Civil Service Shared Services Centres (SSC) have an interactive voice response (IVR) telephone system that is capable of recording conversations. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring and training purposes.
All incoming calls received via the IVR are recorded by the SSC and will be retained for a period of six months for PeoplePoint and three months for Payroll Shared Services (PSS). These recordings will only be used for the purposes specified in this policy. The call recording facility is automated and only accommodates incoming calls received from outside by the SSC through the IVR only (Main number). Outbound calls to people made from the Shared Service Centre will not be recorded. If calls are transferred within the SSC, the call recording will continue until the call is ended. The recordings will be used for training and quality monitoring purposes, for the verification of what was said during a phone call if there is a dispute or complaint, to protect staff from abusive behaviour, and to verify the customer’s agreement during certain service requests as appropriate.
Call monitoring: The process of listening to, observing, or recording an employee’s incoming phone calls from customers through the SSC IVR Telephone System.
In order to maintain high standards all telephone calls received via the IVR will be recorded.
The SSC will ensure that the use of these recordings is fair and is compliant with the requirements of the relevant legislation. This includes:
- Data Protection Acts 1988 and 2003
- Interception of Postal Packets and Telecommunications Messages (Regulation) Act 1993
Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with the Data Protection Acts 1988 and 2003. It will be:
- Adequate, relevant and not excessive;
- Used for the purpose(s) stated in this policy only and not used for any other purposes;
- Accessible only to managers and team leaders;
- Treated confidentially and stored securely; and
- Not kept for longer than necessary and will be securely destroyed once the issue(s) in question have been addressed or resolved.
Communicating the Call Recording System
The Shared Services Centre is required to make reasonable efforts to communicate that calls will be monitored and recorded. This will be done by:
- Placing a message on all inbound IVR calls stating calls are being recorded,
- Putting a notice on the SSC’s Portal informing users of the service and Customer Departments/PSB’s,
- Sending an e-mail message to all staff and informing new staff at induction training,
- Notices will be placed on notice boards reminding staff that incoming calls are recorded.
Use of recordings
Call recordings may only be used for the specified purposes, i.e.
- To monitor the quality of call handling and customer service,
- Staff training, coaching and support,
- To verify what was said during a phone call if there is a dispute or complaint,
- To protect staff from abusive behaviour,
- To verify the customer’s agreement during certain service requests as appropriate.
Procedures for managing and releasing call recordings
- The recordings shall be stored securely, with access to the recordings controlled and managed by a Functional Manager assigned by the Head of the SSC with the nominated employee from the Office of the Chief Information Officer (OGCIO),
- Access to the recordings is only allowed to satisfy a clearly defined business need,
- Call recordings may only be played back from the system for use within the SSC by team leaders and managers,
- Browsing of recordings for no specific purpose is not acceptable,
- The Data Protection Act allows persons access to information that is held about them. This includes recorded telephone calls,
- As appropriate, requests for copies of telephone conversations, where required, as part of staff disciplinary processes will only be released with the written agreement of the Head of Human Resources who will consult with the Data Protection Officer before approval is granted,
- Recordings of calls will be disposed of after six months for People Point and after three months for Payroll Shared Services (PSS). However, if there is a justified need to retain a specific recording for a longer period, this may be reviewed and the retention period amended. Information will not be retained for a longer period than necessary.
Retention of Recorded Calls
All recorded IVR calls shall be retained by the SSC for no longer than six months for PeoplePoint and no longer than three months for PSS from the date of the recording.
This policy will be reviewed by the Shared Services Transformation Unit at the end of each financial year; to ensure it is fit for purpose and is aligned with any legislative changes.
This policy was prepared by the Shared Services Transformation Unit, Reform and Delivery Office, Department of Public & Expenditure and Reform in collaboration with key stakeholders, with adherence to the Data Protection Legislation and the guidance note (Dept. of Finance 10/2008) Protecting the Confidentiality of Personal Data. Any changes or queries regarding the policy should be directed to Ms Hilary Murphy Fagan, Chief Executive Officer, National Shared Services Office at (01) 604 5745 or Hilary.Murphy-Fagan@nsso.gov.ie