A communications team wants a short onboarding video in two languages. It can use a stock avatar with a cleared script, or make a digital version of an employee who appears to deliver the message. The second option leaves the company with a reusable likeness, access permissions and videos that may survive the employee's departure. Approve the pilot only if someone can account for those assets and stop further use.
Start with one approved script, one named audience and a short review period. The example below is hypothetical. The HeyGen safety guide covers the broader vendor review. This walkthrough focuses on the decision to create, release and retire one employee avatar.
Decide whether the employee's likeness is needed
Run the first rehearsal with a stock avatar and public or synthetic text. Show the business owner the result and ask what the employee's likeness would add. If a recognizable presenter matters, document the reason, audience, languages and end date. Keep customer names, employee records and unreleased figures out of the script unless the relevant data owner has separately approved the workflow.
HeyGen documents a recording by the depicted person for each video-based Digital Twin. Your organization still needs a separate decision about who may use that likeness and for which scripts, channels and languages. If GDPR applies, have the privacy owner assess the legal basis and whether an impact assessment is required. The European Data Protection Board highlights how the power imbalance in an employment relationship can undermine freely given consent. Offer a practical alternative that does not require the employee's likeness. HeyGen consent recording instructions · European Data Protection Board guidance · GDPR text
Give each asset an owner and an exit condition
The project owner should be able to point to the system holding each artifact and the person who can stop access or use. Use a register like this before recording anyone.
| Artifact | Who should control it | What to verify before release |
|---|---|---|
| Original footage and voice sample | Recording lead and designated editor | Record where originals and uploads live, who can retrieve them, and when each copy is due for removal. |
| Consent recording and internal authorization | Privacy or people team | Protect access to the evidence and record the approved purpose, languages, audience and withdrawal contact. |
| Reusable avatar, looks and voice | Named workspace administrator | Record the asset IDs, permitted users and how to block generation or sharing. Test those restrictions with an ordinary member account. |
| Script, translated text and draft video | Communications editor and reviewer | Tie sign-off to a script version and a specific render. Review translations and any claim the avatar appears to make. |
| Downloaded video and copies in other systems | Owner of each publication channel | Record the file or asset ID, destination, audience, expiry and removal owner. Include the learning platform and shared drives. |
Review the vendor's biometric notice alongside the register. HeyGen describes different purposes and retention rules for biometric information derived for avatar creation, identity verification and model training where applicable. Ask which are in scope for your workflow and region. Give raw media, derived data, reusable assets and exports separate retention entries. HeyGen biometric privacy notice
Check the contract and workspace separately
Record the product surface, plan, workspace and applicable agreement. HeyGen's privacy policy describes processing on customer instructions for activities such as generating and hosting content, and separate controller purposes such as account administration and model training. Map the activities that matter to the pilot. Have the privacy or procurement owner check which personal data the applicable DPA covers, who processes it, where transfers occur, and how rights requests and deletion would be handled. HeyGen privacy policy · HeyGen data processing addendum
HeyGen states that Enterprise customer data is excluded from training by default and that the customer agreement governs training restrictions. Keep the relevant terms and evidence of the actual workspace with the approval. For retention, check whether any addendum applies to the workspace and content type. HeyGen describes its configurable retention program for covered new API content after activation. Reusable avatars and voice clones sit outside that window, and qualifying reuse can restart the clock for covered content. A missing asset in the interface or an API response only establishes that the asset is unavailable through that path. Record what evidence you would need for backend deletion separately. HeyGen enterprise compliance and retention documentation
HeyGen's Enterprise settings document controls for custom avatar creation, default avatar visibility, look and voice access, downloads and public publishing. Confirm which controls your plan exposes and record the actual settings. With cleared test material, have an ordinary member attempt to generate with a restricted avatar, download a video and open a share link from outside the intended audience. If an integration can generate or export, include its identity and permissions in the same test. Check existing shares separately when you tighten a default. HeyGen Advanced Enterprise Settings
Approve the render and rehearse withdrawal
Assign a reviewer who can send the video back to the editor. Review the exact render, each language version, its destination and audience, and any required notice about the use of synthetic media. Record the release decision against that version. Require fresh approval for a new script, language, external channel or purpose. If the workspace cannot enforce the handoff, keep export with a named publisher and record which account can release the file.
Before using a real employee's likeness, rehearse a withdrawal or departure with disposable test material. Name the person who receives the request and the administrator who can stop generation. Have channel owners locate and remove a test export from each approved destination. Record when access was blocked, which copies were removed, any copies the organization cannot retrieve, and which provider requests remain open. Use the same register to track any documented retention or legal hold. An internal learning system and a publicly downloaded video call for different recovery plans.
Make the pilot decision
Approve only the use you can describe in one sentence, such as one internal onboarding video in two reviewed languages, served through a named learning platform until its scheduled review. Keep the signed decision, account settings, test results, version approval and export register together. Hold the employee-avatar pilot if you cannot explain who can reuse the likeness, confirm the applicable data terms or identify someone who can take every approved channel offline. The team can still evaluate production quality with a stock avatar and cleared script.
Aeon's AI confidentiality assessment can help map the footage, scripts, reusable assets and exports to owners and controls before rollout. Where script preparation involves restricted material, a private AI fit assessment can help determine whether that step should stay in a more controlled environment.