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Bliro is the AI sales assistant that documents customer conversations on-site and online via real-time transcription (live transcript), without a bot and without audio or video recordings. The consent of the other party is not required for this. Nevertheless, there is an obligation to provide information under Article 13 GDPR. This article provides specific wording, templates and a process with which sales representatives transparently inform their interlocutors without interfering with the conversation. It is part of our Field service playbooks on AI documentation for on-site appointments.
Why consent is not required but still needs to be informed
Many sales teams ask themselves: Do I have to ask my customer for permission before the on-site appointment if I use Bliro to document the conversation? The short answer: No. Die LUTZ Business Law Firm | ABEL clarifies in an analysis from January 2026 that anonymized real-time transcription without permanent audio storage can be based on the legitimate interest under Art. 6 para. 1 lit. f DSGVO. Bliro does not create any audio files and is therefore not subject to § 201 StGB (violation of the confidentiality of the word).
What remains, however, is the obligation to provide information under Article 13 GDPR. Informing is not the same as asking for permission. Die Data protection law firm points out that the Baden-Württemberg supervisory authority recommends that interlocutors be informed of the planned transcription as early as the meeting invitation. In the field, this means: You inform, you don't ask for permission.
Specialist lawyer Michael Eberlein confirms, with reference to the Bavarian State Office for Data Protection Supervision (BayLDA), that transcription to document meeting results does not necessarily have to be based on consent. BayLDA expressly acknowledges the legitimate interest in efficient logging.
What exactly needs to be in the information?
Die Society for Data Protection and Data Security (GDD) In a short paper dated March 2026, recommends that the following points be covered:
Carolin Loy, Head of Digital Economy at BayLDA, underlines an additional point in the Privacy Talk podcast (February 2026): Name the tool used and describe whether it is a live transcription or a subsequent transcription. With Bliro, it's easy: live transcription, not recording.
Three ways to inform your interlocutor
1. In advance via email or appointment invitation (recommended)
The cleanest way is a quick note in the appointment confirmation or calendar invitation. The Baden-Württemberg supervisory authority recommends exactly this approach. Your interlocutor reads the information before you meet, and there is no unpleasant moment during the appointment itself.
Example wording for the email:
“Quick note: We use Bliro, an AI tool for real-time transcription, for our customer conversations. Bliro does not make audio or video recordings. The tool documents the conversation as text so that we can record meeting results cleanly and process them promptly. The transcripts are stored in encrypted form on EU servers and automatically deleted after [X days]. If you have any questions, feel free to contact me.”
2. Orally at the start of the appointment
If the email is impracticable, for example during spontaneous appointments, a short sentence at the start of the conversation works. The key: Casually, factually, not make a big issue out of it.
Example wording (oral):
“Before we start: I use an AI tool that records our conversation as a text so that I can send you a clean follow-up afterwards. Nothing is being recorded, no audio file, no video. Just a live transcript. Is that right for you?”
The last question (“Is that right for you?”) is not consent in the legal sense. It is a polite question that signals: transparency, no hiding. The legal basis for the GDPR remains legitimate interest, not consent.
3. Standardized in your email signature
For teams that use Bliro across the board, a brief note in the email signature can supplement the information requirement. This does not replace direct information, but covers cases in which advance communication has been forgotten.
Sample signature text:
“We use Bliro for AI-based conversation documentation (real-time transcription, no recordings). Details: [link to data protection information]”
What to do if the interlocutor asks
The most common queries can be divided into three categories. Here are the answers you should have ready:
“Is the conversation being recorded?” No Bliro doesn't create audio or video files. The tool converts spoken language into text in real time via system audio (device-level audio capture). There is no audio file at any time.
“Who is reading the transcript?” Only the people involved in the conversation and, if applicable, the responsible team lead have access. Bliro anonymizes interlocutors and stores data on EU servers (AWS Frankfurt) in compliance with GDPR. Bliro is ISO 27001 certified.
“Can I turn that down?” You are not dependent on consent, so refusing does not change the legal basis. Nevertheless, pragmatism is required: If an interlocutor feels uncomfortable, switch off Bliro for this appointment. The customer relationship is more important than a single transcript.
At a glance: Bliro's duty to provide information in the field
Frequently asked questions about the information requirement for AI transcription in field service
Is it legally risky to transcribe conversations without consent?
No, as long as no audio recording is made and the transcription is based on legitimate interest. Die LUTZ Law Firm | ABEL confirms that anonymized real-time transcription without audio storage can be carried out in a legally secure manner under certain technical conditions even without explicit consent. A Discussion paper from the Werning law firm comes to the conclusion that, with transparent advance information, the threshold for authorization under Section 201 StGB can be met. The information requirement under Article 13 GDPR must be complied with in any case.
Is an oral reference sufficient or does the information have to be provided in writing?
In principle, the GDPR does not require a specific form of information. Die GDD recommends However, in their short paper dated March 2026, to document the information in writing, ideally in the meeting invitation. An oral note at the start of the conversation is useful as a supplement, but should not be the only source of information.
What happens if I forget to provide information?
A violation of the information requirement under Article 13 GDPR may result in fines. In practice, the recommends IMSCHWEILER-LEGAL law firmto anchor the information as an integral part of the appointment process: Note in the calendar invitation, text module in the email template, short note in the signature. Bliro teams that standardize the process reduce risk to a minimum.
Does the works council have to approve the introduction of Bliro?
When using AI transcription tools across the board, there are participation rights in accordance with BetrVG § 87. Bliro addresses this issue through anonymous coaching: supervisors only see aggregated team data, not individual transcripts of individual employees. Die IMSCHWEILER-LEGAL law firm recommends involving the works council at an early stage and regulating the use in a works agreement.
How does the duty to provide information differ from consent?
The duty to provide information (Art. 13 GDPR) means: You inform your counterpart that data processing is taking place, for what purpose and by what means. Consent (Art. 6 para. 1 lit. a GDPR) means: You need an active “yes” from the interlocutor before you can start. Bliro is based on legitimate interest, not consent. Die Baumgartner Baumann law firm confirms that the scope for legitimate interest is significantly greater if no biometric voice profiles are created and no audio files are created.
Frequently Asked Questions
