This policy applies to customers and all Company associates, whether employed or contracted-in, who may, in the course of performing the duties of their role, participate in supporting calls for customer-facing queues.
It is New Era’s policy to ensure call recordings are managed in line with UK Legislation:
- Regulation of Investigatory Powers Act 2000 (“RIPA”)
- Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (“LBP Regulations”)
- Data Protection Act 2018
- The GDPR through the DPA 2018 above
- The Employment Practices, Data Protection Code
- Telecommunications (Data Protection and Privacy) Regulations 1999
- Human Rights Act 1998
Call recording will be used to improve the service provided to the Company’s customers and to support associates in carrying out their role.
This will include:
- Inbound calls to all CSC and to VNOC extensions via the ACD (automatic call distributor);
- Calls transferred to extensions within CSC and VNOC
Specific queues within the Contact Centre are recorded; only those which the partner/customer has agreed to. Calls to the recorded queues have a pre-recorded welcome message prior to the call being routed to the New Era customer support agent. The message states:
- “Thank you for calling the video support team. This call will be recorded for quality and service improvement purposes.”
Recording services shall stop only when:
- The Caller disconnects from the call;
- When the call is transferred externally;
- When the call is transferred to an extension not affiliated with the CSC or VNOC;
- The Caller Opts-Out which involves the Caller disconnecting the call.
To opt out of call recording services the caller must disconnect from the call and utilise an alternate communication method, such as email.
How will Recordings be used?
Recordings will be used as part of the quality management process at New Era.
Recordings will be used to assist in customer support quality control to identify any issues in customer support processes, with a view to improving them.
Recordings are kept no longer than necessary to satisfy Ne Era’s operational needs. Where the conduct exhibited by participants in a recordings has been abusive or is otherwise of concern, or where such conduct has resulted in complaints brought forward by participants (or their representatives, as applicable), said recording will be saved as long as is necessary to complete the resolution of said complaint, upon which the recording will, at the sole discretion of New Era in consultation with its Human Resources representative, be destroyed irrevocably.
Recordings will only be released where so required by law or regulation applicable under the jurisdiction of the associate affected by said release. Such release will only occur with the consent of the DPO, COO, or Director, Customer Care in consultation with any other top-level management and/or Human Resources, and with the consent of the participants involved in the recording.
How Will Recordings Affect Associates and Customers?
Recordings may contain personal data of both the inbound caller and New Era’s associate (New Era’s associate and the caller individually referred to as the “Data Subject”, collectively hereinafter the “Data Subjects”). Therefore, New Era (hereinafter: the “Data Controller”) will assure that the Data Subjects’ rights as well as its own rights and obligations are being complied with in accordance with New Era’s global privacy policies for employees and in accordance with applicable local legislation.
Recordings will be reviewed only by authorised New Era personnel and Human Resources in order to assess the associate’s performance in relation to New Era’s call handling standards and in order facilitate quality and service improvement.
Any playback of recordings will take place in a designated and approved location where confidentiality is assured.
Associates will also be given the opportunity to listen to the recording where they were a participant in order to receive feedback and developmental support through coaching and training interventions. To request a review of a call recording where an associate was a participant in the call, the associate should adhere to the request process as identified in this policy.
Recordings identified as suitable for training purposes shall not be played back in a public arena without the prior consent of the employee(s) involved and the Data Subject in order to appropriate data protection consideration of any third party rights involved.
While New Era does not routinely collect data for the purpose of disciplinary/corrective action with associates, New Era reserves the right to refer to a recording where a performance failure has occurred. As such, any associate who has become subject to New Era’s disciplinary procedures is entitled to have access to that data provided that all third party rights have been observed.
Procedures for Managing and Releasing Recordings
The recordings shall be stored securely in New Era infrastructure, with access to the recordings controlled and managed by Human Resources for up to sixty (60) days. Following the sixty (60) days, the recordings shall be archived to a secure location.
Access to the recordings will be restricted to Human Resources as the primary point of contact, and supported by authorised New Era IT representatives.
Recordings may be reviewed only by members of New Era’s leadership team and business operations management in consultation with Human Resources.
Applicable local data protection and data privacy legislation allows Data Subjects to access information that we hold about them. This includes recorded telephone calls. Therefore, the Recordings will be stored in such a way to enable Human Resources to authorise IT to retrieve information relating to recordings. In all instances where recordings are requested, Human Resources shall act as the primary point of contact in the request process.
All requests for copies of recorded telephone conversations must be submitted in writing solely to Human Resources and the DPO and, subject to evaluation of said request, recordings will be requested for retrieval with arrangement to follow permitting the concerned individual to hear the recording at the nearest regional company office where possible.
In the case of a request from a data subject, or a judicial or regulatory body in connection with the detection or prevention of crime (e.g. the police), such request will be forwarded to Human Resources who will facilitate the release of the recording in accordance with applicable data protection and data privacy laws and regulations.
Customers who participated in recordings can access their information using the contact us page on New Era’s website.
CONSULTATION AND ENGAGEMENT
This policy has been developed in consultation with the Company’s Leadership Team, Business Operations Management and Human Resources to ensure the Company’s compliance with applicable personal data and data privacy laws and regulations.
PERFORMANCE AND RISK MANAGEMENT
This policy will be reviewed annually or where so required in order to comply with any legislative or regulatory change to applicable data protections and data privacy laws and regulations.
The Company’s management is responsible for ensuring this policy is understood and complied with through individual meetings and training for all associates. Managers with direct reports are responsible for facilitating this training with their respective teams.
Training for New Era’s associates who are authorised to use and store the recordings must be given appropriate training and guidance. It is important these associates understand the application of all policies including, but not limited to the Company’s information security and data protection policies.
Human Resources are responsible, jointly with the IT team, to ensure that appropriate personnel are identified to have access to the recordings.
NEW ERA’S ASSOCIATES
All associates must adhere to Company policies, in addition to maintaining their individual obligations under local/regional legislative requirements.
Non-recorded telephone access shall be made available to associates in all regional locations and in common areas or break rooms for use during breaks or outside of work hours. Employees are encouraged to make use of their personal phones for all personal calls.
CUSTOMERS AND PARTNERS
Where the Company engages with partners and/or customers, directly or indirectly, contractual agreements and operational procedures must reflect the principles of this policy and the principles of applicable data protection and data privacy laws and regulations. This should include setting out in the agreement how recordings will be used and accessed across the partnership.
INFORMATION AND TRAINING
Training on how to access call recording will be limited to those with authorised access including the members of New Era’s senior management team, its IT managers and systems administrator.
The InfoSec team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.
Any exception to the policy must be approved by the InfoSec team in advance.
Violation of this policy may result in disciplinary action which may include termination for New Era’s employees and temporaries; a termination of employment relations in the case of contractors or consultants; dismissal for interns and volunteers; or suspension or expulsion in the case of a student. Additionally, individuals are subject to loss of New Era Information Resources access privileges, civil, and criminal prosecution.