Recording of Customer Telephone Calls
Revised: March 2018
Organizations record customer telephone calls for a variety of reasons, such as ensuring quality of customer service, dispute resolution or training/development of staff.
These recordings involve the collection of personal information and therefore must be handled appropriately—from collection through to disposal.
Canada’s federal private sector privacy law, the Personal Information Protection and Electronic Documents Act (PIPEDA), sets the ground rules for how businesses handle personal information in the course of commercial activities.
Businesses subject to PIPEDA must comply with the Act when recording calls—whether the customer or the organization initiates the call. Businesses contracting out call centre, telemarketing and similar services must ensure that these third parties also follow the rules.
When it comes to recording customer telephone calls, this page outlines what individuals can expect and how businesses subject to PIPEDA can comply. For those not subject to PIPEDA, the guidelines below are best practices.
Customer calls and personal information
Businesses generally record calls with the intention of capturing the content of their conversations with customers. However, these recordings can also collect personal information beyond the intended purpose of a call. For example, a recording can capture:
- voice characteristics, such as tone, and
- incidental personal information offered by the caller not relevant to the call.
Some businesses use recordings of customers’ voices as a means of verifying their identity during future calls. For more information about the privacy considerations of using a biometric such as voice for authentication purposes, please refer to our Guidelines for Identification and Authentication and Data at Your Fingertips: Biometrics and the Challenges to Privacy.
How to record a customer call while respecting privacy law
The following guidelines provide customers and organizations with more detailed information about their rights and obligations under PIPEDA when recording customer telephone calls:
- The organization can only record a call for purposes that a reasonable person would consider appropriate under the circumstances.
- The organization must inform the customer that they are recording a call, clearly state the purpose of the recording and ask for their consent. It is important to get the customer’s consent in several ways to ensure that their consent is meaningful. For example:
- by the customer pressing a number on the keypad (in the case of automated messages); and
- with clear messages on monthly statements. (For example: If you have any questions about your bill please call 1-800-XXX-XXXX. Please note your call will be recorded for XX purposes.).
- If the customer proceeds with the call knowing that the conversation is being recorded and why, their consent is implied.
- If the caller objects to the recording, they can ask that the company not record the call or use an alternative approach such as:
- visiting a retail outlet;
- writing a letter; or
- completing the transaction online.
In very limited circumstances, consent is not required under PIPEDA when recording customer calls, for example:
- calls made to collect a debt;
- calls made to investigate a potential fraud; or
- calls where the customer’s knowledge that the call is being recorded could hamper the organization’s ability to obtain accurate information.
- Customers have a right to request access to the recording at a later date. The length of time an organization keeps the recording will vary.
- An organization may only use the information collected for the purposes specified.
An organization should not state that it is recording the conversation for quality assurance purposes if the recording will be used for other purposes, such as marketing or profiling.
Organizations must also ensure they comply with all of their PIPEDA obligations when recording customer calls, including having appropriate safeguards and limiting retention of recordings. For further information on PIPEDA requirements, please refer to our PIPEDA Toolkit for Businesses.
If a customer has concerns about privacy practices with respect to recording customer calls, they should bring it to the attention of the business. We have Tips for Raising Your Privacy Concern with a Business that may help.
If a customer is not satisfied with the response to their privacy concerns, they may be able to file a formal privacy complaint with our Office.
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