Call Recording Privacy Notice

Introduction

Revell Research Systems Limited (the Company, we, us, our) is providing you with this information in order to comply with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), which require us to tell you what we do with your personal information.

This notice relates to the personal data that is processed by us when we record a telephone or teleconference call (such as Microsoft Teams, PowWowNow or Zoom). It also relates to any voicemails that you leave on any of these services.

If you are joining a call through an online platform (such as Microsoft Teams or Zoom) then our Online Meetings and Teleconferences Privacy Notice will also apply and covers the exchange of data between participants, which goes beyond recording the call's audio or video.

Who is collecting this personal data?

Revell Research Systems Limited is collecting this data as the Data Controller.

Revell Research Systems Limited is registered with the Information Commissioner in the United Kingdom as a data controller under number Z186392X.

Who are we sharing your personal data with?

We may share personal data processed under this notice, where necessary and proportionate, with the following categories of recipient:-

• The courts and those involved in legal proceedings and non-contentious matters, including solicitors and barristers
• Police and law enforcement agencies
• Our subsidiaries, our ultimate holding company and all its subsidiaries
• Agents acting on our behalf
• Service providers (including associates)
• Call participants

We will not sell or rent your data to third parties. We will not share it with third parties for marketing purposes.

Why are we collecting and what will we do with your personal data?

We collect personal data in order to record discussions between participants and to facilitate note taking. We also record conversations in routine calls to help us monitor and improve the quality of our call handling, staff training and the service we offer to our clients.

We also offer voicemail facilities on our telephone system and some teleconference platforms so callers can leave us messages when we can't answer their call immediately.

We normally record calls only where participants have been informed and the recording is undertaken on the basis of consent. In limited circumstances, we may record or retain calls under our legitimate interests where necessary to protect those working for us, prevent or investigate fraud, establish, exercise or defend legal rights, investigate complaints or protect the security of our business and systems.

We may process this data for the purpose of the proper administration of our business and in communicating with you as well as maintaining backups.

You should be aware that we may process your personal data under additional privacy notices should your data be collected for other specific purposes. These might include those relating to usage logs, online meetings and teleconferences.

We may share data with the courts and associated professionals in establishing, exercising or defending our legal rights. We may share data in reporting crime to or when co-operating with the police and law enforcement agencies.

What is the legal basis for processing?

Our lawful bases for processing are Consent and Legitimate Interests.

• consent - the participants have agreed that the call may be recorded. They may withdraw their consent at any point.
• legitimate interests - the Company has legitimate interests in administering its business, protecting those who work for it, preventing and investigating fraud, investigating complaints, protecting the security of its business and systems, establishing, exercising or defending legal rights and maintaining backups.

These lawful bases are detailed in Article 6 of the UK General Data Protection Regulation (UK GDPR):-

• the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6(1)(a)).
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Article 6(1)(f)).

How are we collecting this information?

We collect personal data about you through the recording facilities of our telephone systems and teleconference platforms when calls are made, received, joined or recorded. Certain participant details may be collected automatically by these systems when you use them.

Please note that our Usage Logs Privacy Notice will apply to you as our systems automatically record interactions between us.

What information are we collecting?

We collect the following personal information when we record calls and meetings facilitated by our telephone system or the teleconference platforms we use.

• caller's identifier (typically a telephone number or email address and usually collected automatically when the call is made)
• video and/or audio
• date, time and duration of recording
• participant contact details supplied automatically (depending on platform)
• call metadata

Our telephone system records the telephone number presented to it by the caller's telephone company (CLI details). The teleconference platforms we use typically maintain 'profile information' that you supply when you use these systems that are shared with us when you participate in a call. These details tend to include basic contact details such as name, job title, organisation, telephone and email address.

You may also provide details about yourself in the call that is recorded.

You should read this privacy notice in conjunction with our Online Meetings and Teleconferences Privacy Notice if you are joining a call over the Internet, as this covers the exchange of data between participants, which goes beyond recording the call's audio or video.

Who can see your information within the Company?

Access to your personal data is restricted to authorised directors, staff and associates who require it for legitimate business purposes.

How long is your information kept?

We will only keep your information for as long as necessary. The retention period is either dictated by law or our legitimate requirements. Once your information is no longer needed it will be securely and confidentially destroyed.

We typically retain personal data in call recordings for no longer than twelve months and more often than not delete recordings once they have been dealt with.

How secure is your information?

We take appropriate technical and organisational measures to protect your information against unauthorised access, disclosure, alteration and destruction. You can read more about our approach to security at www.rrs.co.uk/security.

Who keeps your information updated?

You are responsible for keeping your personal details up-to-date. Please advise the Company of any changes.

Will your information be used for any automated decision making?

No. We do not undertake solely automated decision making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

Our Privacy Statement

You can access the Company's Privacy Statement at www.rrs.co.uk/privacy. This statement provides you with more information about how we address data protection and privacy as well as informing you of your rights.

Other Privacy Notices

You are likely to interact with us in more than one way, so our other privacy notices may apply to you in different scenarios. We are open and transparent about how we use your personal data. You can find all of our Privacy Notices at www.rrs.co.uk/privacy.

Changes to this Notice

Any changes to this privacy notice will take effect when the revised notice is published. If these changes affect how your personal data is processed, the Company will take reasonable steps to make sure you know.

Further Information