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AI, customer experience and the law: practical guidance for UK businesses

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AI is no longer a futuristic idea in customer experience. It’s the friendly voice that greets callers, the AI receptionist that routes calls at 7am, the chatbot that helps customers out of hours, and the quiet virtual assistant supporting your call handling team behind the scenes. For many UK businesses, this is exciting and slightly unsettling at the same time. The technology is moving quickly, while laws, guidance and ethics can feel harder to pin down. It’s completely understandable to feel real pressure here, because getting customer data, transparency or fairness wrong can have serious consequences for trust and reputation. The good news is that you don’t need to be a lawyer or a data scientist to use AI responsibly. This guide will walk you through some of the key legal and ethical principles that apply in the UK today, what’s changing in Europe and the USA, and firmly rooted in doing the right thing for your customers.

What we mean by AI in customer experience

AI in customer experience is any use of artificial intelligence to greet, support or serve your customers. For UK businesses, that increasingly includes:

  • AI receptionists that answer calls, greet callers and handle routine enquiries.
  • Automated call answering and routing that collects simple details and directs callers to the right place.
  • Voice agents that support or sit alongside a telephone answering service.
  • Chatbots and messaging assistants on your website or in social channels.
  • AI triage tools that decide whether a call should go to an AI receptionist, your call handling team or a specialist.
  • Personalisation tools that tailor greetings or responses based on caller history and preferences.

Used well, these tools do not replace human care. They create a smoother front door for customers, reduce wait times, free your people from repetitive questions and give them more time for complex and sensitive conversations.

The key is to combine AI with clear guardrails, strong human oversight and a genuine commitment to doing the right thing for your customers.

In the UK, there is no single AI law for customer service. Instead, your AI receptionist or call answering service must comply with existing rules, mainly the UK GDPR and the Data Protection Act 2018. The Information Commissioner’s Office (ICO) has detailed guidance on AI and data protection, including how to apply principles such as fairness, transparency and accountability to AI systems.

Personal data in calls and voice interactions

Whenever a customer calls your business, you are likely processing personal data. That might include:

  • Caller ID and contact details.
  • Details about their account, order or service use.
  • Information about their health, finances or other sensitive topics shared in the call.
  • Call recordings and transcripts, if you create them.

Voice data and call recordings can be particularly sensitive, so you must handle them with care, just as you would any other personal data. The ICO’s artificial intelligence hub and related guidance explain how the usual data protection principles apply to AI systems that process this kind of information.

Lawful basis and data minimisation

Under UK GDPR you need a lawful basis for processing personal data. For AI customer service, that is often legitimate interests or performance of a contract, but you should document your reasoning and ensure the impact on individuals is proportionate.

The ICO expects organisations using AI to apply data minimisation and security principles carefully. That means collecting only what you need, keeping it only for as long as you genuinely need it, and putting strong technical and organisational controls in place, particularly where AI systems can access or generate large datasets. The ICO’s AI and data protection risk toolkit is a useful starting point.

Fairness and avoiding bias

Fairness is a central principle in the ICO’s AI guidance. You should be able to show that your AI receptionist, routing logic or call handling workflows do not treat certain groups unfairly, for example by consistently routing particular postcodes or accents away from valuable support or sales opportunities.

In practice, that means:

  • Checking for patterns in call routing and outcomes.
  • Reviewing any automated prioritisation rules that influence who gets through first.
  • Allowing human review and correction where AI decisions could materially affect a customer.

Transparency and explainability

Customers should understand when AI is involved and what that means for them. The ICO and The Alan Turing Institute provide practical advice in their Explaining decisions made with AI guidance on how to explain AI assisted processes and decisions in clear, accessible ways.

For AI receptionists and call answering services, that typically means:

  • Updating your privacy notice to explain how call and chat data is used, including any AI processing or training.
  • Clearly signalling when a caller is speaking with an AI receptionist.
  • Giving callers an easy path to speak with a human if they prefer.
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EU AI Act and why it still matters

The EU AI Act is the first comprehensive legal framework that focuses specifically on AI. It uses a risk based model, categorising AI systems as minimal, limited, high or unacceptable risk, with different obligations for each level.

Even though the UK is not part of the EU, this still matters for many UK businesses in three key ways.

Most CX tools sit in the limited risk category

For most customer service teams, AI receptionists, voicebots and chatbots will fall into the limited risk category. These systems are generally allowed but must meet specific transparency requirements. For example, EU rules make it clear that users should be informed when they are interacting with an AI system rather than a human.

Serving EU customers from the UK

If you serve customers in the EU or your AI tools affect people in EU countries, the EU AI Act can apply even if your business is based in the UK, in a similar way to how GDPR works in practice.

At a practical level, that means:

  • Making sure any AI receptionist or call handling solution you use is transparent by design.
  • Working with vendors that understand both UK GDPR and EU AI Act obligations.
  • Keeping records of how you assess and manage risk in your AI tools.

Generative AI and transparency

The AI Act introduces special transparency obligations for general purpose AI models and generative tools. These include requirements for documentation, training data information and risk assessments, which are being phased in from 2025 onwards. As a user of AI customer service tools, you are unlikely to need to meet those obligations yourself, but your providers will. Choosing partners that stay ahead of these rules is a pragmatic way to future proof your customer experience.

Lessons from California and other leaders

California is emerging as an important reference point for AI and privacy regulation. The California Privacy Protection Agency (CPPA) has been developing rules for automated decision making technology (ADMT) under the state’s privacy law, covering areas such as risk assessments, cybersecurity and consumer information rights.

