CCHA Call Recording Statement
A Scope and Objectives
This Statement outlines CCHA’s call recording process. The purpose of call recording is to provide an exact record of the call which can:
• Help identify staff training needs
• Help protect staff against abusive or nuisance calls
• Help improve performance
• Establish the facts in the event of a complaint either by a customer or staff member and also assist in resolving it
• Assist in identifying any issues with processes and improve them
• Further evidential protection for ‘dis-repair’ claims
• Demonstrates that calls are accurately reflected in CCHA’s customer management systems
This Statement applies to all staff who are customer facing and whose calls are recorded through the call recording system, 8x8. This includes members of staff from:
• Customer Services Teams
• Income Team
• Maintenance/Property Services
• Independent Living
• Lettings and Neighbourhood Teams
This Statements’s core objectives are to ensure and improve customer service delivery and protect customers and staff whilst minimising the risk of breaches of Payment Card Industry/ Data Protection (PCI/DP) compliance.
B Purpose
The Purpose of this Statement to ensure that, calls recorded are managed in line with PCI/DPA data retention requirements. Call recordings will be used to improve the service provided to CCHA’s customers and to support staff in carrying out their role.
This Statement applies to all customer facing staff, including agency workers, whose calls arrive or are routed via 8x8 ie:
• All external incoming calls and direct calls
• All external outgoing calls
• All internal incoming and outgoing calls
• All customers are advised as part of the corporate welcome message that calls are recorded for service improvement purposes. The message starts with; ‘Welcome to Castles & Coasts Housing your call may be recorded for quality monitoring purposes’.
Recording automatically stops when:
• The front facing member of staff accesses Allpay;
• The front facing member of staff finishes the calls.
Stopped recordings will automatically recommence when:
• The front facing member of staff leaves the Allpay screen.
• The front facing member of staff commences a new call.
C How call recordings will be used
Recording will be used as part of the quality management processes within CCHA’s Teams/Departments
Recordings will be used to assist in CCHA’s quality control to identify service and process improvements.
Recordings will be stored securely, with access to the same controlled and managed by the Data Custodian or any other persons authorised to do so by the Data Custodian, for example an individual’s manager within a department or a person investigating a complaint.
Recordings will be automatically deleted after 12 months. Where it is identified that the content of a call recording may be required for a legitimate reason, such as on-going complaints, evidence or investigation purposes (Formal and Housing Ombudsman related) or been abusive or problematic (Anti-Social Behaviour) beyond a period of 12 months, the call recording file will be securely stored. Any authorisation for retaining recordings for longer than 12 months is at the discretion of the Data Custodian (Head of Customer Service and Engagement) with agreed permanent deletion dates
Any playback of recordings will take place in a private setting and individuals should be given the opportunity to listen/see their own recordings in order to receive feedback and developmental support through coaching and training interventions.
Call recordings may also be given to customers at their request or played to customers to expedite the resolution of a complaint.
D Request a copy of a recording
The UK GDPR allows individuals whose calls have been recorded (the “Data Subject”) to access the information held about them. This includes call recordings
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. An exemption may apply to restrict disclosure of a call recording.
E Regulatory and Legal Considerations
This Statement in no way is intended to detract from current legislation in relation to the recording of calls which includes:
• Regulation of Investigatory Powers Act 2000 (‘RIPA’);
• Investigatory Powers Act 2016 (‘IPA’);
• Telecommunications (Lawful Business Practice & Interception of Communications) Regulations 2000 (‘LBP Regulations’);
• Privacy and Electronic Communications Regulations 2013;
• EU retained version of the GDPR (UK GDPR);
• Telecommunications (Data Protection and Privacy) Regulations 1999;
• Data Protection Act 2018 (‘DPA 2018’);
• Human Rights Act 1998.
F Monitoring, Reviews and Evaluation
Compliance for PCI/Data Protection will be assessed through:
• Customer Service Advisors and Income Officers being targeted to direct customers to the automated payment option for all rent payment calls.
• To further minimise DP/PCI compliance breaches, the retention period of call recording will be 12 months.
G Document Owner
The Head of Customer Service & Egngagement is the document owner for the Call Recording Statement.