What are other housing associations retention with call recordings? When a dsar for call recording is received do you provide the actual recording or have the call transcribed?
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Jill Kinder
I’m from a housing association. We keep phone calls for 6 months and this is stated in our Privacy Notice. We would provide the actual call and if there was any third party information included we would bleep it out. We’ve not had to do that yet thankfully, as not sure how easy it would be!
JeremyClarkson
It’s fairly easy to bleep the third party information out if you have the software. It’s just tedious if the phone call was really long. I once had to listen to a 15 minute phone call several times, ensuring I bleeped out any named third party individuals.
JeremyClarkson
We release the actual recording but beep out any names mentioned in the recording. We do not transcribe calls.
d9d9d9
In regard to the second question, I recommend looking at Guidelines 01/2022 on data subject rights -Right of access. Of particular interest are likely para. 104 and Example 1 in para. 171.
In brief, the right to access also applies to the actual call recordings (and the transcripts, if they exist already). You should however analyse if giving access to this data has a negative impact on the rights and freedoms of the customer service agent.
In the example the EDPB gives, if the only personal data processed by the CS agent is their voice, it is unlikely to identify said CS agent and it would therefore not negatively affect their own rights. Therefore you may provide the full recording in the DSAR.
If other personal data by the CS agent is included (e.g. their name) you may consider emitting/censoring those parts.
I hope this helps!
(In regard to question #1 – stating the unhelpful obvious – it depends on the purpose you process the personal data for in the first place.)