If a client voluntarily uploads their own tax documents into a client-facing AI tool (like Stanford Tax), does that count as the firm's 7216 disclosure, or does the firm still need separate consent?

A member raised this as an open question: when clients are invited to upload documents into a portal/binder tool that uses AI (using Stanford Tax as an example), and the client is the one voluntarily putting documents in, does that sidestep the firm's own 7216 disclosure obligation? The group's tentative reasoning was that 7216 governs practitioners/professionals, so if the client is voluntarily disclosing their own information to a tool, that might not trigger the same requirement—unless the firm goes further and discloses additional information beyond what the client put in. However, a complicating scenario was raised: if firms require clients to use such tools as a condition of being a client (a "square peg in a round hole" mandate), and additional data flows downstream to other AI tools (e.g., data shared with "carbon"), it's unclear whether the firm still gets the benefit of that voluntary-disclosure argument. No definitive answer was reached, and the group flagged it as something to research further.