In Chile, the operation of attorney-client privilege does indeed vary across different legal contexts, though the fundamental principle of protecting confidential information remains consistent. In general, criminal proceedings and investigations enjoy broader and explicit protection that is not as clearly present in civil or regulatory proceedings.

In civil litigation, privilege operates through article 360, No. 1 of the Code of Civil Procedure, which allows attorneys to refuse to testify about "facts that have been communicated to them confidentially in connection with their profession." This protection extends to document production, as article 349 of the Code of Criminal Procedure protects "secret or confidential documents" from being disclosed in a request for exhibition of documents.

Criminal proceedings offer the most comprehensive framework for privilege protection. The Code of Criminal Procedure establishes multiple layers of protection, including witness testimony (article 303 of the Code of Criminal Procedure), protection of documents and objects from seizure (article 220 of the Code of Criminal Procedure) and communication interceptions (articles 222 and 223 of the Code of Criminal Procedure).

In regulatory contexts, privilege generally operates through cross-references to existing rules in civil and criminal regulations. For example, in competition law matters, the National Economic Prosecutor's investigative powers are explicitly limited by reference to criminal procedural protections, including attorney-client privilege (article 39(n) of Law Decree 211). Similarly, testimony before the Competition Tribunal follows civil procedural rules (articles 22 and 29 of Law Decree 211) that maintain the procedural immunity granted by the Code of Civil Procedure.

There is no specific development in Chilean law for notes of interviews produced during investigations. Generally, only criminal investigations have clear and explicit regulation, protecting documents and objects that contain privileged information from being seized (article 220 of the Code of Criminal Procedure).

This protection extends to physical communications between the investigated individual and their lawyers (also including people that "have the duty to keep the secret that has been entrusted to them," specifically including doctors and "confesors"). This includes the notes that they have taken of said communications, objects and any other circumstance that can naturally be included in the right to abstain from presenting testimony.

In this regard, notes of interviews with employees may be covered by privilege in criminal investigations if they can be considered part of the right or faculty to abstain from presenting testimony, for instance, when the employee has performed legal services for their employer. This may also be the case in regulatory matters if they are expressly regulated by reference to criminal law, as is the case with antitrust or anticompetition investigations under Law Decree 211.