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Every client meeting your firm records now leaves four things behind: the audio or video, a transcript, an AI summary and (if someone does the job properly) a file note. Most firms have a retention rule for none of them. The default is “the notetaker keeps everything forever”, which is the one setting no privacy law in any of our six markets is comfortable with.

The fix is simpler than it looks. The file note is the record you keep. The raw recording is a working file you delete. This guide sets out why, what the record-keeping rules in AU, the UK, the US, NZ, Canada and South Africa actually require (as at October 2026), and how to turn that into a schedule your team can follow.

Four artefacts, one record

  • The recording (audio or video). The most complete and the most sensitive. It is personal information, and usually nobody plays it back.
  • The transcript. Searchable and close to verbatim, so it carries most of the recording’s privacy weight.
  • The AI summary. A machine’s reading of the conversation. Handy, but it can be wrong, and nobody at the firm has signed off on it.
  • The file note. The firm’s own record of what was discussed, what was advised, what the client decided and what happens next, reviewed by the person responsible for the advice.

In Australia the Tax Practitioners Board spells out what that record needs. Under section 30 of the Tax Agent Services (Code of Professional Conduct) Determination 2024, registered agents must keep records of the tax agent and BAS services they provide for at least 5 years, showing the nature, scope and outcome of the service, the information considered, advice given to and received from the client and, for complex matters, the facts, assumptions and reasoning behind the advice (TPB guidance). That describes a good file note. It does not describe a 50-minute MP4.

So the retention question splits in two. The file note inherits the longest record-keeping period that applies to the engagement. The recording and transcript inherit the privacy rule: keep them only as long as you need them.

The periods that bite, by market

None of the tax periods below were written with recordings in mind. They govern the records behind a return or a service, so they attach to your file note. The privacy rules govern the raw media.

MarketRecord-keeping period (file note and engagement records)Privacy rule on the raw media
AustraliaATO: generally 5 years. TPB Code s30: 5 years after the service. AML/CTF (tranche 2 services from 1 July 2026): 7 years for most records.APP 11.2: take reasonable steps to destroy or de-identify personal information no longer needed.
United KingdomHMRC: 5 years after the 31 January filing deadline for self assessment businesses, 6 years from the end of the accounting period for companies. MLR 2017 reg 40: 5 years after the business relationship ends.UK GDPR Article 5(1)(e), storage limitation. MLR reg 40 also requires deletion of the CDD personal data once its period ends, subject to exceptions.
United StatesIRC s6107(b): preparers keep a copy or list of returns for 3 years after the close of the return period. State boards of accountancy set their own workpaper periods.FTC Safeguards Rule, 16 CFR 314.4(c)(6): dispose of customer information no later than 2 years after it was last used, unless an exception applies.
New ZealandTax Administration Act 1994 s22: 7 years after the end of the income year (extendable by up to 3 years under audit).Privacy Act 2020 IPP 9: do not keep personal information longer than required for its lawful purposes.
CanadaCRA: generally 6 years from the end of the last tax year the records relate to.PIPEDA Principle 4.5.3: destroy, erase or anonymise personal information no longer required.
South AfricaTax Administration Act s29: 5 years from the date the return was submitted.POPIA s14: do not retain records longer than necessary for the purpose, unless law, a lawful purpose or consent requires it.

Three notes on the table. First, Australian AML/CTF obligations depend on whether your firm provides a designated service (company and trust structuring, handling client money and the like); AUSTRAC’s tranche 2 guidance runs the 7 years from when the relationship ends or the transaction completes; our AML risk assessment template helps you check whether you are in scope. Second, the Australian Privacy Act has a small business exemption with its own exceptions, so check whether it covers your firm before you rely on it in either direction. Third, the US workpaper rules vary by state and by service (attest work is usually longer than tax prep), so read your own board’s rule rather than a national average.

The pattern across all six: the regulated record is the advice record, and the privacy regulators want everything else gone once it has done its job. Nothing in the tax or AML rules above requires you to keep a raw recording, provided the file note captures what those rules ask for.

