Privacy policy

We minimise information shared with AI providers and use anonymised or aggregated material wherever practicable. Confidential client information or personal data will only be entered into ChatGPT where the proposed use has been agreed in writing and suitable provider terms, settings and data protection arrangements have been established. Where we act as your processor, this also requires appropriate processing instructions and any necessary sub-processor authorisation. Client agreement does not replace our data protection obligations.

Before sharing confidential client information or personal data with an AI provider, we will check that the applicable terms and settings exclude that information from model training. We do not use client material to train our own AI models. Provider retention and processing arrangements are assessed separately from training restrictions.

Fathom meeting recording and notes

With participants' agreement, we may use Fathom to capture meeting audio and, where agreed, video or shared-screen content, produce a transcript and prepare draft summaries and actions. This may include names, voices, images, business contact details and information discussed or displayed. We notify participants before capture begins and obtain their agreement. Anyone may decline or ask us to stop, and we will take manual notes instead. We rely on consent for optional meeting capture and AI transcription; accepting client terms or attending a meeting is not, by itself, consent.

We review AI-generated summaries before relying on them for advice or agreed actions. Recordings, transcripts and summaries are confidential, with access limited to authorised people who need them for the engagement. We do not publish recordings or use them for marketing without separate permission. Please avoid sharing patient information, sensitive personal information or unnecessary employee-level data during recorded meetings.

Fathom's published terms allow de-identified meeting data to be used to improve its in-house AI models unless the account holder opts out. Before capturing client meetings, we will check that this opt-out is enabled. Its external AI providers are contractually prohibited from training on meeting content. You can read the provider's privacy information at https://www.fathom.ai/privacy and data-processing terms at https://www.fathom.ai/dpa.

Service providers and international processing

We use service providers for business email, document storage, customer relationship management and delivery of our services, including Attio for contact and relationship records. Where agreed for an engagement, OpenAI and Fathom process relevant information to provide the AI services described above. We limit information shared to what is needed and assess applicable confidentiality, security and data-processing arrangements.

OpenAI, Fathom and their service providers may process information outside the UK, including in the United States. Fathom states that its data is stored in the United States. Before transferring personal data, we will establish an applicable UK adequacy arrangement or appropriate contractual safeguards, such as approved standard contractual clauses with the UK Addendum, where required. Contact Joanna for details of the safeguards relevant to your information or to request a copy.

Retention of meeting and AI records

We keep raw meeting recordings and transcripts only for as long as necessary to check notes, confirm actions and support the engagement. We delete them when those purposes are complete unless a specific contractual, legal, complaint or dispute-related reason requires longer retention. Checked notes forming part of the client record follow the client-record criteria below. We review AI chats and uploaded files and delete material when no longer needed, subject to applicable provider retention and backup arrangements.

You may withdraw consent for future meeting capture or ask us to delete an existing recording or transcript by contacting Joanna. Withdrawal does not affect earlier lawful processing. We will explain if a separate lawful reason requires us to retain a limited record, such as for a legal claim.