This Privacy Notice explains how we use recordings of phone calls within the Housing and Internal Audit Teams.
When a call is recorded we collect:
a digital recording of the telephone conversation
the telephone number of both parties (internal and external)
Personal data revealed during a telephone call will be digitally recorded for example name and contact details to deliver appropriate services.
Occasionally ‘special category’ personal information may be recorded where a customer voluntarily discloses health, religious, ethnicity or criminal information to support their request for advice and/or services.
Telephone call recording will be turned off, when a customer’s credit or debit card details are given, in line with Payment Card Industry Data Security Standards (PCS DSS) and data protection legislation including General Data Protection Regulations (‘GDPR’).
See further details about how we define personal data
Collecting personal data
Waverley Borough Council currently only records phone calls within Housing and Internal Audit teams.
We record calls made to the following teams:
- Family Support Team
- Heads of Housing office
- Home Choice Team
- Housing Customer Services Team
- Housing Options Team
- Internal Audit Team
- Private Sector Housing Team
- Rent Accounts Team
- Tenancy and Estates Team
Using personal data
Call recordings will be used:
- to assist in the quality monitoring of staff performance
- to investigate and resolve complaints
- for the detection, investigation and prevention of crime (including fraud)
- to take actions to protect staff from abusive callers
- to ensure the Council is able to monitor and adhere to quality standards
All call recordings are held securely by the IT Service. Only a Head of Service may request a copy of a call through a prescribed form for a specific reason.
See further details about how the law allows us to use your personal information
Sharing personal data
We may be asked to share a call recording with the Council’s Corporate Complaints Officer in order for them to respond to a complaint.
Sharing data under Data Protection legislation
We may be required or permitted, under Data Protection legislation, to disclose a call recording including your personal data without your explicit consent, for example if we have a legal obligation to do so, such as for:
- Law enforcement
- Fraud investigations
- Regulation and licencing
- Criminal prosecutions
- Court proceedings
Our legal basis for collecting and sharing personal data
Recording of calls is necessary to protect the interests of you, our customers and our staff.
The legal basis for us to process personal data set out in Article 6 of GDPR. Public Task - the processing is necessary for us to perform a public task in the public interest ie example provide housing services.
The legal basis for processing ‘special category’ personal data set out in Article 9 (a) the data subject has given explicit consent. In the majority of cases where customers volunteer special personal data the special category data is already held and known by the team following a formal application or interview process with explicit consent given. Officers will advise callers that any new ‘special category’ personal data will be recorded and request the caller gives “explicit consent” to hold that information to support their request for services. If consent is not given the officer will make arrangements for the call to be deleted.
Retaining personal data
Recordings are kept securely and confidentially. They will be deleted after three months.
Further processing of personal data
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice or by another service Privacy Notice, then we'll provide you with a new notice.
The new notice will:
- explain this new use before we start the processing
- set out the relevant purposes and processing conditions
Where and whenever necessary, we'll seek your consent to the new processing, if we start to use your personal data for a purpose not mentioned in this Privacy Notice.
Your rights relating to personal data
Please see details about your rights under the new data protection legislation introduced in May 2018.
We will keep the call Recording Privacy Notice under review with an annual review.
Version One: 7 May 2019
Page owner: Caroline Ottery. Last updated: 23/05/2019 13:18