ICT Security policy appendix P: Call recording policy
Last updated April 2026, version 2.0
Contents
- Introduction
- Policy purpose
- Key messages
- Notifying customers about call recording
- Procedures for managing and releasing call recordings
- Personal data
- Call recording and storage legislation
- Retention of call recordings
1. Introduction
Wyre Forest District Council’s telephone system records conversations for the purpose of compliance, security, training and quality purposes. This policy outlines how call recordings are managed, stored, accessed and communicated to callers.
The council may record incoming and outgoing calls to and from the organisation. Calls between officers, where the system is enabled, may also be recorded. This is currently used by council tax and business rates staff.
Recordings are normally retained for up to one year.
2. Policy purpose
This policy ensures that call recording processes and procedures comply with the Data Protection Act (DPA) / General Data Protection Regulations (GDPR)
3. Key messages
Why are calls recorded
Call recordings support the Council to:
- Identify staff training needs and improve performance
- Protect staff from abusive or nuisance calls
- Assist in complaint and dispute resolution
- Prevent or detect crime
- Support quality control and ensure accuracy of information
- Analyse customer demand and improve customer experience
Need to notify customers about calls being recorded
The caller should be advised if the call is being recorded. Incoming and outgoing calls are currently recorded for the following teams:
- Customer service staff via the Customer Service Centre (the hub)
- Business Support staff within the operational services team
- Revenue staff (council tax and business rates)
Incoming calls to 01562 732928, using options 3 and 4, are recorded.
Procedures for managing and releasing call recordings
The recordings of all calls will be stored securely, with access to the recordings controlled and managed by authorised managers.
Access to recordings is only allowed to satisfy a clearly defined business need.
Personal data
Personal data collected, while recording activities, will be processed fairly and lawfully in accordance with the Data Protection Act 2018.
Call recording and storage legislation
Calls will be recorded and stored within the Council’s call recording system. This system can only be accessed by authorised managers.
Retention of call recordings
Recordings will be stored securely and retained for 1 year, after which they will be automatically deleted. Any recordings which may need to be used for the purposes of longer-term investigations, that have been extracted from the system, will be kept in a secure place for as long as deemed necessary by the authorising manager.
4. Notifying customers about call recording
This policy applies to hub contact centre staff, business support staff in operational services and revenues staff, including those working from home. Customers are informed via the corporate welcome message that incoming calls are recorded. This applies to all calls to 01562 732928 (options 3 and 4). A recorded message is played for all calls dealt with by revenue staff where call recording is enabled.
Outgoing calls made by the above teams will be recorded. Customers will be told at the start of the call if it is being recorded. A pre-recorded message is played for all revenue calls. Staff in other teams will advise the call recipient verbally that the call is being recorded. All other calls we make will not be recorded.
Calls recorded include:
- All incoming and outgoing calls made to/from the above teams.
- Transfers between Customer Service Advisors or Revenues Officers (including staff‑to‑staff conversations during the transfer)
- All other internal transfers between staff outside the above teams are not recorded.
This policy is published on the Council’s website.
Staff are informed of call recording as part of the induction process.
To comply with Payment Card Industry Data Security Standard (PCI DSS), phone payments use secure technology that prevents card details from being recorded. Manual payments are captured using a designated unrecorded phone line.
A caller may request that their call not be recorded. In this situation, the caller will be advised to contact Wyre Forest District Council by an alternative channel, such as email.
5. Procedures for managing and releasing call recordings
The recordings of all calls will be stored securely, with access to the recordings controlled by authorised managers.
Access to recordings is permitted only when there is a clearly defined and justified business need.
If a complaint is made about a staff member, the line manager may request access to the call recording to establish the facts and respond appropriately. Recordings will not be accessed proactively for the purpose of identifying issues to formally discipline staff members.
Under GDPR, individuals have the right to request access to the personal information we hold about them, including recorded telephone calls. Requests for copies of call recordings must be submitted in writing as a Subject Access Request, and should include relevant details—such as the date, time, and participants of the call—to help us locate the recording.
Requests can be submitted by email or online.
- Email to: dataprotection@wyreforestdc.gov.uk
- Website: Subject Access request
In the case of a request from an external body in connection with the detection or prevention of crime, for example, the police, the request should be forwarded to the Data Controller, who will complete the request for a call recording.
6. Personal data
Personal data collected while recording activities will be processed fairly and lawfully in accordance with the Data Protection Act 2018.
It will be:
- Adequate, relevant and not excessive.
- Used for the purposes stated in this policy and not used for any other purposes.
- Accessible only to authorised managers for training purposes and investigations.
- Treated confidentially.
- Stored securely.
- Not kept for longer than necessary.
7. Call recording and storage legislation
Calls will be recorded and stored within the Council’s call recording system with restricted access and can only be accessed by authorised managers.
Recordings constitute the personal data of both the caller and the member of staff. Therefore, they will be managed in such a way that the rights of data subjects (caller and staff member) can be fulfilled, and all the obligations are observed as per Wyre Forest District Council’s Data Protection - Privacy Policy
8. Retention of call recordings
Recordings will be stored securely and retained for 1 year, after which they will be automatically deleted. Any recordings which may need to be used for the purposes of longer-term investigations that have been extracted from the system will be kept in a secure place for as long as deemed necessary by the authorising manager.
Recordings will be treated confidentially and used, stored and disposed of in accordance with the requirements of the:
- Data Protection Act 2018
- General Data Protection Regulation (GDPR)
- The Employment Practices, Data Protection Code
- Regulation of Investigatory Powers Act 2000 (RIPA)
- The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (LBP Regulations)
- The Telecommunications (Data Protection and Privacy) Regulations 1999
- The Human Rights Act 1998
Policy review
This policy will be managed and reviewed with the ICT policy, or sooner if needed, in the case of new risks and/or changes in legislation.