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Vendor due-diligence checklist
EU AI Act + GDPR · 2026

Is your AI notetaker setup AI-Act-ready?

Seven questions to ask any AI meeting assistant vendor before you sign. Tick the box only when the vendor gives you the pass answer in writing. From 2 August 2026, EU AI Act Article 50 transparency duties and deployer obligations apply alongside GDPR to the AI notetaker in your stack.

Question 1 · Hosting
Where is it hosted, by region and by provider, for both storage and processing?
Pass Names an EU region and a named provider for both storage and every processing step, or states clearly which step uses a non-EU provider.
Fail "Your data stays in the EU," with no breakdown of where audio is transcribed or summarised.
Question 2 · Subprocessors
Who are the subprocessors, and where is the full public list?
Pass A complete, dated list naming the ASR provider, the summarisation model provider, and storage, with a change-notice mechanism.
Fail Names the cloud host but calls the AI providers "trusted partners" or leaves them unnamed.
Question 3 · Training
Is my call data used to train or improve any model?
Pass A written no-training clause in the DPA covering recordings, transcripts, prompts, uploads and outputs, and every downstream model provider.
Fail A webpage reassurance, or an opt-out you have to find and toggle.
Question 4 · Model control
Can the model be pinned or self-hosted, and are you told before it changes?
Pass Version pinning, advance notice of model changes with a description of what changed, and a self-host or on-prem option for higher assurance.
Fail "We always use the latest model," with no notice and no pinning.
Question 5 · Disclosure (Article 50)
How does the bot disclose itself in the meeting?
Pass Explains the capture mode plainly (visible named bot, or botless), and gives you a workable disclosure and consent step for it.
Fail Treats "the bot records" as if disclosure to participants were someone else's problem.
Question 6 · Deletion and retention
Can you control retention, and does deletion reach derived data and backups?
Pass Configurable retention; deletion covers the recording, transcript, summary and search index; a defined backup deletion window.
Fail "You can delete recordings," with no mention of transcripts, indexes or backups.
Question 7 · DPA
Is a DPA available as standard, and does it match the product?
Pass A standard DPA whose subprocessor annex, processing regions, transfer mechanism and no-training clause match the answers to questions 1 to 6.
Fail A DPA that is vaguer than the sales conversation was, or an enterprise-only upsell.

This checklist is a buyer's guide, not legal advice, and does not determine whether any product is compliant. Compliance depends on your whole deployment and your own disclosure and retention practices. Consult a qualified lawyer and your DPO. Full guide and sources at the URL on the right.

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