWho is told, howRetentionEmotion/sentiment featuresReviewed by
[weekly team call][yes][transcript + summary, no audio][legitimate interest, test written 20/10/2026][calendar line + spoken line][transcript 30 days][off][team lead]
[client project call][only if client agrees in writing][summary only][consent of client contacts][email before first call][summary with project file][off][account manager]
[job interview][no][n/a][n/a][n/a][n/a][n/a][owner]

The three rows above are made-up examples to show how to fill the sheet, not legal conclusions for your business.

30-second check before each call

Do this week

This sheet is a starting point, not a legal opinion or proof of compliance. AI Act references were checked on 20 October 2026 against the consolidated text on the Commission's AI Act Service Desk (including the Digital Omnibus amendments: Articles 3, 4, 5, 99, 113 and Annex III) and the Commission Guidelines on prohibited AI practices (C(2025) 5052 final). GDPR references are to Regulation (EU) 2016/679 on EUR-Lex; the EUR-Lex page did not load from our checker on 20 October, so check the official source for exact wording. Retention periods and the suggested wording are our suggestions, not legal requirements. National laws on recording conversations, employee monitoring and works councils differ by country and are only given as examples; check the official source and ask a lawyer before you rely on this. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

Many clients now have a note-taker in every call, including calls with you about payroll, staff or health-related absences. At the next review, ask which meeting tools record or transcribe, hand over this set-up sheet with the client AI inventory workshop, and agree for your own calls with them which ones the note-taker may join. Stay inside your professional rules and pass legal drafting to a lawyer.

Keep the sheet with your AI register

The EURO AI Register free edition runs in your browser with no account and no upload. It covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. List each note-taker once, pick your role (usually deployer), and store the filled set-up sheet and the supplier's terms as evidence records against it.

When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is legal advice or proof of compliance.

Partner programme opening soon

Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

Free start: list your AI tools in the EURO AI Register free edition, then fill one set-up sheet per note-taker. Related: Article 5 prohibited practices list · Annex III high-risk check · record-keeping and logs · AI Act deadline sheet.

Sources

← All guides

Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.