Call Monitoring and Recording Policy

1. Call Monitoring and Recording Policy A introduction for managers March 2007

2. Introduction • This guide provides an introduction to the key points of the Call Monitoring and Recording Policy • An accompanying employee handout has been developed • Copies of the policy are available on the intranet • Further advice may be obtained from your Directorate HR Team or Corporate HR

3. What is the purpose of the policy • To ensure that: • call monitoring and recording is conducted in line with Data Protection legislation • call monitoring and recording data is stored in line with Data Protection legislation • employees and managers understand their roles and responsibilities in relation to call monitoring and recording • the purpose of call monitoring and recording within the council is known and understood by employees and managers

4. Who does the policy affect? • The policy applies to all employees, however there are two main considerations • Employees working within areas where call recording is instigated • All other employees • All employees may be subject to call recording when contacting areas of the business where call recording takes place, therefore managers must ensure that: • all employees are informed that their telephone calls may be recorded • employees are reminded of the council’s procedures in relation to personal telephone calls • the Call Monitoring and Recording Policy is added to any local induction procedures

5. What are call recordings used for? • Call recordings may be used to: • investigate customer complaints or allegations • improve service provision • address staff and public safety concerns by monitoring nuisance, harassing or threatening calls • assist in the prevention or detection of crime • measure and improve agreed quality standards • provide feedback and development for employees in areas where call recordings are instigated

6. How does this affect the rights of individuals? • Following the council’s procedures relating to personal telephone calls will ensure that individual rights are protected • Managers are responsible for ensuring that call recordings are handled in line with data protection guidelines, which in turn will protect individual rights • Whenever call recordings are used consideration must be given to the use of third party data • For example where call recordings are used for training purposes third party rights must be protected and employee consent must be given • Further advice may be sought from Directorate or Corporate HR teams or from the council’s Data Protection Officer

7. Call recordings and disciplinary action • Employees may be concerned about the use of call recordings in the event of a disciplinary investigation; • Call recording data is not routinely collected for this purpose, however, where appropriate, call recordings may form evidence as part of an investigation • In such cases employees must be informed of this and managers must seek further guidance from Directorate or Corporate HR representatives • Employees and their representatives must be informed of the need to give data protection consideration in respect of any third party who may be identifiable in such evidence

8. Use, handling and storage of call recordings • Managers in areas instigating call recordings are responsible for: • the secure storage of call recordings • developing local processes to manage the use, handling and storage of call recordings in line with data protection policies and principles • identifying appropriate personnel who will be authorised to access call recordings • ensuring employees receive appropriate training in storage and handling processes and associated data protection policies and principles • ensuring that those with responsibility for providing feedback, coaching and development using call recordings are provided with training and guidance

9. Use, handling and storage of call recordings • In the course of monitoring call recordings authorised personnel may encounter third party information which they feel should be revealed • Advice should always be sought in such situations as this has implications for the data protection considerations of the third parties • Managers and employees should refer to the council’s Anti-Fraud and Corruption and Whistle Blowing policies

10. References and other sources of information Anti Fraud and Corruption Policy Call Recording Policy Code of Conduct Capability and Disciplinary Procedures Data Protection – Employment Records Employee Handbook Whistle Blowing Policy Information Commissioner’s Office website www.ico.gov.uk