Telephone Recording Policy

Telephone Call Recording Policy

Effective date: 1^st January 2026

Review date: 1^st January 2027

Version: 1.0

1. Purpose
   This policy explains how and why telephone calls are recorded by Military World Ltd, how recordings are stored and protected, how individuals can obtain a copy of a recording, and how long recordings are retained.

The organisation is committed to handling telephone recordings fairly, securely and transparently, in accordance with applicable data protection legislation and other relevant legal requirements.

2. Scope
   This policy applies to telephone calls made to or from Military World Ltd where calls are recorded, including calls made through the organisation’s telephone system, customer service lines, business mobile phones or other approved recording systems.

It applies to employees, workers, contractors and other authorised users of the organisation’s telephone systems.

3. Why calls are recorded
   Telephone calls may be recorded for one or more of the following purposes:

• Quality assurance and service improvement.
• Training and development.
• Monitoring and reviewing customer service.
• Investigating complaints, disputes or incidents.
• Maintaining an accurate record of communications.
• Protecting the organisation, its employees and service users.
• Detecting and preventing fraud or other inappropriate activity.
• Meeting legal, regulatory or contractual obligations.

Calls will not be recorded or used for purposes that are incompatible with the purpose for which they were originally collected.

4. Notification of recording

Where calls are routinely recorded, callers will be informed that recording is taking place at the earliest appropriate opportunity.

The notification will explain, where appropriate:

• That the call is being recorded.
• The purpose of the recording.
• Who is responsible for the recording.
• How further information about the organisation’s use of personal data can be obtained.
• How a person can request access to their recording.

Where recording is required for a specific legal, regulatory or operational reason, additional information may be provided where appropriate.

5. Storage and security

Telephone recordings are treated as confidential information and will be stored securely.

Access to recordings will be restricted to authorised employees or third parties who have a legitimate business or legal need to access them.

Appropriate technical and organisational security measures will be used, which may include:

• Password protection and access controls.
• Encryption where appropriate.
• User authentication.
• Audit logs and monitoring.
• Secure transfer methods.
• Restrictions on downloading, copying or sharing recordings.

Recordings must not be copied, downloaded, emailed, stored on personal devices or shared with unauthorised individuals.

6. How long recordings are retained

Telephone recordings will normally be retained for [e.g. 12 months] from the date of the call.

At the end of the retention period, recordings will be securely deleted or permanently destroyed, unless there is a legitimate reason to retain them for longer.

A recording may be retained beyond the normal retention period where:

• It is required for an ongoing complaint or investigation.
• It is relevant to actual or anticipated legal proceedings.
• There is a legal or regulatory requirement to retain it.
• A specific legal hold or preservation requirement applies.
• There is another documented and lawful reason for extended retention.

Where a recording is retained beyond the standard period, it will be reviewed periodically and deleted when it is no longer required.

7. Obtaining a copy of a telephone recording

An individual may request a copy of a telephone recording that contains their personal data, subject to applicable data protection legislation and any relevant exemptions.

Requests should be made to:

• Address: Data Protection, Military World, Sussex House, 190 South Coast Road, Peacehaven, East Sussex, BN10 8JJ
• Email: gdpr@military.world

To help locate the recording, the requester should provide as much information as possible, including:

• Their name.
• The telephone number used, where applicable.
• The approximate date and time of the call.
• The number or department they called.
• The reason for the request, if relevant.
• Any other information that may help identify the recording.

The organisation may need to verify the requester’s identity before releasing a recording.

8. How copies will be provided

Where the organisation is required to provide a copy of a recording, it will normally be supplied using a secure method appropriate to the circumstances.

This may include:

• A secure electronic download.
• An encrypted electronic file.
• Another secure method agreed with the requester.

The organisation will take reasonable steps to ensure that recordings are not disclosed to unauthorised individuals.

Where a recording contains information relating to other people, the organisation will consider whether that information should be removed, redacted or otherwise protected before the recording is disclosed.

In some circumstances, applicable legal exemptions may mean that all or part of a recording cannot be provided.

9. Requests for access

Requests for recordings will be handled in accordance with the organisation’s data protection procedures.

Where the request constitutes a data subject access request, the organisation will normally respond within the applicable statutory time limit.

If the organisation cannot locate a requested recording, the requester will be informed.

If the recording has already been securely deleted in accordance with this policy, the organisation will explain this where appropriate.

10. Requests for deletion

Individuals may have rights to request deletion of their personal data in certain circumstances. However, the right to deletion is not absolute.

A recording may need to be retained where there is a legitimate legal, regulatory or operational reason to do so.

Requests for deletion should be made using the contact details in section 7.

11. Use of recordings

Recordings will only be accessed and used for legitimate purposes.

Employees must not:

• Access recordings without authorisation.
• Listen to recordings out of curiosity.
• Share recordings with colleagues who do not have a legitimate need to access them.
• Make unauthorised copies.
• Upload recordings to personal or unauthorised systems.
• Use recordings for personal purposes.

Any suspected misuse or unauthorised disclosure must be reported to [appropriate manager/data protection officer] immediately.

12. Third-party providers

Where telephone recording services are provided by an external supplier, Military World Ltd will take appropriate steps to ensure that the supplier handles recordings securely and in accordance with applicable contractual and data protection requirements.

Third-party providers will only retain recordings for as long as authorised by the organisation and in accordance with agreed retention requirements.

13. Complaints

Anyone who has concerns about the recording, storage, use or disclosure of a telephone recording should contact:

• Address: Data Protection, Military World, Sussex House, 190 South Coast Road, Peacehaven, East Sussex, BN10 8JJ
• Email: gdpr@military.world

Complaints will be investigated in accordance with the organisation’s complaints procedure.

Individuals may also have the right to complain to the relevant data protection supervisory authority.

Requests should be made to:

• Address: Data Protection, Military World, Sussex House, 190 South Coast Road, Peacehaven, East Sussex, BN10 8JJ
• Email: gdpr@military.world

This policy will be reviewed at least annually and whenever there is a significant change to the organisation’s telephone recording systems, legal requirements, retention arrangements or processing activities.