This policy formalises Cavendish Family Office (London)’s responsible use of artificial intelligence (AI) and automated transcription tools in client work.
It also ensures all staff and consultants operate transparently, lawfully, and ethically under the UK GDPR and the Data Protection Act 2018.
The purpose is to document how OpenAI (ChatGPT) and Otter.ai are used to enhance drafting accuracy, efficiency, and record-keeping, while maintaining full confidentiality and professional oversight. All outputs are reviewed by qualified personnel before external use, and no client data is ever shared for model training or external publication.
To document the lawful use of artificial intelligence (AI) and automated transcription tools (OpenAI ChatGPT and Otter.ai) in client-related work, ensuring compliance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and professional-confidentiality duties.
Applies to all staff and consultants who use AI-supported platforms to assist with:
Processing is carried out under the legitimate-interest basis (Article 6(1)(f) UK GDPR): improving accuracy, efficiency, and record-keeping while maintaining professional standards. No automated decision-making or profiling occurs.
Personal data may include names, limited biographical or financial references, and discussion summaries. Data is used only for internal professional purposes and deleted when no longer required.
Both operate under appropriate data-transfer safeguards, including Standard Contractual Clauses and encryption in transit and at rest.
Clients are informed in engagement documentation and via email footer that AI-based tools are used for internal professional support. They may request exclusion from such processing or exercise their data-subject rights (access, rectification, erasure, restriction).
Otter.ai transcripts are retained in accordance with the firm’s record-keeping policy and deleted once the client matter closes or earlier if requested. ChatGPT conversation material is deleted after drafting or final review.
The Data Protection Officer (me) is responsible for oversight of AI-related data processing and for responding to any data-subject or regulator enquiries.
This policy will be reviewed annually or following any change in technology, provider, or regulatory guidance.