1. General Principles

The UK General Data Protection Regulation 2016 (UKGDPR) and the Data Protection Act 2018 (DPA) protects personal information held by organisations on computer and relevant filing systems. It enforces a set of standards for the processing of such information. In general terms it provides that all data shall be used for specific purposes only and not used or disclosed in any way incompatible with these purposes.

In the course of its activities the Practice will collect, store and process personal data, including the recording of all telephone calls, and it recognises that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

The Practice is registered with the Information Commissioner for all necessary activities under the UK GDPR/DPA.

2. Call Recording Overview

The purpose of this policy is to govern the procedures for call recording within Old Station Surgery and the subsequent management of access and use of telephone call recordings.

The implementation of recording of telephone calls was agreed in order to support effective delivery of service to our patients and support the training of practice staff.

Purposes of call recording

 The purpose of call recording is to provide an exact record of the call which can:

• Protect the interests of both parties;
• Assist in the assurance of quality of the service the Practice provides to its callers.
• Assist in the management of the practice’s patients care.
• To help protect practice staff from abusive and/or nuisance callers and provide evidence in assessing the serious of threats.
• To clarify the content of particular conversations in the event of a concerns or complaint either by a patient or a member of staff, and assist in the resolution of it.
• Help identify staff training needs, manage the performance of Practice staff, and to support in the training of new and existing staff members. (Staff are made aware of this as part of practice induction)
• Assist in the Practices quality control to identify any issues in practice processes, and aid in addressing them.
• Establish the facts and assist in the resolution of any medico-legal claims made against the practice or it clinicians;

All calls received or made from nominated extensions within the practice will be recorded utilising the practices call recording system. It must be noted that several nominated extensions within the practice operate on the "ad-hoc" call recording basis.  Call recordings may be retained securely in the practices system for up to 3 months.

Some recordings may be retained for longer than this for the following reasons:

• The content of the call is required to provide effective medical care to our patients: In this case the call may be retained indefinitely but will be moved to the relevant patient’s medical record. A transcription or summary of the call may also be made and attached with the audio recording.

 

• The content of the call is required for a complaint:In this case the recording will be retained until the completion of the complaint procedure and the expiry of any appeal period. If necessary the recording will be retained until the end of any tribunal proceedings.

 

• The content of the call has been identified as valuable for practice staff training:In this case the recording will be retained until it is no longer useful for this purpose. The data subject(s) will be informed if their call has been identified, asked to provide their consent and will have the right to object to this processing under the Data Protection Act 2018 and UK GDPR.

 

• The content of the call has been identified as evidence for Criminal proceedings or investigations: In this case the recording will be retained for the duration of the investigation or process. Depending on the allegations the data subject(s) may or may not be notified of this processing. The recording(s) may be shared with law enforcement as evidence under Schedule 2, Part 1 of the Data Protection Act 2018.

3. Communicating the Call Recording System

The Practice will inform the caller that their call is being monitored/recorded for the reasons stated above so that they have the opportunity to      consent by continuing with the call or hanging up. This will be communicated to patients by:

• Publishing a summary of this policy on the Practice website
• Informing all patients in the first instance via a recorded announcement for incoming calls

For outbound calls, including telephone consultations, where no automated announcement exists, the caller will inform the patient if their call is being recorded and the reasons for such

4. Procedures for managing and releasing call recordings

a) The recordings shall be stored securely, with access to the recordings controlled and managed by the Data Controller or any other persons                     authorised   to do so by the Data Controller

b) Access to the recordings is only allowed to satisfy a clearly defined business need and reasons for requesting access must be formally authorised          only by a relevant Partner or Manager. All requests for call recordings should include the following:

• The valid reason for the request
• Date and time of the call if known
• Telephone extension used to make/receive the call
• External number involved if known
• Where possible, the names of all parties to the telephone call
• Any other information on the nature of the call

c) The browsing of recordings for no valid reason is not permitted

d) The UK GDPR allows persons access to information that we hold about them. This includes recorded telephone calls. Therefore, the recordings will         be stored in such a way to enable the Data Controller to retrieve information relating to one or more individuals as easily as possible

e) Requests for copies of telephone conversations made as Subject Access Requests under the UK GDPR must be notified in writing to the Practice            immediately and, subject to assessment, he/she will request the call recording and arrange for the individual concerned to have access to hear the        recording

f) In the case of a request from an external body in connection with the detection or prevention of crime e.g. the Police, the request should be                  forwarded to the Data Controller who will complete the request for a call recording

g) Requests for copies of telephone conversations as part of staff disciplinary processes will only be released with the written agreement of the Data          Controller, or any other person authorised by the Data Controller, who will consult with the Data Controller before approval is granted

h) Recordings of calls will be encrypted and stored electronically in a secure environment. Call recordings will periodically be archived, in line with              electronic and paper file archiving time scales, to external hard drives

 

This policy will be reviewed every two years or more frequently where the contents are affected by major internal or external changes such as:

• Changes in legislation;
• Practice change or change in system/technology;
• Change in Senior personnel e.g. Practice Manager or Senior Partner or;
• Changing methodology.

 

Infringement of this Policy could expose the Practice to data breaches and subsequent fines or substantial compensation.

Any infringement of this Policy is considered by the Practice to be a serious offence and may result in disciplinary action. In the event that any member of staff feels he/she has accidentally breached the above policy will be required to inform their line manager immediately.

5. Equality Impact Assessment

This policy has been subject to an equality assessment.

Following assessment, this policy was not felt to be discriminatory or detrimental in any way with regard to the protected characteristics, or carers.