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A Practical GDPR Checklist for AI Phone Agents

Jul 8, 20269 min read

None of this is legal advice — talk to your counsel before launch, especially for anything customer-facing. What follows is the working checklist we point EU-based teams to when they're setting up their first AI phone agent.

Before the first call

  • Decide what the caller is told at the start of the call — most teams add a short line disclosing that they're speaking with an AI agent, and that the call may be recorded
  • Confirm where call recordings, transcripts and knowledge base documents are stored, and choose EU-based hosting if that's a requirement for your data
  • List every third-party system the agent talks to — calendar, CRM, ticketing — and make sure each one has its own data processing agreement in place

What goes into the knowledge base

Knowledge bases built from documents or a website crawl are convenient, but convenient is how personal data quietly ends up somewhere it shouldn't be. Before uploading a document, check it for names, phone numbers or case details that don't need to be there — the agent only needs enough context to do its job, not a full customer record.

Retention and access

  • Set a retention window for transcripts and recordings, and document why that window was chosen
  • Decide who inside your team can read a transcript, and keep that list as short as the job allows
  • Have a process ready for a caller who asks what data you hold on them, and how to delete it

A short pre-launch checklist

  • Call disclosure line written and added to the opening of the flow
  • Recording notice added where legally required
  • Hosting region confirmed for calls, transcripts and knowledge bases
  • Data processing agreements signed with every connected tool
  • Retention period set and documented
  • Deletion process defined for both individual requests and routine cleanup

Treat this as a starting checklist, not a finished audit — requirements vary by country, industry and what the agent is actually doing on the call, so loop in whoever handles compliance before you go live.

OA
The Our AI Calling Team

Notes from the people building the agent platform.

See it in action on your own phone

Spin up an agent, give it a task and call it. You will hear the difference in two minutes.