AI Meeting Capture

Guideline for Non-Academic/ Non-Class Meetings:

These guidelines apply to capturing meeting content by any automated or technical means including recording the meeting, using AI assistants (e.g., Zoom AI Companion, Otter.ai, Teams), or enabling transcriptions.

I. General Guidelines for Capturing Meetings

Nature and purpose of meeting
1. Users are advised to consider the nature of their meetings before capturing them. It is not advisable to capture all or even most meetings. These create unnecessary records and obligations related to retaining and managing them; they take up storage space; they expose individuals to significant privacy and security concerns; they may chill open communications; they may be subject to public records requests; and they may implicate labor rights. Recording meetings should generally be an exceptional occurrence and should be announced to the meeting attendees.
  1. Capturing of meetings may be allowed:
    1. Where required by law, such as for documented accommodations authorized by Accessibility Resource Center (ARC) and/ or Compliance Ethics and Equal Opportunity (CEEO),
    2. For training and professional development programs where a recording, summary, or transcript will be made available to attendees for their own learning, and
    3. Where, after being given a meaningful opportunity to object, all participants have affirmatively and freely consented (see Section III A below).
2. Except where there is an authorized and documented accommodation:
  1. Capturing of meetings is prohibited for meetings where high or medium-risk data (e.g., health information, financial or loan information, undocumented student data), or certain sensitive (e.g., attorney-client privileged dialogue, animal research protocols, student conduct deliberations) are discussed.
  2. Use of AI assistant features is prohibited for meetings where identifiable sensitive human subjects research is discussed, except where the use of AI is part of the research project or there are approvals from the ISPO and the IRB
3. Deans, Directors, and Chairs may develop internal policies and procedures restricting the use of AI features, and likewise may limit use to only Low risk data.
4. The UNM community is advised to use extreme caution when capturing meetings where other medium or high-risk personal information (research planning, IRB deliberations, HR decisions (hiring, firing, succession planning) is discussed.
5. Attendees of meetings hosted by an organization outside of UNM should be advised that the policies and procedures of the other organization govern the Meeting, including notification and ability to object. High and medium risk data may not be discussed while attending hosted by another organization where AI features are enabled or, where the meeting is being captured.
Authorized Users and Uses
1. All users must adhere to vendor terms of use, UNM policies, information security standards, and all laws and regulations when using AI Tools. It is every user’s obligation to understand and abide by these requirements and by university guidelines.
2. Individuals with authorized and documented accommodations may capture meetings in accordance with their accommodation. However, they are not authorized to distribute the output or use the output for any other purpose than their own personal accommodation needs.
3. Other than individuals with accommodations, only the meeting host is authorized to capture meetings. The host must review transcripts and summaries for accuracy in a timely manner before disseminating them to others. These records may be subject to legal preservation requirements
4. Individuals may not “send” an AI assistant to “attend” a meeting on their behalf when the individual is not also present. No one may require individuals to “send” an AI assistant to “attend” on the absent individual’s behalf. Hosts are required to remove AI assistants that are in meetings without their users

II. Privacy and Data Security Considerations

Nature and purpose of meeting
1. Captured meetings are university records and are therefore subject to request under the Inspection of Public Records Act.
2. Captured meetings, including those for accommodations, must be maintained at the appropriate security level for the sensitivity of the data.
3. Access to captured meeting outputs should be limited to those who have a strict need and right to know the information.
4. Output of captured meetings (e.g., videos, summaries) may not be saved on personal devices (i.e., non-UNM-issued) and must only be stored on UNM-approved services (e.g., in UNM SharePoint, Teams, Kaltura (via Canvas or via https://mediaspace.unm.edu, and not in one's personal account), unless capture is associated with an authorized accommodation.
5. Captured meetings must be maintained in accordance with the UNM Record Retention Schedule and deleted only in accordance therewith.
6. Where a meeting will be captured, individuals must be provided the options to mute audio and turn off video.
7. High and medium risk data may not be discussed while AI features are enabled for the meeting, including a meeting hosted by another organization.

III. Notification and Consent Requirements

Except in cases where advance notice is not possible due to an authorized disability accommodation, meeting host must
1. Provide advance notice, where possible, to all participants that the meeting will be captured and include the notice at the top of the calendar invitation;
2. Provide a meaningful opportunity to object before the meeting. A meaningful opportunity exists where:
  1. The participant had advance notice that the meeting would be captured and given the opportunity to object without pressure, coercion, or negative consequences, or
  2. The participants are given the opportunity at the start of the meeting to object without pressure, coercion, negative consequences, or without having to leave the meeting. Note that the automated message that appears at the beginning of captured Zoom meetings does not constitute a meaningful opportunity to object by itself, because individuals who object must leave the meeting. Individuals may not object to capturing of meetings where a documented disability accommodation exists (see Section III C below).
3. Remind attendees that the meeting will be captured at the beginning of the meeting.
Except where there is an authorized disability accommodation, if a meeting participant objects to capturing by the host, the meeting may not be captured, and the host must disable AI features if a meeting participant requests that features be turned off while presenting or asking questions.
Where a meeting host does not intend to capture the meeting or there is an unknown AI assistant present in the meeting, the host must advise all participants at the beginning of the meeting that AI assistants not associated with the host are only authorized for disability accommodations, not for any other purposes, and request any non-disability related AI assistants to leave the meeting.
A user’s refusal to participate in a meeting with AI features enabled should not, by itself, be the subject of an adverse employment action.

IV. Specific Considerations Regarding AI Tools

Individuals may only use AI Assistants that have
1. Had risk assessments completed by UNM ISPO
2. Had approvals from appropriate data stewards, where applicable
3. Have a written agreement in place (i.e., contract, Master Services Agreement) that enforces UNM’s terms and conditions, as well as UNM’s privacy and security obligations.
Some AI assistants collect and retain all information presented in meetings, including biometrics such as voices, which can be used to train the AI, or which can be shared without authorization outside the organization. These should not be used except where an authorized disability accommodation exists that non-AI tools cannot address.