How long you can keep a recording also depends on what you told the client when you made it. If your engagement letter or the meeting invite says “we record meetings to produce accurate notes”, the purpose is the note. Once the note is approved, the purpose is spent, and the privacy rules in every market above point to deletion.

Keeping raw audio “in case it’s useful” for training, marketing or a future dispute is a new purpose you didn’t disclose. Consent to record also varies: some US states require every party to a call to agree. Put the purpose, the retention period and the client’s right to ask for deletion in the engagement letter, so the client knows before the first call. Our client AI data checklist covers what may go into an AI tool in the first place.

A retention schedule that works

Rather than a single number, set tiers. The periods below are a method, not a legal minimum: test each one against your own markets, services and insurer.

  1. Raw recording: short. Keep it until the file note is reviewed and approved, plus a short buffer for queries. A window of 7 to 30 days is a sensible place to start testing. If nobody listens back within a month, nobody will.
  2. Transcript: medium. Keep it while the work it relates to is live (the return is lodged, the advice is implemented, the client has signed off), then delete. For most engagements that’s weeks to a few months, not years.
  3. AI summary: same as the transcript, or fold it in. Once its useful content is in the file note, it has no separate job. Don’t let it become a second, unreviewed record that contradicts the first.
  4. File note: with the engagement records. Store it in your practice management system against the client and the job, and give it the longest period that applies: 5 years for an Australian tax agent service, 7 years where AML/CTF or NZ tax rules apply, 6 in Canada, and so on. The clock usually starts when the service ends or the relationship ends, not when the meeting happened.

Write the schedule into your AI policy so it covers every recording tool the firm uses.

Deletion stops the moment you know of a complaint, a fee dispute, a regulator’s inquiry, an audit or a likely claim. Every rule above carves out records needed for legal proceedings or required by another law. Name one person (usually the practice manager or a partner) who can place a hold, record the date and the reason, and lift it when the matter closes.

Prove the deletion

Keep a simple log: the setting in each tool, when it was configured, who checked it, and a quarterly spot check that old recordings are actually gone, including from downloads and shared drives.

What to ask your notetaker about deletion

Whichever tool you use, get written answers to these before it records another client:

  • Can the firm (not each user) set separate retention periods for recordings, transcripts and summaries?
  • Does deletion remove the file from backups, and how long do backups persist?
  • Is client data used to train the vendor’s models, and can that be switched off at firm level?
  • Can you place an individual client or meeting on hold so the schedule skips it?
  • Can the approved note be pushed into your practice management system, so the record lives with the job and not in the notetaker?
  • What happens to everything if you cancel?

That last-but-one question matters most, because it decides whether deleting the recording loses anything. Some tools built for accounting firms do this; Vinyl, for example, files the meeting note into the client record in the firm’s practice system and lets the firm set how long recordings are kept. For a wider view of the category, see our guide to AI meeting assistants for accounting firms, and for the security questions, is AI safe for client data?

This is general information, not legal advice. For your firm’s position, check with your privacy regulator (the OAIC, ICO, NZ Privacy Commissioner, Office of the Privacy Commissioner of Canada or South Africa’s Information Regulator), the TPB, AUSTRAC or HMRC, your state board of accountancy, or your professional body.

Frequently asked questions

Do we have to record client meetings at all?

No rule in these six markets requires a recording. The obligation is to keep an adequate record of the service and advice, and a reviewed file note meets it.

Is a transcript enough to count as our file note?

Usually not on its own. A transcript shows what was said but not what the firm concluded, what was advised in final form or what the client decided,. Use it as source material and write the note from it.

A client asks us to delete their recording. Can we?

Generally yes, if no legal hold or retention law requires you to keep it. Deleting the recording does not mean deleting the file note, which you hold under record-keeping rules.

What about recordings we already have from the last two years?

Write file notes for any meetings that lack one and matter (advice given, disputes possible), then apply the new schedule to the backlog in one documented clean-up. Check for open holds first.

Does the same schedule apply to internal team meetings?

The privacy logic is the same, since staff voices are personal information too, but there’s no client engagement record to protect. A firm can usually keep internal recordings for an even shorter window and keep only the decisions and actions.

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