What UK mortgage and protection advisers need to know before using AI meeting notes: recording rules, telling clients, health data and checking the draft.
Written by
Charlotte BrownRole
Mortgage Industry Writer
You finish a forty-minute remortgage review, the next client is waiting, and the write-up goes on the evening list. AI meeting notes promise to fix that: the call is recorded, transcribed and turned into a draft note shortly after it ends.
For a mortgage or protection adviser, the draft is the easy part. The questions that matter are whether you can record the call at all, what you have to tell the client, what happens when health comes up in a protection conversation, and whether you can stand behind a note you didn't type. This guide answers those, with the rules linked. Every rule and source below was checked against its live page on 13 November 2026.
In short:
An AI note taker does three jobs. It captures the conversation, either by recording a phone call or by sending a bot into a video meeting. Speech-to-text turns the audio into a transcript. A language model then drafts a structured note from the transcript, and some tools also suggest updates to the case, such as a changed loan amount or a new employer.
None of that is advice, and none of it is a file note yet. The file note is the version you have checked against what was said and approved. That distinction runs through every rule below, and it's the same one our guide to AI for mortgage brokers makes about suitability drafts and client emails.
We found no FCA rule that requires it. The record-keeping rules ask for a record of the advice, and the FCA's taping rules don't reach mortgage or protection advice.
| Rule | What it asks for | Does it require a recording? |
|---|---|---|
| MCOB 4.7A.25R | For an advised mortgage sale, a record of the customer information, including their needs and circumstances, and a record explaining why the advice is suitable. Kept for a minimum of three years | No. It asks for a record, not a recording |
| ICOBS 5.2.2R | For protection, specify the customer's demands and needs on the basis of information obtained from them, and give them a statement of those demands and needs before the contract is concluded | No |
| SYSC 10A | Firms must take all reasonable steps to record telephone conversations relating to certain activities in financial instruments | Only for that business. Mortgage and protection advice are outside it |
| PRIN 2A.9 | Monitor the outcomes retail customers receive. PRIN 2A.9.15G leaves it to firms to decide what Consumer Duty records to keep | No |
The taping rules are the ones people half remember. SYSC 10A applies to firms such as MiFID investment firms and fund managers, for activities in financial instruments like dealing in or managing investments. A regulated mortgage contract or a protection policy isn't a financial instrument, so the rule doesn't reach a mortgage and protection adviser's calls.
That doesn't make a recording useless. For a complaint about a mis-sold mortgage, the Financial Ombudsman Service's list of what it asks the business for includes "contact and application notes from the time of the sale" and a "call recording of the application meeting". A complaint can arrive years after the advice. Whatever you keep, keep a checked note made at the time, because that's what holds up. Our guide to writing mortgage file notes covers what a usable note contains.
Your network or compliance consultant may have its own recording policy, and that policy applies to you whatever the Handbook says. Check it before you switch a tool on.
Recording a client is processing their personal data, so UK GDPR applies from the moment you press record.
The ICO's guidance on monitoring, which covers recording calls, is direct: "You must tell these people that you are recording the call and why." It describes a recorded message as good practice and says the rest of your privacy information, such as how long you keep it, can follow by email or a link. Its guidance on the right to be informed says privacy information must be given at the time you collect the data.
Telling the client is a transparency duty. It isn't your lawful basis. For recording, legitimate interests is the basis most likely to fit. It means doing and keeping a legitimate interests assessment that weighs your reason for recording against the client's interests. UK GDPR consent is often a poor fit, because it has to be freely given and can be withdrawn at any point. Whatever you choose, write it down, and say in your privacy notice that calls and meetings may be recorded and transcribed, by whom, and for how long.
A short script covers most calls: "Before we start, I'd like to record this call so I can write up an accurate note of what we discuss. The recording is only used for your file. Is that OK?" If the client says no, take notes by hand. Making a recording a condition of getting advice is harder to justify than offering it.
Protection conversations bring up medical history, medication and smoking. That is special category data under UK GDPR Article 9, and it needs an Article 9 condition on top of your lawful basis.
The Data Protection Act 2018 has a condition for this in Schedule 1, paragraph 20, which covers processing health data that is necessary for an insurance purpose, such as advising on or arranging an insurance contract, and necessary for reasons of substantial public interest. It is only met if you have an appropriate policy document in place, as paragraph 5 requires. Some firms rely on explicit consent instead. Check which one your firm uses before a protection meeting is recorded, not after.
| Requirement | What it means for AI meeting notes |
|---|---|
| UK GDPR Article 28 | The note-taking provider processes data for you, so you need a written contract with the required terms |
| UK GDPR Article 35 | The ICO lists artificial intelligence as an example of innovative technology. Combined with another risk factor, such as health data, a DPIA is required, and the ICO considers a DPIA best practice even where it isn't |
| UK GDPR Article 5(1)(c) | Data minimisation. Keep the details the advice needs, not the whole conversation for its own sake |
| UK GDPR Article 5(1)(e) | Storage limitation. Set a period for audio and transcripts and be able to justify it |
| UK GDPR Article 22A | Since 5 February 2026, a decision is based solely on automated processing if there is no meaningful human involvement. Keep a person between the draft and the client |
The FCA isn't writing AI-specific rules either. Its published approach says: "We do not plan to introduce extra regulations for AI. Instead, we'll rely on existing frameworks". For an advice firm that means the Consumer Duty and senior manager accountability apply to how you use a note taker, the same as any other tool.
