UK GDPR and AI use cases

Annex III point 4(b) lists AI systems intended to monitor and evaluate the performance and behaviour of workers as high risk. Synthesising an employee's work history and feedback into a performance evaluation is very plausibly profiling of a natural person under GDPR Article 4(4), which expressly covers analysing or predicting a person's "performance at work". Article 6(3)'s last subparagraph makes an Annex III system high risk regardless of the derogations whenever it performs such profiling, so a tool built this way is high risk by default however much the manager edits the output. The derogations in Article 6(3), including a narrow procedural task or improving the result of a previously completed human activity, do not fit drafting an evaluation from scratch; the closest is point (d), a preparatory task ahead of a human assessment, which only has a chance of applying to a design that avoids profiling altogether, for example one that only surfaces raw facts without synthesising a judgement. Where that derogation is argued, the documentation duty under Article 6(4) falls on the provider of the system, and only on the deploying organization when it builds the tool itself. Because the tool is high risk by default, Article 26(7) requires informing affected workers and their representatives before it is put into use in the workplace, whatever the tool's output is used for; using the same system's output directly in pay, promotion or termination decisions removes any doubt and triggers the full high risk regime. Annex III's high risk obligations apply from 2 December 2027.

Annex III point 5(a): AI systems used by or on behalf of public authorities to evaluate the eligibility of natural persons for essential public assistance benefits and services, or to grant, reduce, revoke or reclaim them. A fundamental rights impact assessment (Article 27) is required before a public body deploys it. A design that scores people over time on their social behaviour or personal characteristics and leads to unrelated or disproportionate detrimental treatment would fall under the Article 5(1)(c) prohibition on social scoring.

Annex III point 4(a) lists AI systems intended to be used for the recruitment or selection of natural persons, in particular to place targeted job advertisements, to analyse and filter job applications and to evaluate candidates. Screening, ranking and scoring applications is therefore high risk. A component limited to a narrow procedural task, such as booking interview slots or answering process questions, can fall outside the high risk category under Article 6(3), but only if it does not materially influence the outcome and does not profile people, and that assessment must be documented (Article 6(4)). Deployers of the high risk part must follow the instructions for use, assign competent human oversight, keep logs, inform workers' representatives and inform candidates that a high risk system is used (Article 26). An organization that builds its own screening system becomes its provider, with conformity assessment duties. The chatbot part also carries the Article 50 disclosure duty.

Scoring individual agents' interactions to monitor and evaluate their performance and behaviour falls under Annex III point 4(b), employment and worker management. The Article 6(3) exception does not apply where the system profiles natural persons. Inferring agents' emotions is prohibited under Article 5(1)(f), except for medical or safety reasons. Inferring customers' emotions from their voice is emotion recognition on biometric data: high risk under Annex III point 1(c), and Article 50(3) requires informing the people exposed to it. Analytics that only aggregate interaction themes without evaluating individuals can fall outside the high risk category.

Annex III point 3(b): AI systems intended to be used to evaluate learning outcomes in educational and vocational training institutions at all levels are high risk. Scoring that determines access to an institution or the level of education a student will receive is also covered by points 3(a) and 3(c). Schools and exam bodies that use such a system have the deployer obligations of Article 26.

Annex III point 5(d): AI systems intended to evaluate and classify emergency calls or to dispatch or set priority for emergency first response services (police, fire, medical aid) are high risk. Pure transcription that performs a narrow procedural or preparatory task may fall outside it under the Article 6(3) exceptions, but alerts that influence triage are in scope. An AI agent that speaks with callers directly, for example on a non emergency line, must also tell them they are interacting with AI (Article 50).

An agent that answers questions, books tours and takes requests falls under the transparency duty of Article 50. It becomes high risk under Annex III point 5(b) if it evaluates the creditworthiness of applicants, for example in tenant screening, and under point 5(a) if a public body uses it to decide eligibility for social housing or other public assistance.

