We are a housing association, recording all calls to and from our call centre for lawful business purposes.
I know that it is not necessary to advise callers during the course of the call that the call is being recorded, so long as we have made reasonable effort to inform potential callers that this is our practice. We don’t have a recorded message advising callers that their call may be recorded, but we have taken actions to make our customers aware that recording may take place via letter headings, publications and our web site. In surveys we have been praised because, rather than having to go through an automated process to reach an operator, calls are answered directly by an advisor, so we would like to avoid a recorded message if we can.
Our dilemma is whether this is adequate when discussing sensitive personal information, as defined in the DPA and whether we are meeting the conditions in Schedule 3 of the Act. Should we be requesting explicit consent to record calls if sensitive personal information is being discussed?
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