Can advisers use AI notetakers in client meetings?
Using AI to record and summarise client meetings.
Consent, the file note and the tool's settings.
Yes, and many firms already do, with three safeguards.
The client knows before recording starts, the adviser checks every note before filing it, and the tool’s storage fits your record-keeping rules.
The note-taking is the easy part.
The record is what you answer for.
Tell the client first
A recording of a financial review holds some of the most personal data a client has.
Tell them before the meeting that an AI tool will record and transcribe it, say what happens to the recording, and stop if they object.
Mention it in your privacy notice as well.
Health information often comes up in protection and retirement conversations.
That is special category data under UK GDPR, which raises the bar, and usually means a data protection impact assessment before you start.
A summary is not a file note
An AI summary tells you what you discussed.
A file note has to show what the client told you, what you recommended and why, and which warnings you gave.
A reviewer who was not in the room should be able to follow it.
AI summaries tend to keep the conversation and lose the reasoning.
So treat every output as a draft.
The adviser reads it, corrects it, adds what is missing, and only then files it.
Consumer Duty still applies
The FCA’s Consumer Duty applies to AI-assisted work as to any other.
If a notetaker drafts the follow-up letter, the adviser still answers for the client understanding it.
Read the draft as the client will.
Check the tool before the first meeting
- Where it processes the audio, and what legal route covers any transfer outside the UK.
- Whether it trains on recordings, and whether you can switch that off for the whole firm.
- How long it keeps recordings and transcripts, and whether that matches your own retention rules.
- Whether you can delete a recording when a client asks.
- A signed data processing agreement with the supplier.
A simple rule for the firm
The client hears about it before recording starts. The adviser signs every note before filing it. The recording lives only in a tool the firm has approved.
Our guide to client data in AI tools covers the wider checks: putting client information into ChatGPT.
To write the rule down, our AI policy template includes a clause on recording meetings.
This guide explains the questions to ask; it is not regulatory advice.
Frequently asked questions
Do I need the client's consent to use an AI notetaker?
Tell them before it starts, explain what happens to the recording, and stop if they object.
Is an AI summary a file note?
Not until the adviser has checked it.
A summary often drops the reasons and warnings a file note needs.
Where does the recording go?
Ask the supplier where it processes the audio.
Ask how long it keeps it and whether it trains on it.
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