Guide

Ten questions before client data goes near an AI tool.

Every week brings another AI product for advisers. Most demos are impressive. The differences that matter — where data lives, what the tool can do without you, what happens when you leave — rarely make the demo. Here are the ten questions that expose them.

Data first

1. Where does processing happen? On your machine, in a UK/EU cloud, or on US infrastructure? This single answer drives your GDPR position, your client agreements, and your breach exposure. "It's encrypted" is not an answer to this question.

2. Is client data used to train anything? Get it in writing. "We may use data to improve our services" in the terms means yes.

3. What leaves, and when? Even locally-installed tools may call cloud models. Ask exactly what is transmitted, to whom, and whether it's optional.

4. What happens when you cancel? If the answer to "can we have our data back and confirm deletion?" is complicated, so is your exit.

Cloud AI tool Your firmclient data Vendorcloud Data leaves the firm to be processed Breach surface, DPAs, transfer questions Edge-installed tool Your machinedata + processing together The software comes to the data Nothing to hand over, nothing to leak
Question one on the checklist — where does processing happen? — decides most of the rest.

Control second

5. Can it act without you? A tool that drafts is an assistant; a tool that sends is a liability with your name on it. Insist on a hard boundary: nothing reaches a client without an adviser's review.

6. Is there a record? Every action the tool takes should be logged — what it read, what it produced, when. Under Consumer Duty, an unlogged assistant is an evidencing gap you installed on purpose.

7. Who in the firm sees what? Multi-adviser firms need answer-level clarity: does adviser A's client history surface for adviser B?

Fit third

8. Does it work with what you have? A tool that ignores your back office creates a second system of record — which is how files drift apart. Ask about integration honestly: reading, writing, or marketing-slide-only.

9. What does failure look like? Ask the vendor what the tool does when it isn't sure. The good answer involves saying so and stopping, not guessing fluently.

10. Who is accountable? The FCA's position is settled: you are. Any vendor implying their tool shifts responsibility for suitability or communications has told you what they don't understand about your business.

Reading the answers

Straight answers to all ten in plain English is itself the signal — the vendors who've thought about UK advice firms answer without flinching. Where you hear hedging on questions 1, 5, or 6, the product was built for a different market and is being sold into yours.

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