Why this matters.
AI notetakers that join video calls, transcribe conversations and summarise meetings are now standard in many small businesses, often switched on by an individual employee without any company decision. Recording and transcribing a conversation means processing personal data, and sometimes special category data, so UK GDPR and the Data Protection Act 2018 apply: you need a lawful basis, clear transparency under Articles 13 and 14, and a proportionate approach to retention. Where the recording captures customers, candidates or staff, you may also need a data protection impact assessment under Article 35.
There is a second layer of law that many businesses overlook. Intercepting a live communication without lawful authority can be an offence under the Investigatory Powers Act 2016, and the Investigatory Powers (Interception by Businesses etc. for Monitoring and Record-keeping Purposes) Regulations 2018 set the conditions under which businesses may record their own calls. The ICO’s monitoring workers guidance expects employers to be open with staff, and regulated firms may have separate record-keeping duties, for example under FCA rules. Third-party tools also send audio to overseas processors, so you need a compliant data processing agreement and a lawful international transfer mechanism.