Speech-to-text mishears, and the mistakes tend to land on the things a mortgage file depends on: names, numbers, dates, lender names and anything said over someone else. A drafted note can also tidy up a conversation into something more certain than it was.
Before you save a note, check:
This is an invented example of what changes between draft and approved note.
| Drafted from the transcript | Approved after checking |
|---|---|
| Clients want a 5-year fix. Loan £280,000. Discussed protection. | 13 Nov, 10:30, video, both applicants. Loan increased from £280,000 to £292,000 after the revised valuation. Both prefer a five-year fix for payment certainty and understand early repayment charges apply for the full term of the fix. Raised income protection; Sam asked for quotes, Alex declined for now. Next: I send the recommendation by Friday. |
The approved note is longer because it records the change, the reasoning and the decision. Those are the details a short draft can lose, and the ones a reviewer will look for. Once the note is right, it feeds the suitability report, so errors carried forward from a transcript end up in the recommendation.
These questions help sort out which tools fit a regulated advice file.
| Question | Why it matters |
|---|---|
| Where does the note end up? | A note in a separate app has to be copied to the case. A note saved to the case is already on the file |
| Does it make you confirm everyone has been told before recording starts? | It builds the transparency step into the habit, and leaves a record of when you confirmed it |
| Can it record phone calls as well as video meetings? | Plenty of advice still happens by phone |
| Does it tell speakers apart? | Joint applicants need to be told apart in the note |
| How long are audio and transcripts kept, and can you delete them? | Storage limitation applies, and erasure requests have to reach the recordings too |
| Is your data used to train AI models? Where is it processed? | Both belong in your DPIA and your privacy notice |
| Is there a review step before anything is saved? | The adviser, not the tool, is accountable for the file |
| What does it cost, and is there a monthly allowance? | Minutes add up across a busy month |
Cleera drafts, flags and organises. The adviser decides what goes on the file.
You can capture a conversation two ways. Transcribe call records a phone call from your browser. Meeting bot sends Cleera Notetaker to a Zoom, Google Meet, Microsoft Teams or Webex meeting, where it joins as a visible participant under that name, records audio only, and uses the names people display in the meeting to label who said what.
Before either starts, you tick a box to confirm that the people on the call know it is being recorded, and Cleera records when you confirmed. For a phone call, Cleera shows you a sentence to read aloud before recording begins. The tick is your confirmation, not the client's, so the telling still comes from you.
When the call ends, Cleera transcribes it and drafts a structured note, marked as needing your review. It also suggests updates to the case and client record, each shown next to the value already saved and flagged where it is less certain. You approve, edit or dismiss each one. The note and the suggested changes are saved to the case only when you approve them, with who approved them and when. Cleera can also propose fact find answers from the call for you to review.
On retention, phone-call audio is deleted automatically within three days of being transcribed, and meeting-bot recordings are held for no more than 24 hours. The transcript and the note you approve stay with the case. Discarding a draft deletes its transcript and remaining audio at the same time. AI requests are made with zero data retention, and recordings are not used to train AI models.
The AI note taker page shows the whole flow, and how the mortgage CRM works covers the rest of the case file.
This guide is general information for UK advisers, not legal advice. For a decision about your own firm, speak to your compliance support or a data protection specialist.
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No FCA rule we could find requires it. MCOB 4.7A.25R asks for a record of the customer's needs and circumstances and of why the advice was suitable, kept for at least three years, but not a recording. The FCA's taping rules in SYSC 10A apply to business in financial instruments, not mortgage or protection advice. Your network or compliance consultant may set its own requirement, so check with them.
You need to tell them before you record, why you are recording and what you will do with it. That is not the same as UK GDPR consent. You also need a lawful basis for the processing, and for health information a separate Article 9 condition. Write both down before you start, and put the recording in your privacy notice.
Yes, but health information is special category data, so you need an Article 9 condition as well as a lawful basis. The Data Protection Act 2018 has an insurance condition in Schedule 1, which needs an appropriate policy document, and some firms rely on explicit consent instead. Check which one your firm uses, and record only the health details the advice needs.
No. A transcript is raw material and a drafted note is a draft. The file note is what you have checked against the conversation and approved. Check names, numbers, dates and who agreed to what before you save it, and add a dated follow-up note if you find a mistake later.
No FCA rule sets a period for mortgage call audio. UK GDPR says personal data should be kept no longer than necessary, so decide why you keep it, set a period in your retention schedule and be able to justify it. Once a checked note is on the file, the audio has usually done its job, so a short period for audio is easy to justify.
Drafting a note for you to check is not a decision about your client. Since 5 February 2026, UK GDPR treats a decision as based solely on automated processing when there is no meaningful human involvement. Advice you have reviewed and stand behind involves a person. A recommendation taken from a transcript and sent unchecked might not.
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