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Global: Recording and Transcribing Internal Meetings – Practical Global Guidance for Employers

By - - AI Compliance, Data Protection, Employment Law, Privacy

Recording and transcribing internal meetings has become increasingly common, especially with the rise of remote work and AI-powered tools.

While technology offers efficiency and transparency, employers should take a practical, risk-aware approach to avoid pitfalls.

Globally Applicable Practical Guidance for Employers

Key Practical Steps for Employers

By following these steps, employers can harness the benefits of meeting recordings while minimising legal and operational risks:

  • Employers should always inform all meeting participants in advance if a meeting is going to be recorded or transcribed. Clear communication at the outset helps to build trust and significantly reduces the likelihood of complaints.
  • Access to recordings and transcripts should be strictly limited to authorised personnel. This approach safeguards sensitive information and helps to maintain legal privilege.
  • Where AI-generated transcripts are used, it is essential to have a human review the output for accuracy. Employers should never rely solely on automated transcripts when making employment decisions.
  • A clear and well-communicated policy should be established, setting out when and how meetings may be recorded or transcribed. This ensures that managers and staff understand what is expected of them.
  • Recordings must be stored securely, and retention periods should be proportionate to the purpose for which the recording was made. Keeping recordings for longer than necessary increases privacy risks.
  • Employers should be prepared to respond promptly to employee requests for access, correction, or deletion of personal data contained in recordings or transcripts.
  • If highly sensitive or personal matters arise during a meeting, employers should consider pausing or stopping the recording to protect the privacy of those involved.
Country-Specific Variations – What to Watch Out For

United Kingdom

Under UK GDPR, employers need a lawful basis for processing personal data and an additional lawful basis for any special category data, such as health information or trade union membership. They should also assess whether recording is necessary and proportionate, sometimes traditional methods like anonymised handwritten notes may be safer.

When recording or transcribing employment meetings, it is best practice to inform employees at the outset. This simple step reduces the risk of complaints and later issues. Employees should also be notified of the processing through a privacy notice, and reconfirming this at the start of the meeting is recommended.

There are no explicit bans on recording, but discrimination and union rights are key employment law risks to watch for. Employers should also be aware of the need to protect legal privilege and maintain confidentiality under certain situations. Employers must ensure security and accuracy, as AI-generated transcripts can mis-record content; human review is essential. Retention periods should be proportionate, as longer storage increases privacy risks.

Finally, employers should prepare for data subject access and erasure requests, since recordings or transcripts containing personal data may need to be disclosed or deleted upon request.

European Union

Under the EU GDPR, employers must have a lawful basis for recording or transcribing meetings. Consent is generally not a reliable legal basis for workplace recordings because of the imbalance of power between employer and employee. However, some Member States have national laws that specifically require consent for audio recordings, so employers must check local requirements before proceeding. Most employers rely on legitimate interests, and if special category data (e.g. health or union membership) is involved, an additional basis is needed.

Employees should receive clear privacy notices explaining the purpose, retention, access rights, and any third-party involvement. Confirming at the start of the meeting is best practice. Employers must also clarify whether providers act as processors or joint controllers. AI transcripts must be checked for accuracy, retention periods kept short, and security measures robust, especially for cloud services and cross-border transfers, which require safeguards like Standard Contractual Clauses.

The EU AI Act adds further obligations for employers using AI tools. High-risk systems, such as those used for recruitment or employment decisions, require strict compliance, consultation with employee representatives, and human oversight. AI literacy obligations start in 2025, with most high-risk requirements effective from 2026.

Employment law risks include discrimination if transcripts are inaccurate, procedural fairness issues, and breaches of works council rights. Covert recording is illegal in many countries, and even one-party recording can breach civil law. Recordings must be justified, limited, and legally compliant. Employers should also protect privileged discussions and consider the cultural impact of recording, as it can undermine trust.

United States

In the US, consent requirements for recording meetings vary by state; some states require all parties to consent, while others do not. Data privacy focuses on security, breach notification, and compliance with state-specific laws. There is no single federal regulation, so employers must check local requirements.

Employment law risks include discrimination claims and issues arising from union or collective bargaining agreements. Employers should also be cautious about recording sensitive conversations and protecting legal privilege.

China

In China, explicit and unbundled consent is required for recording internal meetings. Data privacy is governed by the Personal Information Protection Law (PIPL), with strict rules on cross-border data transfers and the need for impact assessments.

Employers must obtain separate consent for processing sensitive data and comply with Chinese Standard Contractual Clauses for international transfers. Employment law risks are generally lower, but privacy rules are strict and must be followed carefully.

Singapore

In Singapore, employers must obtain explicit consent before recording meetings, as required by the Personal Data Protection Act (PDPA). Data privacy focuses on breach notification and secure storage of recordings.

Employers should ensure consent is properly documented and that security measures are in place. Employment law risks include potential discrimination claims if transcripts are inaccurate, especially for employees with different language backgrounds or disabilities.

Hong Kong

In Hong Kong, employers must notify employees if a meeting is being recorded, particularly if the recording will be used to compile information about them. The Personal Data (Privacy) Ordinance (PDPO) requires secure storage and clear retention policies. Consent is not always necessary, but notification is essential.

Employment law risks centre on accuracy, privilege, and the potential for complaints if employees are not properly informed.

This is a high-level general update only. Legal advice should be obtained on specific circumstances.
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