WHAT HAPPENS WHEN A CUSTOMER CALLS

2: Scope2.1 The policy aims to minimise intrusion byrestricting access to and use of recording tolimited and specified purposes only.2.2 This policy outlines:• Recorded information• Purposes of call recording• Access and availability• Information Security (GDPR)• Monitoring and review

Internal Telephone CallRecording Procedure

1: Purpose

1.1 The purpose of this policy is to govern theprocedures for telephone call recording withinWest Lindsey District Council and themanagement of access and use of telephone callrecordings.

1. 2 The implementation of recording oftelephone calls was agreed in order to supporteffective training, performance monitoring anddelivery of excellent customer services, acrossthe whole council, and to enable the council todeal efficiently with internal or externalcomplaints, implementation of customerstandards and training of staff in the delivery ofexcellent customer service.

PHONE &VOICEMAILGUIDELINES

Calls should be answeredwithin 21 seconds

Voicemails should beresponded to the sameday (or the next workingday if the voicemail was

left after 3.30pm)

If you work part-time, youshould work with your

team to ensure measuresare put into place (such ascall forwarding on non-

working days)

If you are on leave, out ofthe office for the day or inthe office but unable totake calls, you should

arrange for all calls to beforwarded. If you areunable to forward your

calls to a member of yourteam, they can be

forwarded to CustomerServices (prior notice mustbe given) who will then

arrange a call back request

4: Purposes of call recording

4.1 The purpose of call recording is to providean exact record of the call which can:

4.a help protect officers from abusive ornuisance calls.

4.b establish the facts in the event of acomplaint either by a customer or a memberof staff and to assist in resolving it.

4.c help identify officer training needs and tosupport training new and existing officers; and

4.d assist the council’s quality control toidentify any issues in council processes, witha view to improving them.

4.2 In addition, recordings may provideevidence for crime prevention purposes orinternal investigations.

3: Recorded Information

3.1 All calls received or made from nominatedextensions will be recorded using the CouncilsRed Box call recording system and will be storedsecurely for up to 6 months and will then beautomatically deleted, unless highlighted for thepurposes of evidence gathering.

3.2 Telephone calls currently included in the callrecording scope are the following services:• Customer Services• Revenues and Benefits

3.3 Call recording will apply to all calls made andreceived and will include both external andinternal calls.

3.4 Calls to and from other officers within thecouncil will not routinely be recorded but may berecorded during periods of mystery shoppingevents.

3.5 Calls where the caller provides details of apayment card will be subject to a mid-callsolution in order to comply with Payment CardIndustry Security Standards (PCiDSS), ensuringthat the Council will not hold any credit/debit carddata.

5: Internal access and availability

5.1 Access and playback of recordings will becarefully controlled as per the requirements ofGDPR

5.2 Only those with the appropriate authority canaccess calls. (See below)

5.3 Access to calls may be for a number ofreasons. We anticipate the six main reasons willbe for;

5.a Checking accuracy5.b Answering complaints5.c Training to improve services and skills5.d Mystery shopping events5.e Internal investigations5. f Maintenance of the call recording system bythe ICT team

5.4 An individual officer may request to hear callrecordings in which they are personally involvedbut must do this via their team manager, who willsubmit a request via the request form onMinerva.

5.5 Any team manager or above may request tohear call recordings which involves a member oftheir team. They should make a request detailingthe reason for hearing the recording via therequest form on Minerva.

5.6 It should be noted that Senior CustomerServices officers and the Customer Experienceofficer will, on a weekly basis, listen to calls inorder to undertake performance monitoring ofstaff within Customer Services and undertakeadministrative duties in accordance withmanagement of the telephone call recordingsystem.

Exceptions to this are the following:

5.6.1 Where the Customer Strategy andServices Manager has delegated actions to adesignated deputy or equivalent, for thepurposes of mystery shopping or dealing witha complaint, listening to any calls that havebeen recorded be that in real time orretrospectively.

5.6.2 Where the People and OrganisationalDevelopment manager has delegated actionsto a designated deputy or equivalent, for thepurposes of evidence gathering during adisciplinary investigation or hearing.

5.6.3 In addition, Team Managers, canrequest to hear the recordings of a specificcall or a random selection of calls for qualitymonitoring purposes.

5.7 Calls to be listen to will be accessed viathe red box system only, calls will not bedownloaded unless required as part ofevidence in an appeal, hearing oremployment tribunal.

5.7.1 Downloaded calls will be sent via emailin an audio file, if required to be used asevidence as stated in 5.7

5.8 Authorisation to review calls will begranted by the Customer Strategy andServices or the People and OrganisationalDevelopment Managers.

5.9 A telephone extension, that will not besubject to call recording by being excludedfrom the recording system, can be madeavailable for confidential calls e.g. tounion/manager

6. GDPR

6.1 A DPA has been carried out and is atAppendix A of this policy

6.2 Recordings constitute the personal data ofthe caller and the operator. Therefore they willbe manage in such a way that the rights of thedata subject (callers and operators) can befulfilled, and all obligations of the data controller(WLDC) are observed, as per our dataprotection policy.

6.3 Every caller who telephones 01427 676 676will be notified that the call may be recorded andwhy before the conversation commences. This isdone through a pre-recorded message within thecouncil’s telephone welcome message before aconnection is made to an officer. Details of callrecording and the Councils GDPR requirementsare also notified on our website.

6.4 Recordings will be retained for 6 months andthen automatically deleted.

6.5 Some recording may be retained for longerthan 6 months for the following reasons.

6.a Required for a complaint. In this case therecording will be retained until the completion of

the complaint process, including any appealsprocesses.

6.b Required as part of a staff disciplinaryprocess which may result in use of employmenttribunal

6.c Recording that have been identified by thefollowing officers, Strategic leads for CustomerFirst and Corporate Governance, Customer andStrategy and People and Organisationaldevelopment managers and as identified asevidence for record keeping requirements insupport of the dealing with unacceptablebehaviour towards staff and unreasonablepersistent complaints.

6.6 Staff need to be aware thatcustomers/callers have the right to listen to orhave copies of the recording made of their owncalls, via the councils subject access requestprocedures.

6.7 Recording will be located by thecustomer/callers telephone number, date andtime of the call and the officer’s identity.

6.8 Recordings will generally be emailed tocustomers. Exceptions to this will be reviewedas they occur.