12.7 Voice Recording
Recording of speech without justification is highly intrusive and should not be undertaken without establishing reasonable and justifiable need.
Right to be Informed – you must make people aware that voice recording is taking place. Typically this could be:-
- where microphones are deployed in a reception area or classroom in response to staff being subjected to verbal abuse etc. Subject to the following recommendations:-
- the microphone should only be switched ON when required in response to a incident and then only for its duration;
- it is recommended that a biased OFF switch is used enabling recording only while it is pressed;
- at the moment recording is initiated, the person responsible for initiating the recording should make a clear unambiguous announcement such as ‘I AM NOW RECORDING THIS CONVERSATION FOR FUTURE REFERENCE’; and
- if permanent voice recording is undertaken it would be good practice to install prominent warning signs in the area stating – ‘Voice Recording is in operation for the purpose of …………….’
- In a security control room – where there is a need to record response in high risk situations subject to the following recommendations:-
- the microphone must only be switched ON for the duration of the risk situation as decided by the control room supervisor;
- a key switch is used to enable the recording and immediately upon activation a clear announcement should be made ‘VOICE RECORDING IS NOW ACTIVE’ ;
- you should include a statement relating to the use of voice recording in staff contracts of employment; and
- it would be good practice to install a prominent warning sign with a warning lamp illuminated when recording is taking place.
- Recording telephone conversations – the purpose of which is to provide a record of conversations in order to:-
- establish facts in the case of a dispute;
- assist in identifying staff training needs; and
- reduce the likelihood of abusive or nuisance calls.
Prior to accepting incoming calls, an automatic announcement should be made along the lines of:
In the case of outbound calls where recording is required, the person making the call must advise the recipient that the call is being recorded for future reference before initiating a recording.
Recording should be deactivated if sensitive information such as credit/payment card details are to be disclosed.
Right to be Informed – voice announcements shall be made as suggested above. Reference to voice recording should be referred to in the data controller’s Privacy Policies and contracts of employment for affected staff (e.g. reception staff).
Consent – due to the lawful basis of this processing consent would not be required.
Archive Retention – in establishing the archive retention period you will need to consult with the various stakeholders in the business to establish their reasonable and justifiable requirements. This could be several months where verbal instructions are given to proceed with works, provide a service or supply product.
Privacy – access to recordings shall be password protected and managed on computer devices identified by unique reference numbers logged in a Controlled Data Register. The recording must be deleted at the end of the archive period.