AI Voice Agents and GDPR in Greece

What a business should check before using an AI Voice Agent in Greece, from caller disclosure and call recording to DPAs and security.

Sep 6, 20266 minutes reading

By Η ομάδα της Argonstack, TechIns Group

An AI Voice Agent can answer calls, log requests, book appointments and update the CRM. Using one, however, involves the processing of personal data. Voice, phone number, name, conversation content, transcript and actions taken inside the CRM can all be linked to a specific individual.

Compliance is not achieved with a generic "GDPR compliant" label. You need to define the purpose, the legal basis, the data involved, the retention period, the recipients, callers' rights and the security measures in place. The exact framework depends on the industry and how the system is used. This article is a practical guide, not legal advice.

The role of the business and the provider

Typically, the business that decides why and how the Voice Agent is used is the data controller. The technology provider that processes data on the business's behalf acts as a data processor, provided it does not use the data for its own independent purposes.

This relationship must be documented in a Data Processing Agreement. The DPA should cover the categories of data, processing instructions, confidentiality, security, subprocessors, data subject rights requests, breach incidents, and deletion or return of data.

Disclosing that the caller is speaking with an AI

As of August 2, 2026, the transparency obligations of Article 50 of the EU AI Act apply. When an AI system interacts directly with an individual, that person must be informed from the very start of the interaction, unless it is obvious that they are speaking with an AI.

Best practice is a short, clear introductory message. For example: "You're speaking with the company's digital assistant. I can log your request or connect you with a representative." If the call is recorded or transcribed, this must be disclosed separately, in the manner required by the applicable framework.

Call recording and transcript generation

Recording an entire conversation is not the same as the temporary technical processing of audio needed to generate a response. If a recording or transcript is stored, the business must be able to explain why it is necessary, what the legal basis is, and for how long it is retained.

The Hellenic Data Protection Authority notes that recording telephone conversations is permitted only under specific conditions set out in Greek law. It should not be assumed that every call can be stored simply because the Voice Agent has that technical capability.

The principle of data minimization requires that only necessary data be retained. If a short, structured summary and the call outcome are sufficient for ongoing service, permanently storing a full recording may not be necessary. See also Argonstack's privacy policy.

Legal basis and purpose

The legal basis is not always consent. Depending on the case, it may relate to the performance of a contract, pre-contractual measures, a legal obligation, or legitimate interest. Consent must be freely given, specific, informed and revocable. It should not be selected as a default option when the actual relationship does not allow for a genuinely free choice.

Each purpose requires its own assessment. Handling an inbound call, booking an appointment, quality evaluation, model training and marketing outreach are not the same purpose.

Data the agent should not request

The agent should be limited to the fields that are actually necessary. It should not request sensitive data simply because it is technically capable of storing it. In healthcare, insurance, financial services and other regulated industries, stricter design, human oversight and, potentially, a Data Protection Impact Assessment are required.

The EDPB states that a DPIA is mandatory when processing is likely to result in a high risk to individuals. The assessment should be carried out before the system goes into production and updated whenever the system changes substantially.

Security, subprocessors and data transfers

The business needs to know where the data is hosted, which providers are involved, whether any transfers occur outside the European Economic Area, and who has access to recordings and transcripts. Role-based access rights, activity logging, encryption, a retention policy and an incident-response procedure are all required.

Having a server located in Europe is not, on its own, sufficient. The provider's legal entity, its subprocessors, support access paths and the actual data flows all need to be examined.

Human intervention and high-stakes decisions

The Voice Agent should not make unsupervised decisions that have a legal or similarly significant effect on a person. For requests with financial, medical, insurance or legal consequences, there must be a clear path to a human, along with a record of who approves the final action.

The design should also account for what happens when the system doesn't understand a request, when the caller asks for a human, or when an urgent situation is detected.

Checklist before going live

Before activation, the following should be defined: the purpose and legal basis, the introductory disclosure message, the recording policy, the retention period, the DPA, the subprocessors, access rights, the deletion procedure, the handover-to-human process, and failure scenarios. In higher-risk cases, a DPIA and legal review should be completed.

Argonstack's SIA AI can handle inbound calls, after-hours coverage, request intake, appointment booking and CRM updates. The final workflow should be configured according to each business's purpose, data and industry.

Next step

Design a Voice AI workflow with transparency, controlled recording, and a clear handover to a human.

Request a Voice AI Design Consultation

Frequently asked questions

Do we need to disclose that an AI is answering?

Yes, whenever a person interacts directly with an AI system and this is not otherwise obvious. The disclosure must be made clearly from the very start of the interaction.

Can we keep all recordings?

No, not without a specific assessment of necessity, legal basis and retention period. The technical ability to record a call does not, by itself, constitute a lawful purpose.

No, not always. The appropriate legal basis depends on the purpose and the relationship with the individual. The choice should be documented by the business together with its legal counsel.

Is a DPIA required?

It is required when the processing is likely to create a high risk. This is especially relevant in cases involving large scale, sensitive data, systematic monitoring, or significant automated decisions.