Call Recording Policy

Published: 28 September 2021
Freedom of information class: How we manage our resources

Information on our call recording policy.

Purpose and scope

This policy sets out RoS' commitment to provide excellent customer services to the people of Scotland by implementing a mechanism that will allow us to accurately record customer contacts by telephone within our customer experience teams (these consist of customer services, property information and customer relations).

This policy applies to all inbound and outbound telephone calls received by the customer experience teams via the Cirrus telephony platform. No inbound and outbound calls received via Microsoft’s Skype for Business or Teams systems will be recorded.

The aim of the policy is to support to the corporate strategic objectives of:

Developing and delivering digital improvements that support forward thinking sustainable business where the needs of our customers are exceeded.

Invest in our people so that they can support a professional flexible business that works at pace to deliver value and fulfils our public task.

Documented procedures on call handling, technical training and the use of a quality management system support this policy, which in turn ensures the consistent delivery of excellent customer services. RoS will maintain and publish these as required.

Guiding principles

The guiding principles of the call recording policy are :

  • Ownership - Ensure that there is accountability for RoS and our customers in our telephone interactions.
  • Compliance - Ensure that RoS is keeping up with industry standards within our customer-facing areas and using technology to benefit us and our customers.
  • Optimisation - Capturing customer insight and designing our services to best fit our customer needs and exceed where possible.
  • Inclusiveness - Allow customers who cannot use our online services to make requests to access our products and services in a way convenient to them but that also provides an audit trail

The policy

Policy aims and objectives

RoS aims to provide excellent customer focussed services for the people of Scotland. One of the main channels that customers use to contact us is by telephone.

This policy outlines how we will govern call recording and how we will use these recordings for limited and specific purposes.

Purpose of call recordings

Calls are recorded and retained for the following purposes:

  • To ensure that we have an accurate record of a customer contact.
  • Staff training.
  • Establishing the facts in the event of a complaint or application of unacceptable behaviour policy.
  • Assist in identify any issues in RoS' processes, with a view to improving them.
  • Prevention or detection of a crime, including the investigation, apprehension or prosecution of offenders, where any offence involves the unlawful claim for any payment, or any unlawful application of public funds.

Calls where the caller provides details of a payment card for the purpose of making a payment to RoS will not be recorded to comply with Payment Card Industry Security Standards (PCiDSS)

Information security

Informing customers that calls are being recorded

RoS' interactive voice response (IVR) contains a pre-recorded message informing customers that calls will be recorded for training and monitoring purposes. If the customer does not want their call to be recorded they can inform the customer services advisor and that call will be removed from the data storage.

Data protection

Recordings constitute the personal data of both the caller and the RoS' staff member. Therefore, they will be managed in such a way that the rights of data subjects (customers and staff members) can be fulfilled, all of the obligations of the data controller (RoS) are observed, as per RoS' Data Protection and Privacy Policy.

Recordings will normally be retained for two years and then automatically deleted. This will allow for casework pertaining to the call to be completed. Some recordings may be retained for more than two years for the following reasons and other reasons where demonstrable cause is shown:

  • If required to support a complaint investigation by a customer about any of the five complaint categories in RoS' Complaint Handling Procedures (CHP). In this case the recording will be retained until a decision has been made on the case and following the expiry of any review period, in line with RoS' CHP.
  • If required for a complaint against a member of staff. In this case the recording will be retained until the completion of any investigation, disciplinary hearing and expiry of any review period. If necessary, the recording will be retained until the end of disciplinary action against staff and employment tribunal proceedings.
  • If the call has been identified by a member of RoS as valuable for staff training. In this case the recording will be retained until it is no longer useful for this purpose.
  • If identified as evidence for RoS' procedure for dealing with unacceptable behaviour under that policy.
  • If identified as evidence to assist in legal proceedings to protect the Keeper against fraud.

Requests for a copy of the call recording

Anyone can make a request for a copy of the recording of a specific call under either Freedom of Information (Scotland) Act 2002 or Data Protection Act 2018. These recordings will be located by reference to the date and time of the call and the staff member's identity. Callers asking for the recordings of their calls will have to provide enough information about the date, time and staff member to enable to call to be identified. The disclosure of the call will be subject to the instruction of Information Governance having regard to the applicable law.

