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 (e.g. to aid workforce planning)

Purpose

 The purpose of this policy is to ensure that call recording is managed in line with Data Protection Act 2018 requirements.  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 via signage at the practice. The voice file will be stored within the telephone recording system software 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 provision of a data subject access request under the UK General Data Protection Regulation (UKGDPR)/Data Protection Act 2018.

Scope

This policy applies to all practice staff including any contracted or temporary workers.  All external incoming and outgoing calls made by practice staff via the telephone system will be recorded.  Recording will automatically stop when the practice staff member terminates the call.

Callers will be advised that the call will be recorded for training and monitoring purposes in the form of an automated voice message and via an information notice displayed at the surgery plus information contained on the surgery website.  Outbound calls to a patient will be automatically recorded, but we do not need to notify the patient that the call will be recorded, as this message is on the pre-recorded message when a patient calls the practice, as well as in the policy on our website which is viewable to the public.

Playback, Monitoring and Storage of Recorded Calls

Monitoring of the call recordings will be undertaken by the Practice Manager and Operations 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 will be stored securely for 36 months and access to these should be controlled and managed by the Practice Manager and Operations Manager.

All call recordings are stored on a central cloud system hosted by our telephone provider Focus Group, for no more than three years. These recordings are not automatically transferred to the clinical record of care. However, they can be transferred manually if it is deemed necessary for the direct care of that patient.  If it is deemed appropriate by the practice management team, call recordings can be withdrawn from the cloud and deleted or downloaded into an MP3 file format and stored on their secure drives. If a call recording is retrieved and downloaded, a copy of the original file will be made and saved in the practice secure folder. The original file will stay on the cloud unless manually deleted by the user.  If a call recording is deleted from the cloud, there will be no way of re retrieving the file at a later date.

Confidentiality

The UKGDPR/DPA2018 allows patients access to information that is held about them. This includes recorded telephone calls.  Requests for copies of telephone conversations can be made under the UKGDPR 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.