Why we Process your Information

We may record telephone calls made to and from the Surgery (ie not those calls made from homeworking) for:

• Quality Monitoring.
• Compliance
• Security Purposes.
• Training

We do this in the interests of offering a good service to our customers and to protect Public funds.

Sometimes calls may not be recorded if:

• There is a technical fault with the telephony system.
• A call handler is using equipment which does not let calls be recorded eg a mobile telephone.

Your information will not be transferred outside the UK.

Sharing your Call Recording

Your information may be shared with other organisations if they have a legal right to it.

How Long we keep your Call Recording

We will delete call recordings up to 6 months after the call was made. This ensures that any subsequent investigations can be completed.

Your Rights

The information you provided will be managed as required by General Data Protection Regulations. You have the right to receive a copy of the call recording. You have the right to request that the call recording be deleted if you believe we are processing it for longer than necessary.

Churchdown Surgery Telephone Recording Policy

Introduction

Churchdown Surgery has a telephone system that is capable of recording conversations. Like many other organisations, this is standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes.

The General Data Protection Regulations (GDPR) 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 the course of its activities Churchdown Surgery will collect, store and process personal data, including the recording of telephone calls, and it recognises that the correct and lawful treatment of this data will maintained in-confidence in the Surgery.

All inbound and outbound calls made to or by the Surgery via the telephone recording system (ie not those calls made from homeworking) will be recorded and will be retained for a 6 month period. Calls initiated as internal calls between extension users will not be recorded.

Communicating the Call Recording System

Churchdown Surgery is required to make reasonable efforts to communicate that calls will be recorded. This will be done by:

• Publishing a Telephone Privacy Notice on the Surgery’s web site.
• Advising all callers via the auto-attendant when calling the main Surgery number.

Procedures for Managing and Releasing Call Recordings

The recordings shall be stored securely, with access to the recordings controlled and managed by the Practice Managers and Partners. Access to the recordings is only allowed to satisfy a clearly defined business need and reasons for requesting access must be formally authorised by the relevant 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.

All requests for access to call recordings will be dealt with as a Subject Access Request (SAR). Browsing of recordings for no valid reason is not permitted. The Data Protection Act 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 Practice Managers/Partners to retrieve the information accordingly.

Access by Data Subjects

A data subject may make a subject SAR at any time to see the information which the Surgery holds about them; SARs must be made in writing. Upon receipt of a SAR, the Surgery shall have a maximum period of 30 days within which to respond. 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 immediately to a Practice Manager. As a rule the subject will be invited to the Surgery to listen to the recording.

Requests for copies of telephone conversations as part of staff disciplinary processes will only be released with the written agreement of the Senior Partner. Recordings of calls will be kept on file for a 6 month period.