this Policy provides information about the following:
- What is the purpose of call recording?
- What calls are recorded?
- What happens to the recordings?
- Who can access call recordings?
At The Orchard Medical Centre, our telephone system provider is X-on (otherwise known as Surgery Connect). Our contract began on 19/04/2024, the call recording functionality is set to go live on the 3rd of July 2024.
1) What Is The Purpose Of Call Recording?
In accordance with the UK GDPR, the lawful basis for processing data also applies to the recording of telephone calls. To conform with these regulations, the practice must:
- Advise callers (incoming and outgoing) that the call is being recorded.
- Provide information about these recordings. This information must be made available to the public and explain: What is being recorded, why it is being recorded, how it is stored, and who can access the recordings.
- Hold a register for all call recordings that have been accessed. This register must show: Who has accessed the recording, why was the recording accessed, and what happened with the recording (was it listened to, deleted, or extracted from the cloud).
More information can be found here:
- https://www.gov.uk/government/publications/data-protection-act-2018-overview
- https://gdpr-info.eu/art-6-gdpr/
Call recording provides the ability to record a voice conversation over an audio source. This allows us to capture our telephone conversations into a digital file format, which can then be retrieved and listened back to in the future.
At The Orchard Medical Centre, the main purpose of procuring a call recording system is for training and monitoring purposes. Specifically the monitoring of activity made to and from our Health navigation team. We may use call recordings for:
- Training our new practice staff.
- Identifying practice staff training needs.
- Establishing facts relating to these calls. For example, to be used during our complaints procedure, or if required in the prevention or detection of crime.
- Protecting staff from nuisance or abusive calls.
2) What Calls Are Recorded?
At The Orchard Medical Centre, we record incoming and outgoing calls of certain teams within the organisation. Depending on the business needs, this may change in the future.
The types of calls that may be recorded are:
- Calls made to the surgery using our main number (0117 980 5100)
- Calls made to the surgery using our professional bypass number.
- Calls made to the practice prescription team professional number.
- Calls made from our Health Navigator Team using our main telephone number (0117 980 5100)
- Calls made to or from a staff members Direct Dial, where those staff members work within the Health Navigator team or the prescriptions team.
- Voicemails left on our practice cancellation line (option 2 on our switchboard)
Types of calls that will not be recorded are:
- Calls made to our Surgery using our main line (0117 80 5100) whereby the caller or recipient has explicitly declined their call being recorded.
- Calls made from our surgery line by members of staff who do not work within the health navigator team, such as all clinicians.
- Calls made from a staff members Direct Dial, where those staff members do not work within the Health Navigator team.
3) What Happens To The Recordings?
All call recordings are stored on a central cloud system hosted by our telephone provider for no more than three years. These recordings are not automatically transferred to the clinical record of care. However, they can be transferred manually if it is deemed necessary for the direct care of that patient.
Specifically, X-On have provided the following information about the security of these call recordings: The Call Recordings from your service are held on our secure servers with quadruple site resilience for no more than 3 years. They are destroyed on a rolling basis once the retention period is up. Secure Tier 3 UK Data Centres and all web certificates are securely signed using 2048-bitRSA with SHA-256. Our storage servers are encrypted at rest so the files are not in a plain readable format. We use a mix of open-source components with our own proprietary code. All of this together makes the software solution that is SurgeryConnect. X-on Health holds valid and current certification for ISO9001, ISO14001, ISO22301, ISO27001 and Cyber Essentials Plus.
If it is deemed appropriate by the practice management team, call recordings can be withdrawn from the cloud and deleted or downloaded into an MP3 file format and stored on their secure drives.
In the event that a call recording is retrieved and downloaded, a copy of the original file will be made and saved in the practice secure folder. The original file will stay on the cloud unless manually deleted by the user.
In the event that a call recording is deleted from the cloud, there will be no way of re retrieving the file at a later date.
4) Who Can Access These Call Recordings?
Call recording access is limited to a very small number of senior members of staff, these include:
- The Practice Management team.
- The Practice I.T Support team.
- X-on (only if they have gained explicit consent for each recording by a member of practice staff).
Patients at our Surgery have the right to request a copy of their call recordings under what’s known as a Subject Access Request. All requests should be emailed to tomc@nhs.net. You have the right to submit a Subject Access Request in writing, by email, or verbally.