Consent & Data Handling Policy
Call Transcription & Optional Recording Notice
Discovery Call and In-Person Visit: Recording, Transcript and Summary Consent Notice and Data Handling Policy. Review our Privacy Policy and Terms of Service for complete governance context.
# Controller & Entity Information
Controller (legal entity): RichProMax Limited, a private company limited by shares
Trading as: Motive Journey (Registered Business Name No. 764794)
Registered in: Ireland. Company Registration No. (CRO): 779918
Registered office: Apartment 2, 4 O’Neill Crowley Quay, Fermoy, Co. Cork, Ireland (P61X407)
Contact: info@motivejourney.com · +353 89 944 8950
Note on VAT: RichProMax Limited is not currently registered for VAT, so no VAT is added to our fees.
Full corporate details are published on our Legal and Company Information page.
This document has two parts:
- Part A is the client-facing consent notice and wording (what the person sees and agrees to before a call or visit is recorded).
- Part B is the internal data-handling policy (how we treat the recording, transcript and summary).
The purpose is to let us record discovery calls and in-person diagnostic visits, generate transcripts, and produce short AI summaries in a way that is compliant with the GDPR, the Irish Data Protection Act 2018, the ePrivacy Regulations, and the EU AI Act (read our AI Transparency Notice), so that the recording feature does not create legal exposure for the company.
A. Part A. Client-Facing Consent Notice
A.1 Short notice
“(shown at the start of the call and next to the booking form) This call or in-person visit may be recorded by RichProMax Limited (trading as Motive Journey) so we can prepare an accurate solution plan for you and follow up. If you agree, we keep the recording only for as long as needed to prepare your solution plan, after which it is deleted. We may keep a short written summary of the interaction for the duration of our work together. You can decline recording and still have the call or visit, and you can ask us to delete your recording at any time. Full details are in our Privacy Policy.”
A.2 Consent options
The person is offered clear, separate choices. Recording never starts until an affirmative choice is made.
Option 1: “Yes, you may record this interaction, create a transcript, and prepare a summary.”
Option 2: “No recording. Please take written notes only.”
If the person chooses Option 2, the interaction proceeds normally without any recording or transcript.
A.3 What each choice means
(plain language, available on the same screen)
- Recording: an audio or video capture of the call or in-person visit.
- Transcript: a written text version of what was said.
- Summary: a short set of notes about your business needs and next steps, which may be produced with the help of an AI tool.
A.4 In-Person Visits & Third Parties
This notice covers recordings made during online calls AND during in-person visits to a client’s premises. Consent is obtained before recording starts, in the same way and with the same right to decline. Where other people are present at the premises, the client is responsible for informing them and ensuring they consent to the recording.
A.5 Rights reminder
(shown with the options) You can withdraw your consent and ask us to delete your recording and transcript at any time by emailing info@motivejourney.com. Withdrawing consent does not affect the lawfulness of anything done before you withdrew it.
B. Part B. Internal Data-Handling Policy
B.1 Legal basis
The legal basis for recording, transcribing and summarising discovery calls and in-person visits is consent (GDPR Article 6(1)(a)).
We do not rely on legitimate interest for recording, because systematic recording under legitimate interest requires a documented balancing test and the Data Protection Commission expects that test to be genuinely carried out before processing begins. Consent, freely given with a real option to decline, is simpler and safer for our purpose.
Consent must be:
- Freely given: the person can decline recording and still have the call or visit. We never make the interaction conditional on accepting the recording.
- Specific and informed: the person is told who records, why, what is kept, for how long, and their rights.
- Unambiguous: consent is captured by an active choice, never by silence or by continuing the interaction.
- Withdrawable: withdrawal is as easy as giving consent.
B.2 Consent logging
For every recorded interaction we log, at minimum:
- who consented (name and, if applicable, business name),
- the date and time consent was given,
- exactly what was consented to (recording, transcript, summary),
- the method (for example, on-screen selection or spoken confirmation captured at the start of the recording).
This log is our evidence that consent was valid.
B.3 Retention Criteria
We keep personal data only for as long as it is needed for the purpose it was collected for. In practice this means:
- Recordings and transcripts are retained only for as long as needed to prepare your solution plan, after which they are permanently deleted.
- Call and visit summaries are kept for the duration of our work together.
- The consent log is retained as our legal evidence.
You can ask us to delete your data at any time, and we will do so unless we are legally required to keep it.
B.4 Data subject rights
We must be able to act on these promptly, and in any case within one month:
- Access (Article 15): provide a copy of the recording, transcript or summary on request.
- Erasure (Article 17): delete the recording and transcript on request, or when consent is withdrawn, or when the retention purpose ends. We may keep data only where it is genuinely needed for a legal claim.
- Rectification (Article 16): we do not alter audio. For a factual correction, we annotate the summary or metadata and keep a note of the person’s concern.
B.5 Security and Processors
Recordings, transcripts and summaries are stored in a secure, access-controlled location. Access is limited to authorised staff only. Data is encrypted in transit and, where possible, at rest.
We use processors that provide data processing terms meeting Article 28 GDPR. Our current main processor is Google, whose Data Processing Addendum applies to our use of its services. Any transfer outside the EU/EEA must be protected by Standard Contractual Clauses or another valid mechanism.
B.6 AI transparency and limits (EU AI Act)
Transparency obligations under Article 50 of the EU AI Act apply from 2 August 2026. A person can ask to speak with a human at any time.
Summaries produced with AI may be inaccurate or incomplete. A human reviews them before they are relied on.
We do not use AI to infer emotions, mood, sentiment or intentions from a person’s voice. Emotion recognition based on biometric data is subject to separate and stricter obligations, and some uses are prohibited. Our summariser works from the words spoken only, not from voice characteristics.
B.7 No use of call data to train models
Call recordings, transcripts and summaries are not used to train, fine-tune or improve any AI model, whether our own or a third party’s. A discovery-call transcript typically contains details that could identify a business or person, so it cannot be treated as anonymised. Any system improvement uses only aggregated, non-personal operational metrics (for example, average call length or the count of common enquiry types as numbers), with no text or audio that can be linked back to a person.