Complaint handling is not listed in Annex III, so internal classification and drafting for a handler who decides is minimal risk. Where the agent talks to customers to take the complaint, Article 50(1) requires telling them they are dealing with AI. Only a system that also assessed creditworthiness or priced life and health insurance (Annex III point 5(b) or 5(c)) would be high risk for that part.

People must be told they are interacting with an AI system, and synthetic voice or text must be identifiable as such (Article 50). Reminding people of existing bookings and disclosure alone are limited risk. A missed appointment score used by or for a public authority to grant, reduce, revoke or reclaim access to healthcare or other essential public assistance and services, for example deciding who is offered funded transport, can fall within Annex III point 5(a), and profiling of natural persons within Annex III rules out the Article 6(3) exemption. Using the score only to decide who gets extra reminders or support does not by itself place it outside Annex III when that support is itself the assistance being granted.

Drafting outreach that a rep reviews and sends as their own message is typically minimal risk. If the agent holds conversations with prospects itself, for example by replying to emails or calling, people must be told they are interacting with AI (Article 50, limited risk). It is not an Annex III use case.

Booking, rescheduling and reminders carry transparency duties: patients must be told they are dealing with AI (Article 50(1)). It becomes high risk if a public authority, or a provider acting on its behalf, uses it to evaluate eligibility for healthcare services (Annex III point 5(a)), or if it acts as an emergency healthcare patient triage system (Annex III point 5(d)). Clinical triage may also make it a medical device, which is high risk under Article 6(1) when the device needs a notified body assessment. Keep the agent to scheduling and use risk scores only to offer support.

Ranking offers is generally minimal risk and the conversational part carries the Article 50 transparency duty. Using AI to evaluate creditworthiness for a credit offer is high risk (Annex III point 5(b)), and Article 5 prohibits techniques that exploit vulnerabilities due to a person's social or economic situation to distort their behaviour in a harmful way.

A customer service agent for bills, readings and moves falls under the transparency duty for systems that interact with people (Article 50(1)): customers must be told they are talking to AI. If the agent assesses creditworthiness, for example to set a deposit when a new customer moves in, that part falls under Annex III point 5(b) and is high risk; keep credit decisions in separately governed systems. The agent is not a safety component in the operation of the gas, water or electricity supply (Annex III point 2), so safety reports such as a gas smell go straight to the emergency line rather than being handled by the agent.

A scribe that only transcribes and summarises for a clinician to review is not listed in Annex III and is usually minimal risk, although the provider of a system that generates text can still owe the Article 50(2) duty to mark output as AI generated, unless an exception such as an assistive function for standard editing applies. If the product qualifies as medical device software under the EU Medical Device Regulation and needs a notified body assessment, for example because it suggests diagnoses or treatment, it becomes high risk under Article 6(1) and Annex I. Health data in audio and notes falls under GDPR Article 9 in every case.

Annex III point 5(a) makes AI high risk when it is used by or on behalf of public authorities to evaluate the eligibility of natural persons for essential public assistance benefits and services, or to grant, reduce, revoke or reclaim them. An assistant that only explains rules and guides applications carries the Article 50 transparency duties (limited risk); one that screens or scores eligibility falls under point 5(a), and a public body deploying it must carry out a fundamental rights impact assessment first (Article 27).

Decision support for professional investors and advisers about companies is not a use listed in Annex III and is not a practice prohibited by Article 5. The users are deal professionals who know they are working with an AI tool, and no consumer interacts with it, so the Article 50(1) duty to disclose an AI interaction has little practical effect. Article 50(2) is different: a firm that builds the assistant itself, including on a platform such as Blits.ai and putting it into service under its own name, is the provider of that system and must mark generated text in a machine readable format, unless the system only performs an assistive function for standard editing or does not substantially alter the input data or its semantics, which may cover extraction and redaction. A firm that instead licenses a vendor product, such as Datasite or Rogo, should confirm that the vendor meets this duty. Obligations are otherwise general: AI literacy for the deal team under Article 4 and, where personal data in the data room is processed, the GDPR.

