Best Practices for Recording of Customer Telephone Calls
Justification for Tape Recording
Taping telephone calls involves the collection of personal information.
Therefore, the practice should meet fair information practices. In the
case of organizations subject to the Personal Information Protection
and Electronic Documents (PIPED) Act, this form of collection must
comply with the legislation:
- Organizations should only record calls for specified
purposes;
- Those purposes must meet the reasonable person test;
- Organizations must make a reasonable effort to ensure that the
individual is advised of the purposes for which the information will
be used;
- The individual must consent;
- The information collected should only be used for the specified
purposes; and
- The tapes should be subject to the other provisions of the Act
with respect to matters such as safeguards, access, retention and
disposal.
The bottom line is that conversations should not be taped unless it
is "for purposes that a reasonable person would consider are appropriate
in the circumstances." The individual must be informed of the
taping and the purposes for it and the individual has to consent, except
in those limited cases where consent is not required. Otherwise, the
tape recording of customer telephone calls is unauthorized collection
of personal information. Taping Procedures
In order to comply with the PIPED Act, organizations should
take the following steps when recording conversations:
- The individual should be informed that the conversation
is being recorded at the beginning of the call. This can be done by
an automated recording or by the customer service representative.
- The individual should be informed of the purpose. The organization
must be clear about the purposes; an organization should not state
that it is recording the conversation for quality assurance purposes
if, in fact, the recording might be used for other purposes. This
could be done in a variety of ways - verbally, by pressing a
number on the keypad (in the case of automated messages) or with clear
messages on monthly statements. (For example: If you have any questions
about your bill please call 1-800-XXX-XXXX. Please note your call
will be recorded for...) If the individual proceeds knowing the
conversation is being recorded and the purpose of the recording, consent
is implied.
- The organization should offer alternatives if the caller objects.
The alternatives might involve not taping the call; visiting a retail
outlet; writing a letter; or, conducting the transaction over the Internet.
Other Privacy Implications
The recording of customer calls by organizations raises several other
privacy issues. Although a customer service representative could attempt
to write down the details of a conversation, a recording is qualitatively
different for a number of reasons:
- It will capture incidental information that the service representative
might not note - information that may not be germane to the call
but could be used by the organization for other purposes;
- It will capture the caller's tone of voice, that could also
be used for other purposes such as a legal proceeding; and
- It can be used to infer information about the caller, for example
ethnic origin and age that is not relevant to the purpose of the call.
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