While these rules focus on high impact areas such as employment, finance and access to essential services, the direction of travel is clear. Regulators want:

  • Stronger accountability for AI that impacts people’s lives.
  • Clearer information for consumers about how AI is used.
  • Regular risk assessments and documented controls.

For UK businesses, this is a chance to learn rather than wait. If you adopt similar habits in your AI receptionist or call handling projects, you will be in a strong position if UK specific AI rules tighten in future.

An ethical AI customer experience playbook

Laws set the minimum standard. Your ethical choices are what customers feel day to day. A simple, practical playbook can help you create a customer experience that feels humane, transparent and trustworthy, even as AI tools become more capable.

1. Always tell customers when AI is involved

Make it clear at the start of a call or chat when an AI receptionist or automated system is handling the interaction. A short friendly line such as “You are speaking with our AI receptionist, I can help with everyday questions or connect you with the right person” can set expectations and reduce anxiety.

2. Make human help easy to reach

Ethical AI customer service always keeps people in the loop. Give callers simple routes to reach a human, with clear menu options or voice prompts that offer a person if they are stuck, vulnerable or simply prefer human contact.

3. Treat call data with respect

Decide what you truly need to store, for how long, and why. Limit access to transcripts and recordings. Use anonymisation or pseudonymisation where possible in training data and make sure your vendors apply strong security and data minimisation controls.

4. Build fairness checks into routing and logic

Plan for fairness from the start. Test whether certain postcodes, time slots or caller types consistently experience longer waits or lower priority. Review and adjust workflows to avoid any unintended bias in your AI driven call handling.

5. Train AI to recognise vulnerability and escalate

Voice interactions can reveal distress, confusion or vulnerability that a simple web form would never capture. Work with your providers to define clear escalation triggers, so that potential safeguarding issues, financial vulnerability or health concerns are recognised quickly and routed to trained people.

6. Carry out strong vendor due diligence

Ask your AI receptionist or call answering providers how they:

  • Process, store and secure call data.
  • Use recordings or transcripts in model training.
  • Comply with UK GDPR, ICO guidance and, where relevant, EU AI Act transparency requirements.
  • Align with recognised ethical frameworks such as the OECD AI Principles , which emphasise human rights, transparency, robustness and accountability.

Implementation checklist for UK business owners

If you are planning or reviewing AI in your customer experience, this checklist can help you move from good intentions to practical action.

  • Map AI touchpoints across calls, chats and messaging, including AI receptionists, call routing and any AI enabled telephone answering service.
  • Confirm lawful basis for each processing activity involving personal data and record your decisions.
  • Update privacy notices so they clearly explain where AI is used in answering calls, handling enquiries or training models.
  • Conduct DPIAs for higher risk AI use cases, such as extensive call recording, profiling or automated prioritisation.
  • Define fairness, escalation and human review policies and bake them into your workflows and training.
  • Set clear retention periods for call recordings and transcripts, and implement technical controls to enforce them.
  • Document your AI risk management approach, including vendor checks, testing and ongoing monitoring.
  • Go beyond the minimum by adopting ethical principles that focus on trust, dignity and long term brand reputation, not just compliance.

How Moneypenny can help

At Moneypenny, we see AI as a way to enhance human service, not replace it. Our AI receptionist and telephone answering services are designed to work hand in hand with experienced receptionists and call handlers, so your customers always feel heard and looked after.

We focus on:

  • Blended AI and human support that gives callers the speed of automation and the warmth of real people.
  • Responsible call handling and data practices aligned with UK GDPR and ICO expectations.
  • Careful design of scripts and workflows so AI remains transparent, fair and easy to escalate to a person.

If you are exploring using an AI voice agent, telephone answering or want to provide extended out-of-hours support for your customers, we can work with you to shape an approach that is efficient, compliant and genuinely customer centric.

FAQs

Is an AI receptionist legal in the UK?

Yes, an AI receptionist is legal in the UK as long as you comply with existing laws and guidance, particularly UK GDPR and ICO expectations on fairness, transparency and accountability for AI systems. You must treat voice and call data as personal data, have a clear lawful basis for processing, and be open with callers about how AI is used. The ICO’s AI and data protection guidance
is a helpful reference.

Do I have to tell callers when AI is answering or routing their call?

While the UK does not yet have a specific AI labelling rule for all customer service situations, both ICO guidance and the EU AI Act’s approach to limited risk systems support being transparent when people interact with AI rather than a human. In practice, clearly telling callers when they are speaking with an AI receptionist is a strong ethical choice and aligns with emerging global expectations.

Can I use call recordings or transcripts to train AI?

You can use recordings and transcripts to improve AI tools if you have a lawful basis and you respect data protection principles. That means being transparent with callers, limiting access, minimising how much personal data you keep, and putting strong security in place. For any higher risk use, such as large scale profiling or sensitive information, a DPIA is strongly recommended and the ICO’s risk toolkit can help you structure that analysis.

How do I protect caller privacy when using AI for telephone answering?

Start by mapping what personal data your AI receptionist or call handling system collects, who can access it and where it is stored. Apply UK GDPR principles carefully, including data minimisation, security, retention limits and access controls. Choose providers that can explain their own compliance measures in clear language and that are willing to support DPIAs and risk assessments where needed.

What if I serve customers in the EU or US?

If your AI customer service affects people in the EU, you may need to consider both UK GDPR and EU rules, including the EU AI Act’s transparency obligations for systems that interact directly with people. If you have customers in US states such as California, keep an eye on emerging ADMT and privacy regulations, which are increasing expectations around risk assessments and consumer information. Working with vendors who track these changes for you can reduce complexity.

Above all, remember that trust is your competitive advantage. Every transparent disclosure, fair routing decision and thoughtful escalation builds confidence that your business is using AI to serve people, not the other way round.

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