Answering policy questions and starting routine requests is limited risk, with the Article 50 duty to disclose AI. It becomes high risk under Annex III point 4 if it is used to make or support decisions on recruitment, promotion, termination, allocating tasks based on individual behaviour or personal traits, or the monitoring and evaluation of workers; an employer deploying it then must also inform workers' representatives and the affected workers before use (Article 26(7)). Sensitive topic detection should work on what the employee writes: inferring emotions of people in the workplace from biometric data such as voice or facial expressions is prohibited under Article 5(1)(f), except for medical or safety reasons.

An assistant that answers questions and sends reminders falls under the transparency duty of Article 50. It becomes high risk under Annex III point 3(a) if it is used to determine access or admission or to assign students to institutions, and under point 3(c) if it assesses the level of education a student will receive. Keep admission and placement decisions with staff.

The drafting assistant does not assess creditworthiness, so on its own it is not the Annex III point 5(b) credit scoring system. It helps the lender meet the Article 86 right of affected people to a clear and meaningful explanation of decisions based on such a high risk system. If it is built into the scoring system it shares that system's high risk obligations; as a separate drafting tool its tier depends on its design and on how its output is reviewed. The follow up chat assistant must tell customers they are dealing with an AI system (Article 50).

Claims handling as such is not listed in Annex III. The same system becomes high risk when it is also used for risk assessment and pricing of natural persons in life and health insurance (point 5(c)), or when it is used by or on behalf of a public authority to grant, reduce, revoke or reclaim essential public assistance benefits and services, including healthcare services (point 5(a)). Otherwise the tier is minimal, so the design and the operator decide. Decisions on claims based solely on automated processing are also subject to Article 22 of the GDPR and the UK GDPR.

Annex III point 8(a) makes AI high risk when it is intended to assist a judicial authority in researching and interpreting facts and the law and in applying the law to a concrete set of facts. Tools for prosecutors fall under point 6(c) if they evaluate the reliability of evidence, and tools that assist the examination of asylum, visa or residence applications fall under point 7(c). Under Article 6(3) a system that only performs a narrow procedural task or a preparatory task, such as organising a file or transcribing and summarising it for the person who decides, may not be high risk, but the provider must document that assessment (Article 6(4)). Summaries of internal legal advice for government lawyers, as Amsterdam plans, are generally outside Annex III.

Document review for a party in civil litigation or an internal investigation is not listed in Annex III, so it is usually minimal risk. It becomes high risk where a law enforcement authority uses AI to evaluate the reliability of evidence in the investigation or prosecution of criminal offences (Annex III point 6(c)), or where a judicial authority uses it to research and interpret facts and law (point 8(a)). Prosecutors and investigators should classify each use against those points.

Annex III point 7(c) makes AI high risk when it assists public authorities in examining applications for asylum, visas or residence permits, including assessing the reliability of evidence. Applicant facing information assistants that give general guidance fall under the Article 50 transparency duties (limited risk). Evidence classification, routing and interview support used in the examination are likely high risk, unless the provider documents under Article 6(3) that a component only performs a narrow procedural or preparatory task. That exception never applies to a system that profiles natural persons, which matters for routing on personal attributes or risk profiles.

It depends on where the system runs. Classifying and routing a bank's or insurer's correspondence is not a use listed in Annex III, so it is minimal risk: the AI literacy duty of Article 4 applies, and the Article 50 duty to tell people they are dealing with AI does not, because the system does not interact with the sender. Used by or for a public authority in a benefits process covered by Annex III point 5(a), the provider can treat it as not high risk only while it performs a narrow procedural or preparatory task under Article 6(3); the provider must then document that assessment before it goes live (Article 6(4)) and register the system in the EU database (Article 49(2)). If the system evaluates eligibility for benefits or profiles the people who write in, it is high risk, so those judgements stay with people.

