Introduction
This policy outlines the practice’s call recording process. The purpose of call recording is to provide a record of incoming and outgoing calls which can:
• Identify practice staff training needs
• Protect practice staff from nuisance or abusive calls
• Establish facts relating to incoming/outgoing calls made (e.g. complaints)
• Identify any issues in practice processes with a view to improving them
This policy does not cover telephone consultations with clinical staff. Telephone consultations are a clinical event and are recorded in the clinical record. This will generally be via a standard code and text entry using the clinical system in the traditional way and will be retained for the same period as the remainder of the medical record
Purpose
The purpose of this policy is to ensure that call recording is managed in line with DPA & Data Retention requirements. This will generally involve the recording of telephone conversations which is subject to the Telecommunications Act 1984.
The practice will make every reasonable effort to advise callers that their call may be recorded and for what purpose the recording may be used. This will normally be via a pre-recorded message within the telephone system, and an information notice on our waiting room TV, practice website and practice leaflet. The voice file will be stored within the telephone system to which the same rules of confidentiality will apply.
Where a patient requests to listen to a recording then this should be allowed within the general provisional of data subject access under the Data Protection Act 2018.
Scope
This policy applies to all practice staff including any contracted or temporary workers.
All calls via the telephone systems used in the practice will be recorded, including:
• All external incoming calls
• All external outgoing calls made by practice staff
• All internal incoming and outgoing calls made by the practice staff
• Call transfers
Recording will automatically stop when the practice staff member terminates the call.
Callers will be advised that the call will be recorded for quality/training purposes in the form of an automated voice message and an information notice on our waiting room TV, practice website and practice leaflet
Playback / Monitoring of Recorded Calls
Monitoring of the call recordings will be undertaken by the partners and/or senior staff (General Manager, Office Administrator/Nurse Manager). Any playback of recordings will take place in a private setting and where applicable, individuals should be given the opportunity to listen to the relevant recordings to receive feedback and developmental support.
All recordings and call recording equipment will be stored securely, and access to these will be controlled and managed by senior staff as detailed above.
Recordings will be accessed by logging into a dedicated, password protected computer system.
Calls will be retained by the Practice for up to 12 months.
Confidentiality
The Data Protection Act allows access to information that is held about them and their personal data. This includes recorded telephone calls.
Requests for copies of telephone conversations can be made under the Data Protection Act as a “Subject Access Request”. After assessing whether the information can be released, the requestor can be invited to the practice premises to hear the recording. The right to be forgotten’ does not override legal and compliance obligations.
If there is a request from an external body relating to the detection or prevention of a crime (e.g. police), then requests for information should be directed to the Practice Manager.
Under GDPR, organisations are prohibited from recording the personal conversations of staff, even with consent, and therefore need to ensure that while business calls are recorded, personal calls always remain private.