This policy applies to telephone calls made and received by FISC Limited, FISC Global CY Limited or any associated trading brands such as TRACS™, eMaster™ or any others from time to time (“we”, “us” or “our”) from its central telephone system.
It sets out the basis for how Call Recordings are managed and utilised in accordance with necessary legislative requirements and how we protect and respect privacy and personal data.
- PURPOSE OF CALL RECORDING
The telephone call recording system in operation can record all incoming and outgoing calls.
Call Recordings may be used for various reasons, including but not limited to:
- For training purposes and to investigate compliance with our quality standards.
- To support the investigation of complaints.
- To ensure that we comply with regulatory requirements and procedures.
- To provide evidence for any investigation, including regulatory investigations; and
- To provide evidence of a business transaction and for fact verification purposes.
- WHICH CALLS ARE RECORDED?
The scope of this Policy extends to the following calls:
- All inbound calls to the FISC Accounts, FISC Support and TRACS Support Teams.
- All outbound calls made by the FISC Accounts, FISC Support and TRACS Support Teams.
- All calls transferred between the extension numbers of the above-mentioned Teams.
- All online meetings held via any online platform.
All customers will be advised that calls are recorded as part of a pre-recorded welcome message before a connection to a Team Member is established. Attendees of online meetings will be notified prior to the meeting starting if the meeting is being recorded.
Call Recording will be stopped if the caller specifically requests this, or to prevent the recording of sensitive personal data.
You may contact us by other means, such as by email or letter, if you do not wish to be recorded.
We will also publish this Policy on our website, www.fisconline.co.uk, and notify staff of the Policy in our Staff Handbook.
- WHERE ARE CALL RECORDINGS STORED?
Call Recording data is stored securely in a secure drive location which is backed up.
Call Recordings will be retained securely for no longer than six (6) months. All calls and backup versions of calls will be deleted after this time.
This retention period does not apply to personal data involved in legal proceedings.
- WHO ACCESSES CALL RECORDING INFORMATION?
Access to Call Recordings is restricted to the Senior Management Team. This includes the Chairman, Chief Technical Officer, Technical Director, Managing Director and Compliance Manager.
Access to Call Recordings is only allowed to satisfy a clearly defined and authorised business need and all reasons for requests for access must be formally authorised by a Senior Management Team Member.
All requests must include the valid reason for the request, date and time of call (if known), telephone extension used to make/receive the call, external number involved (if known), names of all parties to the telephone call (where known) and any other information on the nature of the call.
Browsing of Call Recordings for no valid reason is not permitted and will be subject to the Disciplinary Procedure.
- CAN I REQUEST A COPY OF A RECORDING?
Call Recordings are subject to international legislation and regulation as they may contain personal data and are subject to Intellectual Property Rights laws. Applicable UK Data Protection and Data Privacy legislation allows individuals whose calls have been recorded (the “Data Subject”) to access the information held about them. This includes recorded telephone calls.
The right of access can be exercised at any time and is limited to information used or stored about the individual requestor or “Data Subject”. We will endeavour to respond to all requests as soon as possible and within one month.
Requests for copies of any recorded telephone conversations must be submitted in writing for the attention of the Compliance Manager, Jackie Crookes, at firstname.lastname@example.org.
All requests involving Call Recordings are subject to evaluation on a case-by-case basis. In all cases, the consent of all parties involved on the calls must be secured before we are able to consider access to any Call Recording. Subject to assessment and the approval of release, we will make the necessary arrangements for the call to be accessed on a case-by-case basis.
You can also submit a request for access to personal information for the attention of the Compliance Manager at:
FISC Limited, Parkway Works, Kettlebridge Road, Sheffield S9 3BL
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 must be forwarded to the Compliance Manager who will process the request for access to a Call Recording appropriately and immediately.
Requests for copies of Call Recordings as part of staff disciplinary processes will only be released with the written agreement of a Director, or the Compliance Manager who will consult with a Director before approval is granted.
We regularly review compliance with our Call Recording Policy. In the event that we receive a formal written complaint, we will contact the person who made the complaint and make all efforts to resolve the complaint directly with them. We will also work with the appropriate regulatory authorities, including the designated data protection authority, to resolve any complaints.
- CHANGES TO THIS POLICY
As we may make changes to how we operate our business, our Call Recording Policy may change from time to time.
We reserve the right to make changes to this Call Recording Policy without explicit consent where changes in the legislative framework governing call recording require us to reflect these in our Call Recording Policy.
We will post any changes to our Call Recording Policy on this page and keep prior versions of this Policy in an archive for review.
- QUESTIONS OR CONCERNS REGARDING THE CALL RECORDING POLICY
If you have any questions or concerns about this Call Recording Policy, or should you wish to register a complaint about anything relating to it, please contact Jackie Crookes, Compliance Manager at email@example.com.