Claims fraud detection by an insurer is not listed in Annex III, and point 5(b) explicitly excludes AI systems used to detect financial fraud from the credit scoring category. Point 5(c) covers only risk assessment and pricing in life and health insurance, so a fraud model becomes high risk when it also feeds those decisions, or when it is used by or on behalf of a public authority to grant, reduce, revoke or reclaim public assistance benefits (point 5(a)). Profiling and automated decisions remain subject to GDPR, including Article 22 where a claim is refused on a decision based solely on automated processing.

Renewal intake for commercial lines and outreach are not listed in Annex III. Renewal risk assessment or pricing for life or health insurance of natural persons is high risk under point 5(c), and so is a lapse score that feeds those decisions; a lapse score used only to decide who gets a service call is not listed. Customer facing renewal assistants carry the Article 50(1) duty to tell people they are interacting with an AI system, unless that is obvious from the context.

Permit and licence decisions are not listed as such in Annex III, so officer decision support is usually minimal risk, and an assistant that talks to applicants carries the Article 50 transparency duty. The exceptions are permits in an Annex III area: examining applications for visas and residence permits (point 7) and evaluating eligibility for essential public assistance benefits and services (point 5(a)) are high risk. Solely automated decisions with legal or similarly significant effects on a person fall under GDPR Article 22 whatever the tier.

Prioritizing inspections of businesses and premises is not a use listed in Annex III, so such a system is usually not high risk. The assessment changes when it scores natural persons, such as individual licensed professionals or sole traders, and the inspectorate acts as a law enforcement authority: assessing the risk that a person offends, or profiling persons in the detection or investigation of criminal offences, is high risk under Annex III point 6 (d) and (e), and predicting that a person will commit a criminal offence based solely on profiling is prohibited by Article 5(1)(d). GDPR applies wherever sole traders, home based businesses or named professionals are scored.

A generator of synthetic tabular test data is not listed in Annex III and does not interact with people, so it is minimal risk with only the AI literacy duty of Article 4. When the system generates synthetic text, images, audio or video, such as documents or conversation transcripts, Article 50(2) requires its provider to mark the output in a machine readable format as artificially generated. When synthetic data is used to train, validate or test a high risk system, such as credit scoring, it falls under that system's data governance duties in Article 10.

Risk selection for administrative tax audits is not listed in Annex III, and Recital 59 says systems used by tax and customs authorities in administrative proceedings should not be treated as high risk law enforcement systems. Use in criminal tax investigations (Annex III point 6, law enforcement), or evaluating the eligibility of natural persons for public assistance benefits run through the tax system (Annex III point 5(a)), can make it high risk. When individuals are scored in administrative tax work, the GDPR applies, including its profiling rules (Member States may restrict some rights for taxation matters under Article 23). Article 22 applies when a decision with legal or similarly significant effect is taken solely by the model. Criminal investigations fall outside the GDPR and under the Law Enforcement Directive (EU) 2016/680 instead.

Fraud detection is not listed as high risk in Annex III, and point 5(b) explicitly excludes systems used to detect financial fraud from the creditworthiness category. Blocking fraud traffic is not normally a safety component of critical digital infrastructure (point 2). The tier can change if the same scores are reused for an Annex III purpose: eligibility for essential public assistance benefits and services (point 5(a)), creditworthiness or credit scoring of natural persons (point 5(b)), or risk assessment and pricing for life and health insurance (point 5(c)). A voice or chat agent that takes fraud reports from customers also carries the Article 50(1) duty to tell people they are dealing with an AI system.

Annex III point 4 lists AI used for the recruitment or selection of natural persons (4(a)) and AI used to make decisions affecting promotion, or to allocate tasks based on individual behaviour, personal traits or characteristics (4(b)). A marketplace that ranks employees for internal roles or allocates projects on the basis of inferred traits is therefore high risk. Recommending learning content or mentors to an employee who chooses freely is usually not. Deployers of the high risk part must inform workers' representatives and the affected employees before use (Article 26).

Research and drafting support for lawyers in firms and companies is not listed in Annex III, so it is normally minimal risk with AI literacy duties. Annex III point 8(a) makes it high risk when a judicial authority, or someone on its behalf, uses AI to research and interpret facts and the law and to apply the law to a concrete set of facts, or when it is used in a similar way in alternative dispute resolution, so a deployment for courts, tribunals or arbitration needs its own classification.

