Call Recording Consent in Canada: What to Tell Callers When AI Answers

Call recording consent in Canada doesn't go away because a robot is doing the talking. If an AI receptionist answers your phone and records or transcribes the call, it's collecting personal information. The rules still apply.

It's easy to skip this during setup. The greeting sounds fine and the bookings roll in. Nobody thinks about the words until a caller asks if they're talking to a real person.

Here's what the Office of the Privacy Commissioner of Canada (OPC) expects, what your greeting should say and four scripts any Ottawa or Canadian business can copy. Short version: tell people up front, in plain words. It takes one sentence.

What call recording consent in Canada requires

For most private businesses, the law is PIPEDA, the federal privacy law for commercial activity. Alberta, British Columbia and Quebec have their own similar private-sector laws. Ontario has its own law for personal health information, which matters if you run a clinic.

The OPC's guidance on recording customer calls is short and clear. It applies whether the customer calls you or you call them. Here's the core of it:

• Only record for purposes a reasonable person would consider appropriate.
• Tell the caller you're recording, say why, and ask for consent.
• If they carry on knowing it's recorded and why, consent is implied.
• If they object, don't record, or offer another way to do business, like online or in person.
• Use the recording only for the purpose you stated. Don't say "quality" and then use it for marketing.
• Callers can ask for access to their recording later.

What about "one-party consent"? The Criminal Code makes intercepting private communications a crime, with an exception when one party to the call consents. That's a criminal-law rule, and it doesn't cancel your privacy-law duty to tell customers.

Why an AI receptionist changes the script

A receptionist jotting notes is not a recording. An AI that transcribes every word is. The OPC points out that recordings can also capture voice characteristics and personal details a caller offers that have nothing to do with the call.

Say it's an AI. The OPC's principles for generative AI say people using a public-facing AI tool should know they're interacting with AI and understand the privacy risks. Don't dress the bot up as "Jessica from the front desk."

Modern AI voices sound natural, and that's exactly why disclosure matters. If callers find out on their own, you lose more than one booking. You lose trust.

Know where the data goes. Your AI vendor may process calls outside Canada. The OPC's cross-border guidelines say that's allowed, but you stay accountable for the data.

You also need to tell customers their information may be processed in another country. While it's there, courts, law enforcement and national security authorities in that country may be able to access it.

Check the vendor's fine print. The OPC's call guidance says third parties handling your calls must follow the rules too. The AI principles say providers should disclose secondary uses, like training models on conversations, so ask your vendor and get the answer in writing.

4 disclosure scripts you can copy

Each script covers four points: it's an AI, the call is recorded, why, and what to do if they'd rather not. Put it in the first few seconds, before the caller shares anything personal.

If a caller says no to script 2, honour it. Offer the text line or a staff callback, and make sure the recording stops.

Ottawa tip: if you serve francophone callers, record a French version and offer it in the first line. The OPC's AI principles say information should be understandable by the intended audience.

Your checklist before you go live

1. Greeting. AI, recording, purpose and an opt-out, all in the first few seconds.
2. Retention. Decide how long you keep recordings. The OPC expects you to limit retention, so don't keep them forever by default.
3. Access. Know how to pull a caller's recording if they ask for it.
4. Vendor. Confirm where calls are stored, who can hear them and whether they train models.
5. Privacy policy. Say the same things in writing on your website.

An AI receptionist exists to stop missed calls from leaking revenue, especially after hours. Don't let a missing sentence in the greeting create a new problem.

This is general information, not legal advice. It's our plain-English read of public OPC guidance. If you're in health care, law or finance, talk to a lawyer or your regulator before you go live.

Our take: disclosure is a trust signal, not a speed bump. Callers across Canada have heard "this call may be recorded" for years. Adding "I'm an AI" is one more honest sentence.