compliancegdpr

AI automation and GDPR: a checklist for Hungarian companies

Seven things to settle before an AI system touches customer data: lawful basis, DPAs, data minimisation, residency, retention, disclosure and records.

Published: 5 min read

Written by: The Automata AI Cégeknek team

The seven-point checklist

Work through these in order during scoping. Each takes hours, not weeks.

  1. 01Lawful basis: name it for each data flow, usually contract performance or legitimate interest.
  2. 02Data processing agreements: one with every provider that sees personal data, including the model API.
  3. 03Data minimisation: send the model the fields the task needs, not the whole record.
  4. 04Residency: choose EU regions where offered; otherwise rely on standard contractual clauses and document it.
  5. 05Retention: define how long logs and transcripts are kept, then delete automatically.
  6. 06Disclosure: tell people at the start of a call or chat that they are speaking with an AI.
  7. 07Records: add each AI processing activity to your records of processing and, for higher-risk uses, run a DPIA.

Where companies usually slip

Two places: using a consumer AI account instead of a business API with a DPA, and keeping call recordings indefinitely 'just in case'. Both are easy to fix before launch and hard to explain afterwards.

Frequently asked questions

Do I need a DPIA for a voice agent?

Often yes if it records calls or processes health, financial or other sensitive data at scale. For a booking agent at a hair salon, usually no, but documenting the assessment is still good practice.

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