Retention, deletion, compartmentalisation.
Sector · Legal
Legal: intake and routing, with confidentiality held apart.
A caller to a law firm assumes confidentiality from the first sentence, and often gives the substance of a matter before anyone has decided whether the firm can act. That is what makes a voice agent delicate here: it is not the advice question — an agent must never advise — it is that the first thirty seconds can contain material covered by the firm's professional secrecy, while the conflict check has not happened yet.
What the law requires
- A person interacting with an AI system must be told so, unless it is obvious from the circumstances.
- Regulation (EU) 2024/1689, Art. 50(1)
- A lawyer is bound to professional secrecy over everything entrusted in that capacity, and a breach is a criminal offence.
- § 43a(2) BRAO and § 203 StGB (DE) · Advocatenwet, art. 11a (NL)
- Providing legal services is reserved: it is permitted only where a statute allows it.
- § 3 RDG (DE)
- A person affected by a decision taken on the basis of the output of an Annex III high-risk AI system, producing legal effects or similarly significant effects, can obtain an explanation of the role that system played.
- Regulation (EU) 2024/1689, Art. 86
- Personal data must be limited to what is necessary for the purpose it is collected for.
- Regulation (EU) 2016/679, Art. 5(1)(c)
What Audact does about it
- Confidential turns are compartmentalised: they stay out of general retention, patent-pending (UK IPO).
- In development
- Scope limits enforced while the call runs, so the agent takes an intake and routes it instead of answering a legal question.
- In controlled testing
- Per-decision rationale logged and retrievable, so what the agent did and why is answerable per interaction.
- In controlled testing
- The Article 50 disclosure spoken in the flow, with a receipt recording that it happened.
- In controlled testing
- RA-MICRO write-back for matters, time and document templates.
- Planned
The first thirty seconds
Confidentiality starts before the file does.
Someone calls, and within two sentences has named the opposing party, the amount at stake and what they did. No conflict check has run. No engagement exists. The firm is nonetheless holding material covered by its professional secrecy, and in Germany a careless disclosure of it is a criminal matter under § 203 StGB rather than a professional-conduct point.
The design consequence is that the record cannot be built the way an ordinary call log is built. Turns that carry substance are compartmentalised as the call runs (held apart from general retention), while the operational shell of the call, that it happened, when, how it was routed, stays available for the practice to work with.
Explanation
Article 86 is narrower than it is usually quoted as.
The right to an explanation in Article 86 attaches to a decision the deployer takes on the basis of the output of a high-risk AI system listed in Annex III, where that decision produces legal effects or similarly significantly affects the person. An intake agent that schedules a consultation and routes a caller is not making that kind of decision, and quoting Article 86 at it overstates the position.
What is worth having regardless is the record. Logging the rationale per decision (what the agent did, on what basis, in which turn) answers the ordinary questions a client, a partner or a supervisory authority asks, and it is the thing that turns an assurance into an answer. That it also supports an Article 86-style explanation where the article does apply is a consequence, not the reason.
Questions
- Will the agent give legal advice?
- No. Providing legal services is reserved, and the agent takes an intake and routes it. Questions that call for advice are refused at run time and passed to the firm, and the refusal is recorded on the receipt for that call.
- What happens to what a caller says before a conflict check has run?
- Turns carrying substance are compartmentalised while the call runs, so they stay out of general retention. The operational shell of the call remains available for the practice; the substance is held apart.
- Does Article 86 apply to our intake line?
- Almost certainly not. Article 86 attaches to decisions based on the output of an Annex III high-risk system that produce legal effects or similarly significant effects. Scheduling and routing is not that. The per-decision rationale is logged anyway, because it answers the questions that do get asked. This page is general information, not legal advice.
What is kept apart, and what is kept
Compartmentalisation is a decision made while the call runs, not a retention policy applied later. See how the engine decides what may be said, refused and held apart.
Related
Data governance Article 50: 2 August 2026 The duty that already applies.
RA-MICRO The practice-management side.
GDPR Minimisation and the rights of the caller.
All sectors Which layer sits on which sector.
