Telephone Recording Policy

AIPS Ltd records telephone conversations of calls from its central telephone system, it currently does not record the content of any telephone conversations outside of this system nor calls initiated as internal calls between extension users.

The telephone call recording system in operation can record all incoming and outgoing telephone calls and recordings may be used to investigate compliance with the Company’s quality standards, to support the investigation of complaints, to ensure that AIPS complies with regulatory procedures and to provide evidence for any regulatory investigation.

Communicating the Call Recording System

AIPS Ltd is required to make reasonable efforts to communicate that calls will be recorded. This will be done by:

  • Publishing this policy on the AIPS website;
  • Advising all callers via auto-attendant when calling the main office number

Procedures for managing and releasing call recordings

1.  The recordings shall be stored securely, with access to the recordings controlled and managed by the Directors and Departmental Managers.

2.  Access to the recordings is only allowed to satisfy a clearly defined business need and reasons for requesting access must be formally authorised by the relevant Manager or the Managing Director. All requests for call recordings should include the following:

  • The valid reason for the request.
  • Date and time of the call if known
  • Telephone extension used to make/receive the call.
  • External number involved if known.
  • Where possible, the names of all parties to the telephone call.
  • Any other information on the nature of the call.

3.  All requests for access to call recordings will be dealt with as a subject access requests.

4.  Browsing of recordings for no valid reason is not permitted.

The Data Protection Act allows persons access to information that we hold about them. This includes recorded telephone calls. Therefore, the recordings will be stored in such a way to enable the Data Protection Officer to retrieve information relating to one or more individuals as easily as possible.

5.  Requests for copies of telephone conversations made as Subject Access Requests under the Data Protection Act must be notified in writing to the Data Protection Officer immediately and, subject to assessment, he/she will request the call recording and arrange for the individual concerned to visit AIPS Ltd’s offices to hear the recording.

Access by Data Subjects

A data subject may make a subject access request (“SAR”) at any time to see the information which the Company holds about them.

  • SARs must be made in writing, accompanied by the correct fee.
  • The Company currently requires a fee of £10 with all SARs.

1.  Upon receipt of a SAR the Company shall have a maximum period of 40 days within which to respond.

2.  In the case of a request from an external body in connection with the detection or prevention of crime e.g. the police, the request should be forwarded to the Data Protection Officer who will complete the request for a call recording.

3.  Requests for copies of telephone conversations as part of staff disciplinary processes will only be released with the written agreement of the Managing Director or the General Manager who will consult with the Data Protection Officer before approval is granted.

4.  Recordings of calls will be kept on file and periodically archived to external hard drives and stored in accordance with our data storage policy.

This Policy has been approved & authorised by:

Name:Helen Ahluwalia
Position:Operations Director
Date:1st December 2012

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