It is nine in the evening, the other side’s pleading runs to sixty pages and the hearing is on Thursday. Pasting it into a chat and asking for a bullet summary takes twenty seconds and saves two hours. It is a thing people in a law firm do without stopping to think, which is exactly why it is worth looking at what happens while it is being done.
Disclosure does not need an audience
Article 622 of the Italian criminal codeopens in a new tab punishes anyone who, knowing a secret by reason of their profession, discloses it without just cause where harm may follow: up to a year in prison or a fine of 30 to 516 euro, prosecuted on the complaint of the injured party.
The word people stop at is “discloses”. It sounds like telling someone, and a text box does not look like someone. On the other side of that box, though, there is a company, with employees, logs and terms of use: the text has been communicated to a third party, which received it, kept it for as long as it decides to, and depending on the contract used it for training. That the third party is a program does not remove the company standing behind it.
The fine, incidentally, is the negligible part. The harm the offence requires is the same thing that ends a client relationship and starts a claim, and that one has no 516 euro ceiling.
The bar does not wait for a complaint
The Italian code of conduct for lawyersopens in a new tab gets there first and from a different direction. Article 13 binds the lawyer to strict professional secrecy and the greatest reserve about facts learned while representing and advising a client; Article 28 restates it as both a duty and a primary right, and adds the part people forget: the obligation survives the retainer, including a retainer that was completed, given up, or never accepted.
The sanction starts at a reprimand and reaches, in serious cases, suspension of one to three years. Nobody has to file a criminal complaint, and the client does not have to have noticed anything: disciplinary proceedings also start from a report by the other side.
Secrecy is not only the signing lawyer’s
The duty in the code of conduct does not stop at whoever holds the retainer: the lawyer has to have it observed by their collaborators, their employees and anyone in the office for their training period. The GDPRopens in a new tab reaches the same conclusion by a different and harsher route: it does not look at who pressed enter, it looks at who the controller is. A trainee pasting a pleading into a chat at nine in the evening is not exposing themselves, they are exposing the firm.
This is not a hypothetical. In the case decided by the Court of Florence (a filing citing judgments that did not exist, generated by ChatGPT), counsel stated that the citations came from research done by an associate in the office, whose use of artificial intelligence they had not been aware of. That sentence matters more than the ruling: in front of the judge it was not a defence, it was an admission that the office had no rule.
The practical consequence is short. A rule that lives in the principal’s head exists for the principal and for nobody else; for it to exist for everyone it has to be written down, it has to say which tools may be used with which documents, and it has to be read by whoever joins. One page is enough, and one page is also the only length anybody actually reads.
Then there is the regulation, the only one that asks you to prove it
The firm is the controller of its clients’ data. Pasting a filing into an outside service is processing: it needs a legal basis, a relationship with that supplier, an assessment of the transfer outside the Union where the supplier sits outside it, and measures appropriate to the risk under Article 32.
What separates this from the first two is the direction of proof. In criminal and disciplinary matters somebody has to show you were wrong; under the GDPR you have to show you were right, which is the accountability principle in Article 5(2). To the question “what measures did you take before handing that document to a third party”, the answer “I read it first myself” is not a measure.
The measures the regulation recognises have a known shape, and none of them is an intention. The processing goes into the Article 30 record with its purpose, its legal basis and its recipients; the supplier is appointed processor under the Article 28 agreement; a transfer outside the Union rests on one of the Chapter V instruments; and where the processing is large scale or touches special categories, the Article 35 impact assessment applies. Which of these actually bite depends on how the tool is configured, and it is the first place where a technical choice shortens a list of obligations.
Three questions to ask before you paste
Everything above compresses into a twenty-second check, which is roughly the time available at nine in the evening. Three questions, in this order.
One: is there anything in this text that leads back to a person? Not “is there a name”: is there a tax code, an IBAN, a docket number, a date of birth, an address, a land registry reference. If the answer is yes, the text does not leave as it stands.
Two: does the question I am about to ask need that value? Almost never. “Summarise in bullets”, “find the preliminary objections”, “is this deadline mandatory” are questions about the shape of a text and about the law, not about the people in it. If the answer is no, the value gets substituted and there is nothing else to decide.
Three: when the answer comes back, can I put the real values where they belong? This is the question that separates useful work from an exercise: a summary full of placeholders that somebody then has to retype by hand has consumed the time it was meant to save.
Since 2025 there is also a duty to say so
Since 10 October 2025 a fourth rule sits on top of the three above: Article 13 of Italian Law 132/2025opens in a new tabrequires the professional to tell the client that they use AI systems (what exactly it asks for is here).
It is the only one of the four that changes something even for people who had done nothing wrong. While using the chat was a matter between the lawyer and themselves, saying nothing was not an omission; now that informing is a duty, not having done it is one more thing to explain, and you explain it to a client who has meanwhile worked it out on their own.
What remains is taking the data out first, not afterwards
None of the rules above bans the tool. They ban handing a client’s data to a third party, which is a different thing. A summary of sixty pages in which the parties are called [FULLNAME_1] and [FULLNAME_2] is exactly as useful as the other one, because what you need is the shape of the arguments, not the names.
The condition is that the substitution happens before the text leaves, on the firm’s own machine. An online service that anonymises on your behalf saw the document in the clear in order to anonymise it, and at that point you have two suppliers instead of one. That is why Omissia works locally: the analysis, the model that recognises the values and the mapping between placeholders and real names all stay on the machine, encrypted with the system keychain, and the mapping disappears when the case file does.
What exactly has to come out of a filing is in the piece that lists the values, and what still identifies a file after the names are gone is in the one about metadata.