Most personalization and content generation is minimal risk. Providers of systems that generate synthetic audio, image, video or text content must mark the output as artificially generated, and deployers must disclose deep fakes (Article 50(2) and 50(4)). Personalization that deploys manipulative or deceptive techniques, or exploits vulnerabilities due to age, disability or a specific social or economic situation, in a way that causes or is reasonably likely to cause significant harm, is prohibited under Article 5(1)(a) and (b). Using AI to assess creditworthiness or to price life and health insurance is high risk under Annex III point 5(b) and 5(c) and belongs on its own page. Outside the AI Act, the FCA Consumer Duty applies only to FCA regulated firms (the financial services slice of this use case), and the Telephone Consumer Protection Act applies only to campaigns delivered by call or text message in the US.

Transcribing and summarizing meetings for the participants is minimal risk. It becomes high risk under Annex III point 4(b) if transcripts are analysed to monitor or evaluate individual workers' performance or behaviour, and inferring participants' emotions from their voices or faces at work is prohibited by Article 5(1)(f). Recording and transcription also need a lawful basis and clear information to participants under GDPR.

Recommendation and personalization systems are not listed in Annex III, so most deployments are minimal risk under the EU AI Act. They become a compliance question elsewhere: manipulative or deceptive techniques that materially distort a person's behavior in a way that causes significant harm, or that exploit vulnerabilities linked to age, disability or a specific social or economic situation, are a prohibited practice under Article 5(1)(a) and (b), which is relevant to recommendation systems that target children. A decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on a person falls under GDPR Article 22, though routine content ranking rarely meets that bar on its own.

Summaries, CRM suggestions and follow up drafts that the seller reviews are not an Annex III use and are minimal risk. Using call analysis to monitor and evaluate the performance and behaviour of individual sellers, or to allocate leads to sellers based on their behaviour or personal traits, is high risk under Annex III point 4(b). Inferring sellers' emotions from their voice is prohibited in the workplace by Article 5(1)(f). Emotion recognition applied to customers' voices is high risk under Annex III point 1(c), and Article 50(3) requires deployers to inform the people exposed to it.

An automated valuation model values the collateral, not the person, so it is not itself listed in Annex III; the EU Mortgage Credit Directive treats property valuation (Article 19) and the creditworthiness assessment of the borrower (Article 18) as separate steps, and Article 18(3) says the creditworthiness assessment must not be based predominantly on the value of the property exceeding the amount of credit, or on an assumption that the property's value will increase. The valuation becomes relevant to Annex III point 5(b), creditworthiness assessment of natural persons, only where its output is built into a separate system that evaluates the borrower's creditworthiness, and whether that happens depends on how the lender designs the credit decision, not on the valuation model itself.

Assistants that talk with residents must tell people they are interacting with AI (Article 50(1)), and AI generated text published to inform the public on matters of public interest must be disclosed unless it has had human review under editorial responsibility (Article 50(4)). Internal translation that neither talks with people nor is published carries no specific obligation. Translation can also sit inside an Annex III process, such as examining asylum, visa or residence permit applications (point 7(c)) or evaluating emergency calls and dispatching emergency services (point 5(d)). Whether the translation component is itself high risk depends on its intended purpose (Article 6(3) exempts systems that only perform a narrow procedural task); either way it should be governed with that high risk process.

A tutor that only converses with students falls under the transparency duty of Article 50. It becomes high risk under Annex III point 3(b) when it evaluates learning outcomes, including when those outcomes are used to steer a student's learning process, and under point 3(c) when it assesses the level of education a student should receive. Inferring students' emotions is prohibited in education institutions under Article 5(1)(f).

An assistant that answers informational questions about courses and requirements, without deciding admission, assigning students to an institution, or evaluating learning outcomes, falls under the transparency duty of Article 50: students must be told they are talking to AI. It would move toward Annex III point 3 (education and vocational training) if it were used to determine access or admission to an institution or programme (point 3(a)), or to evaluate learning outcomes, including when those outcomes are used to steer the learning process (point 3(b)).

