I'd like to understand the rules around automated transcribing calls in the UK, from a B2B perspective.

GDPR seems quite clear that if you are recording calls, video and/or audio, you must get consent. However, what about just transcribing, and not recording?

  • I can't seem to find any resources on this, so any advice on how to find more out would be great.

Many thanks

  • At its most basic level, are you saying you need permission from the caller to jot down in a notebook [transcribe] the salient points of the conversation? Please quote the "quite clear" rules. At a higher level, how can your online or email system not record these media and interactions? Jul 15, 2023 at 20:14

1 Answer 1


GDPR seems quite clear that if you are recording calls, video and/or audio, you must get consent.


The GDPR requires that your have a legal basis for processing personal data. Consent is a legal basis but there are others.

With respect to note taking, the GDPR only applies to “personal data wholly or partly by automated means and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of a filing system.”

So, if they notes are not about an individual (and many B2B phone calls will not be) or are neither automated nor filed, the GDPR does not apply. If they are captured by the GDPR, you need to have a legal basis for the notes. Again, consent is one but it is not the only one.

  • To give a specific example, "John Smith told me that Widgets Inc would like to buy 1000 tons of steel on January 31st" is not protected by GDPR, as John Smith is acting in his capacity as representative of Widgets Inc. John Smith ordering the steel for his own personal needs would probably be covered. Jul 16, 2023 at 16:24
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    @JonathanReez “John Smith” is personal information and if the note is going to be filed, GDPR does apply. “John Smith Ltd” is not personal information.
    – Dale M
    Jul 16, 2023 at 21:59

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