Do I need to disclose AI in customer service (chat, email, voice)?
Chat and voice: yes, clearly — Article 50(1) covers direct AI interaction. Fully automated AI email replies: best practice and arguably covered when conversational; AI-drafted human-sent replies: no, a human is the interactor. When in doubt, disclose.
By channel
| Channel | Disclosure needed? |
|---|---|
| Website chatbot | Yes, always, first contact |
| Voice AI on phone lines | Yes, at call start |
| Fully automated AI email agent | Grey zone leaning yes — if it converses with a person, treat it as covered |
| AI-drafted, human-sent replies | No — the human interacted, not the AI |
| Internal AI tools staff use | No (not public interaction) |
Why "when in doubt, disclose" wins
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- •AI inventory and system classifications
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- •Recommended notice wording and placement
- •Evidence and documentation gaps
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