Call Recording Policy

Policy Purpose: 

The purpose of this policy is to govern the procedures for telephone call recording within Kenny Waste  Management Limited (the Company), and the management of access to, and use of, the recordings.  The policy aims to minimise intrusion by restricting the recording of calls, the access to, and use of  these recordings to limited and specific purposes. 

Legislation: 

The recording and monitoring of telephone calls is affected by several items of legislation, in particular:  

• Human Rights Act 1998 
• Data Protection Act 2018 (GDPR) 
• Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations  2000 (LBP Regulations)  
• Telecommunications (Data Protection and Privacy) Regulations 1999 
• Payment Card Industry Data Security Standards (PCI DSS) 
• ICO Employment Practices Code 

Recording Information: 

Kenny Waste Management telephony system is capable of recording calls using Horizon Business Call  Recording and are encrypted using AES-256. 

Although not all calls will be automatically recorded, it should be assumed that they are as all company  telephone lines have the function to save a recording of the call. An example of when a call may not be automatically recorded is when dialling a member of the HR department. Calls to company mobile  phones will not be recorded.  

Call recordings where the caller provides details of a payment card for the purposes of making a  payment to Kenny Waste Management will be manually paused in order to comply with Payment Card  Industry Security Standards (PCI DSS). The recording will then be reconvened once the payment details  have been processed.  

Purpose of Call Recordings: 

Calls are recorded and retained for the following purposes: 

• To monitor the quality of call handling and customer service and to ensure the information  we provide is consistent and accurate. 
• Staff training, coaching and support 
• To verify what was discussed within the call should a dispute or complaint arise 
• To protect staff from abusive behaviour 
• To verify the customers agreement during certain service requests

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• Calls may also be used as evidence within an investigation should a misconduct,  performance, or capability concern arise.  
• To verify the details of the call for the purposes of, or in connection with, any legal  proceedings 

Retention and Storage of Call Recordings: 

All call recordings will be retained for a period of 6 months on the Horizon Call Recording system in  AWS. This system is also BS10008 compliant in addition to ISO27001, ISO22301 and Cyber Essentials. All recordings will be deleted after 6 months, unless retained for a specific business purpose.  

Access to Call Recordings: 

Access to call recordings are controlled in line with principles under Data Protection legislation and is  limited to the Customer Service Manager, Executive Assistant to the Board (General Data Protection  Regulations Representative), and the Board of Directors. Should any other employees of Kenny Waste  Management require access to call recordings, permission to access must be granted by the Board of  Directors, and for non-employees via a Subject Access Request. 

Call recordings can be obtained by Line Managers for training and quality assurances purposes.  Specific call recordings may be accessed by Line Managers, HR or any Disciplinary Hearing Panel as  evidence in relation to any disciplinary process. In these cases, requests for access must be made in  writing for authorisation from a Company Director.  

In the case of a request from an external body with law enforcement powers in connection with the  prevention, detection, or investigation of crime e.g., the Police, Home Office, DWP, HMRC etc. the  request must be made in writing to the Board of Directors who will consider the request. 

The UK Data Protection legislation 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  General Data Protection Regulations Representative to retrieve information relating to one or more  individuals as easily as possible. 

Any unauthorised access of call recordings may lead to disciplinary action. Browsing of recordings for  no valid reason is not permitted. 

Advising of the Call Recording Facility: 

Kenny Waste Management will make every reasonable effort to communicate that calls will be  recorded. This will be done by: 

• Employee’s informing the caller when call recording facilities are being used 
• Using a recorded message with the auto attendant facility to inform callers that their call is  being recorded  
• Reminding the caller that the call is being recorded should they be displaying abusive  behaviour and that the calls contents may be reviewed by management 
• The Call Recording policy is published on the Kenny Waste Management website.