A customer facing assistant must tell people they are interacting with an AI system unless that is obvious (Article 50(1)). It does not evaluate creditworthiness (Annex III point 5(b)) or eligibility for public assistance benefits (point 5(a)), so it is not high risk; biometric verification whose sole purpose is to confirm identity is excluded from Annex III point 1(a).

A customer facing assistant must tell people they are interacting with an AI system (Article 50(1)). It triages and opens cases but does not evaluate creditworthiness (Annex III point 5(b), which in any case excludes systems used to detect financial fraud) or decide access to an essential service, so it is not high risk under Annex III.

A customer facing troubleshooting agent must tell people they are interacting with AI unless that is obvious (Article 50). It is not high risk as long as it is not used as a safety component in the management and operation of critical digital infrastructure (Annex III, point 2); running line tests and resets for one customer's service does not make it one.

A customer facing intake agent must be designed so that people know they are interacting with AI (Article 50(1)). Claims intake and claims handling are not listed in Annex III: point 5(c) covers risk assessment and pricing in life and health insurance, not claims. One design choice changes this: detecting distress by inferring emotions from the caller's voice is emotion recognition based on biometric data, which is high risk under Annex III point 1(c) and needs disclosure under Article 50(3). Detecting vulnerability from what the caller says does not. The limited tier assumes that design: every handover signal on this page (injury, distress, anger, vulnerability) is detected from the words of the conversation, and inferring emotions from the voice itself is out of scope.

A customer facing assistant must tell people they are interacting with AI (Article 50). It is not a high risk use under Annex III: it applies the airline's reaccommodation rules and does not decide on access to an essential public service or on creditworthiness.

A customer facing sales agent must make clear that people are talking to an AI system, unless that is obvious (Article 50(1)). Qualifying and routing prospects is not an Annex III use. It becomes high risk where the same system takes on an Annex III task, for example evaluating the creditworthiness of natural persons (Annex III point 5(b)) or assessing risk and pricing for life or health insurance (point 5(c)); those decisions then need the high risk controls.

A customer facing assistant must be designed so that people know they are interacting with AI (Article 50(1), applicable from 2 August 2026). It is not high risk as long as it does not carry out risk assessment and pricing in relation to natural persons in life and health insurance (Annex III point 5(c)).

Article 50(1): an assistant that talks directly with recipients must be designed so they know they are interacting with an AI system, unless that is obvious from the context. It is not high risk: explaining tracking, changing a delivery and taking in a parcel claim fall under none of the Annex III areas (it does not decide on public assistance benefits, creditworthiness, insurance pricing or employment), and it involves no practice prohibited by Article 5.

A customer facing agent must disclose that it is AI (Article 50(1)). It stays out of Annex III as long as eligibility for credit offers is decided upstream by the bank's own, separately governed credit processes; if the agent itself assessed creditworthiness it would be high risk under point 5(b).

A customer facing agent must disclose that it is AI (Article 50), unless this is obvious from the context. Travel insurance claims handling is not listed in Annex III; point 5(c) covers risk assessment and pricing in life and health insurance, not the handling of claims. Handing a traveller who reports a medical emergency to the assistance team is not the classification of emergency calls or the patient triage in point 5(d), as long as the agent only hands over and does not set medical priorities. Claim decisions based solely on automated processing are subject to GDPR Article 22 (and its UK equivalent), and medical data is special category data under Article 9.

Article 50(1) requires that readers know they are interacting with AI. Article 50(4) requires deployers to disclose AI generated text published to inform the public on matters of public interest, unless the content has undergone human review or editorial control and a person holds editorial responsibility. Whether answers generated on demand for a single reader count as text published to inform the public is open to interpretation, but they are rarely reviewed before readers see them, so the conservative choice is to label them.

