Call Recording - Privacy Notice

During a telephone conversation with us, you will be informed if your conversation is to be recorded and the reasons for recording.

Processing activity - when a call is recorded (outgoing and/or incoming), we collect:

• a recording of the conversation;
• your phone number.

Call recording will be turned off, when your credit or debit card details are given, in line with Payment Card Industry Data Security Standards (PCS DSS).

Lawful bases[1] - our lawful bases for processing your personal information are:

• UK GDPR Article 6(1)(c) - where processing is necessary for compliance with a legal obligation to which we are subject i.e. Health & Safety at Work etc. Act 1974 – to comply with our duty of care to protect our employees from harm;
• UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives include:

1. •    ensuring you receive a quality service from us
2. •    to investigate and resolve a complaint
3. •    protecting our staff’s personal safety and welfare e.g. from abusive callers
4. •    for the detection, investigation and prevention of crime (including fraud)

These objectives constitute our legitimate interests for call recording.  A third party could reasonably expect and conclude to be subject to call monitoring in these specific situations. We have a Legitimate Interests Policy that sets out how this information will be handled.

We may process the following personal information:

• Special Category Personal Data as defined byUK GDPR  Article 9(1) e.g. health, pursuant to UK GDPR Article 10 and Data Protection Act 2018, section 10(5), Schedule 1, Part 2 paragraph 6(1) and 2(a) – processing is necessary for reasons of substantial public interest; and
• Criminal Offence Data as defined by UK GDPR Article 10 and supplemented by the Data Protection Act 2018, section 11(2), Schedule 1, Part 2 paragraph10(1) (preventing or detecting unlawful acts).

We have a Data Protection Policy, which sets out how this information will be handled.

Data sharing - your information will be shared with the relevant service department and if you have requested and/or complained about a service, may also be shared with our external service provider (where we have outsourced the service). We may also share your information with a number of other organisations for example Kent County Council’s social services where we have concerns about your and/or another individual’s well- being and the Ombudsmen (where you have complained to the Ombudsmen and we are asked to investigate your complaint). We may share your information with elected Councillors and/or Member of Parliament where you have asked them to represent you.

We rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent and Medway Information Agreement for further details on our sharing arrangements.

Retention period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept in accordance with the retention period(s) referred to in our Information Asset Registers unless exceptional circumstances require longer retention e.g. a pending court case. All information will be held securely and disposed of confidentially.

Anonymisation - your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports such as showing the number of complaints we receive and/or equalities monitoring, but not in a form which identifies anyone.

Right to object -  where processing your personal information is required for the purposes of our legitimate interests (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.

You may request that your call is not recorded.  In this situation, you will be advised to contact us by letter or email.

Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.

Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights.

GDPR/Privacy Notices/ Call Recording Privacy Notice