In the event that an individual makes a subject access requests for all calls they have made to Registers of Scotland, all reasonable attempts will be made to confirm that the identity of the individual making the subject access request matches the identity of the caller. If in doubt the final decision will be made by RoS' Data Protection Officer. The Data Protection Officer will also balance the privacy of the caller or member of staff with the rights of the individual making a subject access request when coming to a decision.

A permanent copy of the recording will be provided in a format that RoS can reasonably expect the enquirer to be able to use taking account of the individual's preferences (if any) and practicality and cost of preparation. Formats could include WAV, MP3 or other digital format, or a transcript.

All other data protection requests

All other data protection requests in relation to information held on the Cirrus Telephony System as articulated within Articles 12 to 23 (inclusive) of the Data Protection Act 2018 will be dealt with by the Risk and Information Governance Team and actioned as appropriate.

Access controls

Access and playback of recordings will be carefully controlled as per the requirements of RoS' data protection policy. Only those with the appropriate authority can access calls. They are required to maintain a secure and private password, which is auditable and traceable within the software. Access to calls may be for a number of reasons, the main reasons will be for checking accuracy, answering complaints, and for training to improve service and skills.

  • The Customer Experience Management Team will have access to the recordings for the entirety of the retention period. Any calls requested after 14 days, should be directed to the Head of Customer Services or Head of Customer Experience who will consider the request and consult with subject matter experts as appropriate.

A further assurance process will be put in place to ensure that no additional calls are being listened to over the 14 day quality assurance period for the Customer Experience Management Team. This will align with the Customer Experience Risk and Information Governance return that will ensure that this process is strictly adhered to.

Any individual officer may request to hear call recordings in which they are personally involved, and any manager may request to hear call recordings which involve a member of their team. They should make a request via email, detailing the reason for hearing the recording to the Head of Customer Services or Head of Customer Experience. In their absence, the request may be considered by the relevant Head of Service, Director or the RoS' Data Protection Officer.

Whilst Cirrus, the external contractor who support the telephone recording system can access the system remotely, this is only to maintain the system, and they do not have access to the calls recorded on it.

Staff protection

There is a risk that RoS staff receive calls that contain examples of unacceptable behaviour. A recording may be used as evidence in this situation to support the application of the RoS customer behaviour policy.

A recording may also be used where a RoS staff member receives abuse or otherwise unacceptable behaviour from a RoS colleague. Specific call recordings may be provided to Human Resources or a disciplinary hearing panel for evidence in a disciplinary process. However, recordings will only be available if they are made to one of the telephone numbers designated to have incoming our outgoing calls recorded. Calls made internally between colleagues using Teams will not be recorded.

The decision as to whether a recording will be used as evidence in the situations outlined above will be made by the Head of Human Resources (or an individual designated by the Head of HR). This will not restrict any parties involved in any particular investigation using their access to information rights to obtain a copy of the information held by RoS.

If RoS calls have evidence of criminal activity on the register or criminal behaviour towards staff, we will pass these to Police Scotland.

Calls that are downloaded and retained will be stored on RoS' network drive in the folder appropriate to the purpose for which the call was downloaded with appropriate access controls.

Roles and responsibilities

The Policy and Practice Group is responsible for the content of this policy, its approval and review. The Head of Customer Experience is responsible for ensuring its implementation in practice and for monitoring this over time. They are responsible for ensuring that appropriate procedures, guidelines, standards or patterns as are required to support this are maintained and ownership for these assigned appropriately.

The following people will also have key roles in the implementation in practice of the call recording policy.

Job title Role in this policy

Head of Customer Experience

Policy Sponsor

Head of Customer Services

Lead on the operating practices within Customer Services

EE Product Owner

Lead on the technical maintenance of the system to ensure compliance with data governance rules

Deputy Head of Information Governance

Lead on risk and information governance advice to ensure continuous compliance with risk and information governance rules and practices.

The audience for this policy is both internal and external stakeholders and should be made available via the publication scheme.

Approval and review

The RoS Call Recording Policy will be reviewed and approved by the Policy and Practice Group at least annually, unless earlier review is appropriate.


Gillian Martin, Head of Customer Services

August 2021