An information assistant must tell people they are interacting with AI (Article 50). It is not high risk as long as it does not evaluate eligibility for public assistance benefits or services (Annex III point 5(a)); an assistant that starts to pre assess eligibility should be reassessed.

A taxpayer assistant must tell people they are interacting with an AI system (Article 50). It is not listed in Annex III as long as it only informs and applies fixed rules. It becomes high risk under Annex III point 5(a) if it evaluates eligibility for, or grants, reduces, revokes or reclaims, public assistance benefits (which can include benefits paid through the tax system). Recital 59 says systems used for administrative proceedings by tax and customs authorities are not high risk law enforcement systems; audit selection and risk scoring are covered on a separate page.

Drafting letters for human approval is not listed in Annex III. The decision the letter communicates may come from a separate high risk system, such as credit scoring (Annex III point 5(b)) or a public body's eligibility decision on benefits (point 5(a)); the drafting tool does not make that decision. Article 50(2) requires the provider of an AI system that generates text to mark the output as artificially generated, which puts this on the limited risk (transparency) tier; this includes an organization that builds its own drafting tool. Article 50(2) does not apply where the AI has only an assistive function for standard editing and does not substantially alter the input data or the semantics of the output.

A 311 assistant must disclose that it is AI (Article 50). It is not high risk while it only informs and creates service cases. If it evaluates or classifies emergency calls or sets dispatch priority for police, fire or medical services, it falls under Annex III point 5(d) and becomes high risk.

An internal drafting assistant that an official reviews is not listed in Annex III. Article 50(4) requires disclosure of AI generated text published to inform the public on matters of public interest, unless it has undergone human review and a person holds editorial responsibility, which this design provides. If the tool is used to evaluate eligibility for public assistance benefits or services rather than to draft, Annex III point 5(a) can apply.

Analysing complaints in aggregate to find causes is not listed in Annex III, is not a practice prohibited by Article 5 and does not decide on individuals. It does not interact with the public, so the disclosure duty in Article 50(1) does not apply; the machine readable marking of generated text in Article 50(2) is a duty of the provider of the generative model or system that writes the summaries. If the same system decided individual complaint outcomes or redress, or its themes were used to evaluate the performance of individual complaint handlers (Annex III point 4), that design would need its own assessment.

Tools that support staff in searching, deduplicating and proposing redactions are not listed in Annex III (point 5(a) covers eligibility for public assistance benefits and services, not access to documents), and every release decision stays with an officer. A public facing request assistant that talks to requesters would carry the Article 50(1) transparency duty.

Detecting mule accounts is fraud and AML detection by a private firm, which Annex III does not list; point 5(b) explicitly excludes systems used to detect financial fraud from the credit scoring category. Restricting an account based solely on an automated score can be a decision with similarly significant effects under GDPR Article 22, so keep a human decision and a route to challenge.

Organising and summarising consultation responses for analysts does not decide on individuals and is not listed in Annex III, so no high risk obligations apply. If AI generated text is published to inform the public on matters of public interest without human review and editorial responsibility, Article 50(4) requires disclosure.

Sanctions screening by banks and payment firms is not listed in Annex III: point 5 covers credit scoring and life and health insurance pricing, and point 6 covers AI used by or on behalf of law enforcement authorities. It is not a prohibited practice under Article 5, and as an internal tool it carries no Article 50 transparency duty. It still processes personal data at scale, so GDPR applies, and decisions that block a payment or freeze assets remain human decisions.

Transcribing and summarizing meetings for an employee is not a use listed in Annex III, and the advisor reviews every note before it is filed or sent. The tier would change if the tool inferred emotions: emotion recognition is high risk under Annex III point 1(c), and inferring the emotions of employees at work is prohibited under Article 5(1)(f). Both stay out of scope.

Scoring, blocking and labelling calls is not listed in Annex III, is not a prohibited practice under Article 5, and the system does not interact with people or generate content, so Article 50 does not apply. A conversational scambaiting agent such as O2's Daisy talks to callers with a synthetic voice, which raises separate Article 50 transparency questions and should be assessed on its own.