Call recording policy

Introduction

This page outlines the policy and procedures for recording calls at Ealing Council using the netcall liberty converse contact centre. The purpose of this policy is to ensure that the council complies with the relevant laws and regulations, protects the privacy and confidentiality of callers and staff, and improves the quality and effectiveness of customer service.

Scope

This policy applies to all calls made or received by the council staff using the netcall liberty converse contact centre, which is a cloud-based platform that enables efficient and personalised customer service. The policy covers the following aspects of call recording:

  • when and why calls are recorded
  • how calls are recorded, stored, accessed, and deleted
  • who can access and listen to recorded calls
  • how callers and staff are informed and consent to call recording
  • how recorded calls are used for quality assurance, training, and dispute resolution
  • how recorded calls are protected from unauthorised access, disclosure, or misuse

Policy statement

The council records all calls made or received by the staff using the netcall liberty converse contact centre for the following reasons:

  • to comply with the legal and regulatory obligations, such as the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the Freedom of Information Act 2000, and the Regulation of Investigatory Powers Act 2000
  • to protect the rights and interests of the callers and the staff, such as providing evidence of transactions, agreements, or consents, and preventing or detecting fraud, abuse, or harassment
  • to improve the quality and effectiveness of customer service, such as monitoring and evaluating the performance of the staff, identifying the training and development needs, and resolving complaints or disputes

The council uses the netcall liberty converse contact centre to record calls, which is a cloud-based platform that provides the following features:

  • automatic recording of all inbound and outbound calls
  • secure storage of recorded calls in encrypted format on the cloud server
  • easy access and retrieval of recorded calls through a web-based interface
  • advanced search and filtering options to locate specific calls
  • ability to playback, download, or share recorded calls with authorised users
  • ability to annotate, rate or flag recorded calls for quality assurance or training purposes
  • automatic deletion of recorded calls after a retention period of 12 months, unless there is a valid reason to keep them longer

The council ensures that the callers and the staff are informed and consent to call recording by the following means:

  • displaying a clear and prominent notice on the council website and other communication channels that all calls are recorded
  • playing a pre-recorded message at the beginning of each call that informs the caller that the call is being recorded and the reasons for doing so
  • allowing the staff to access and listen to their own recorded calls for self-evaluation and feedback

The council restricts the access and use of recorded calls to authorised users only, who are the staff members who have a legitimate and relevant need to do so, such as the:

  • staff members who made or received the call, or their line managers or supervisors
  • quality assurance or training team who monitor and evaluate the staff performance and provide feedback or coaching
  • complaints or disputes resolution team who investigate and resolve any issues or concerns raised by the callers or the staff
  • legal or compliance team who deal with any requests or enquiries from the regulators, law enforcement agencies, or courts

The council protects the recorded calls from unauthorised access, disclosure, or misuse by the following measures:

  • using encryption, password protection, and access control mechanisms to secure the recorded calls on the cloud server and the web interface
  • applying the data protection principles and the council's data protection policy to the recorded calls, such as collecting, processing, and storing the recorded calls in a lawful, fair, and transparent manner, and respecting the rights of the data subjects
  • conducting regular audits and reviews of the call recording system and the policy to ensure that they are functioning properly and comply with the current laws and regulations
  • providing the staff with a training and guidance on how to handle and use the recorded calls in a responsible and ethical manner, and reporting any breaches or incidents to the appropriate authorities.

The following lines are recorded within Ealing Councils contact centre:

  • Building control: 020 8825 6020
  • Business waste: 020 8825 5333
  • Council tax: 020 8825 7050
  • Customer portal helpline: 020 8825 7733
  • Ealing together: 020 8825 7170
  • Elections (during campaigns only): 020 8825 7777
  • Facilities management: 020 8825 9000
  • Family information service: 020 8825 5588
  • Grime busters: 020 8825 8825
  • Housing benefits: 020 8825 7000
  • Housing benefits change of circumstances: 020 8825 7829
  • Highways: 020 8825 6222
  • Housing demand: 020 8825 8888
    • Acquisitions
    • Allocations (housing register and Locata)
    • Compliance
    • Temporary accommodation finance
    • Temporary accommodation other matters
    • Housing solutions (homeless)    
  • Housing repairs: 020 8825 5682
    • Contractors (internal use only)
    • Internal escalations (internal use only)
  • Mobility: 020 8825 8161
  • Parks: 020 8825 6999
  • Pest control: 020 8825 6644
  • Planning: 020 8825 6600
  • Pollution control: 020 8825 8111
  • Registrars: 020 8825 7171
    • Births
    • Deaths
    • Marriages and civil partnerships
    • Nationality checking service
  • Social services (adults and childrens): 020 8825 8000
  • Street services: 020 8825 6000
  • Switchboard: 020 8825 5000

Retention of call recordings

Recordings will be stored securely and retained for a minimum of 90 days after which they will be deleted. Any recordings which may need to be used for the purposes of criminal proceedings or longer-term investigations that have been extracted from the system, will be kept in a secure place until any such proceedings or investigations have come to an end. At this point, they will be deleted. 

Request to access or delete calls

Anyone who wants access to their calls or to have these deleted from the system should make this request following the subject access request process. 

Review and approval

This policy will be reviewed and updated yearly, or as required by any changes in the laws, regulations, or business needs. The policy will be approved by the senior management of the council and communicated to all the staff and the public.