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Can you prove consent for AI call recording and other AI features? A GDPR Article 7 consent record sheet for small businesses

Updated 24 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 Article 7 consent record sheet: one row per AI purpose that relies on consent (for example recording and transcribing customer calls, using client photos in AI-edited marketing, AI chatbot follow-up messages), one column per consent check from Articles 7, 8 and 9, a result formula that counts failed checks, three made-up example rows, a per-person log layout and a withdrawal routine.

Short answer: if you rely on consent, Article 7(1) GDPR says you must be able to demonstrate it. That means keeping the exact wording you used, which version each person agreed to, when and how, and making withdrawal as easy as saying yes. A pre-ticked box or a line buried in your terms does not count.

Step 1: is consent the right basis for this AI use?

Step 2: the consent record sheet (one row per AI purpose)

ColumnWhat to writeSource
A. Purpose and AI tool[purpose, e.g. record and transcribe sales calls] · [AI tool] · lawful basis = consent (Art. 6(1)(a)); if a different basis fits better, note it and leave this sheetYour AI register entry; Art. 6(1)
B. Consent wording and versionExact text shown or read out, version number and date, and where it appears (call script, web form, paper form)Art. 7(1)
C. InformedY / Partial / N: the wording names your business, the purpose, what data is used, that the person can withdraw at any time, and any automated decisions or transfers outside the EU that applyArt. 7(3) third sentence; Recital 42; EDPB 05/2020 section 3.3
D. Separate from other termsY / N: the consent request stands apart from terms and conditions and other matters, in clear and plain languageArt. 7(2)
E. Active opt-inY / N: the person ticks, clicks, signs or says yes; no pre-ticked box, no silence, no "by continuing you agree"Art. 4(11); Recital 32
F. Not a condition of serviceY / N: the person gets the service even if they say no, unless the processing is really needed for that serviceArt. 7(4); Recital 43; EDPB 05/2020 section 3.1
G. One purpose per yesY / N: separate yes or no for each purpose (for example transcription and using the recording to train the tool are two questions)Recital 32; EDPB 05/2020 section 3.2
H. Withdrawal as easy as givingY / N: the same channel works to withdraw (say it on the next call, untick in the account, reply to an email), and the withdrawal route is written downArt. 7(3); EDPB 05/2020 section 5.2
I. Record per personY / N: for each person you can show who, when, how and which wording version they agreed toArt. 7(1); EDPB 05/2020 section 5.1
J. Children (online services)Y / N / Not relevant: if you offer an online service directly to children, the age threshold is 16 unless your country set a lower age (not below 13); below that age, parental consent with reasonable checksArt. 8(1) and 8(2)
K. Special category dataY / N / Not relevant: if health, biometric or other special category data is involved (clinic calls, voice ID), consent must be explicit, for example a signed or clearly stated yes to that specific useArt. 9(1) and 9(2)(a); EDPB 05/2020 section 4
L. Result=IF(COUNTIF(C2:K2,"N")>0,"Fix: "&COUNTIF(C2:K2,"N")&" check(s) failed",IF(COUNTIF(C2:K2,"Partial")>0,"Check wording","Consent record OK"))Art. 7
M. Action, owner, date[rewrite wording / add separate tick box / add withdrawal route / start per-person log / switch to another lawful basis / stop the use] · [role] · [dd/mm/yyyy]Art. 5(2) accountability

Put Y, Partial or N in columns C to K (Not relevant where it does not apply; the formula ignores it). Sort by column L so the rows to fix come first.

Step 3: the per-person log (second tab)

One row per person per purpose: person ID (customer number, not a copy of their file) · purpose (matches column A) · wording version (matches column B) · date and time · how given (ticked web form, said yes on recorded call at 00:12, signed form) · withdrawn on · data deleted or basis changed on. Keep only what you need to show consent; the EDPB says the record itself should not lead to excessive extra processing.

Three example rows (made-up businesses, for illustration only)

Withdrawal routine

Do this week

This sheet is a working aid, not a legal opinion or proof of compliance. References are to Regulation (EU) 2016/679 (Articles 4(11), 6, 7, 8, 9 and 17 and Recitals 32, 42 and 43, as published on gdpr-info.eu) and the EDPB Guidelines 05/2020 on consent under Regulation 2016/679, version 1.1. Example rows are made up for illustration and do not describe any real business or supplier. Checked on 24 October 2026. Spot an error in this guide? Write to mininglife7@gmail.com.

For accountants and tax advisers

Clients who start recording calls or posting AI-edited client photos rarely keep consent records. Hand them this sheet with the client AI inventory so the decision and wording are written down. Stay inside your professional rules and refer legal questions on.

Keep the answer next to 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 AI tool once and attach its consent wording and check row as an evidence record.

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 add this sheet. Related: legitimate interest assessment · AI meeting note-taker setup · Article 30 records · Article 28 DPA clause check

Sources

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