Call Recording Policy
Introduction
This policy outlines EDClass Limited's call recording process. The purpose of call recording is to provide a record of incoming and outgoing calls which can:
- Identify EDClass' staff training needs
- Protect EDClass' staff from nuisance and abusive calls
- Establish facts relating to incoming/outgoing calls made (e.g. complaints)
- Identify any issues in EDClass' processes with a view to improving them
Purpose
The purpose of this policy is to ensure that call recording is managed in line with GDPR and Data retention requirements. This will generally involve the recording of telephone conversations which is subject to the Telecommunications Act 1984.
EDClass will make every reasonable effort to advise callers that their incoming call may be recorded and for what purpose the recording may be used. This is done via an auto-respondent message within the telephone system and in our policy on our website. Any outgoing calls will also be recorded and EDClass' staff will make every reasonable effort to notify callers of this. The voice file will be stored within a recording system to which the same rules of confidentiality apply.
Where a request is made to listen to a recording then this should be allowed within the general provisional data subject access under the Data Protection Act 2018.
Scope
This policy applies to all EDClass staff including any contracted or temporary workers. All calls via the telephone systems used within the company will be recorded, including:
- All external incoming calls
- All external outgoing calls made by EDClass staff
- All external call transfers
Recording will automatically stop when an EDClass staff member terminates the call.
Playback/monitoring of recorded calls
Monitoring of the call recordings will be undertaken by any Authorised Personnel. Any playback of recordings will take place in a private setting and where applicable, individuals should be given the opportunity to listen to relevant recordings to receive feedback and developmental support.
All recordings will be stored securely on the BT Cloud Voice Call Recording system, and access to these will be controlled and managed by any Authorised Personnel.
Recordings will be accessed by logging in to a dedicated, password-protected online system.
Calls will be retained by EDClass for a period of 30 days unless downloaded for complaints, allegations or any other reasons where the file is needed.
Confidentiality
The Data Protection Act allows access to information that is held about an individual and their personal data. This includes recorded telephone calls.
Requests for copies of telephone conversations can be made under the Data Protection Act as a “Subject Access Request”. After assessing whether the information can be released, the requestor can be invited to EDClass' premises to hear the recording. The right to be forgotten does not override legal and compliance obligations.
If there is a request from an external body relating to the detection or prevention of a crime (e.g. police), then requests for information should be directed to any Authorised Personnel. Under GDPR, organisations are prohibited from recording the personal conversations of staff, even with consent, and therefore need to ensure that while business calls are recorded, personal calls always remain private.