Last revised: 10th July 2019


DMN has a telephone system in the Customer Service, Driver Control and Recruitment Departments that is capable of recording conversations. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes.

All calls received into these departments will be recorded by DMN and will be retained for a period of six months after which they will be deleted unless retained for the purposes specified in this policy. Recordings will only be used for the purposes specified in this policy.

DMN employees may on occasion also have calls they receive reviewed by an external research firm conducting a mystery shopping programme on behalf of DMN. The purpose of these mystery shopping programmes is to independently evaluate our customer service standards. These organisations will conduct these research programmes, including recording of calls with the appropriate safeguards, within the legislative framework detailed in paragraph 5 and the memorandums of understanding between them and DMN.

Purpose of this telephone recording policy

In order to maintain high standards and protect the public and staff we need to record all telephone calls received into the Customer Service, Driver Control and Recruitment Departments and retain them for a limited period of time.

We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes:

  • The Regulation of Investigatory Powers Act 2000
  • The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000
  • The Telecommunications (Data Protection and Privacy) Regulations 1999
  • The General Data Protection Regulation 2018
  • The Data Protection Act 2018
  • The Human Rights Act 1998.

Scope of policy

All calls made to the Customer Service, Driver Control and Recruitment Departments will be recorded. Under normal circumstances a call will not be retrieved, monitored or retained for longer than six months unless:

  • it is necessary to investigate a complaint
  • it is part of a management ‘spot check’ that customer service standards are being met. NB. Recordings used for quality monitoring purposes will be retained for 12 months
  • there is a threat to the health and safety of staff or visitors or for the prevention or detection of crime
  • it is necessary to check compliance with our own or regulatory procedures
  • it will aid standards in call handling through use in training and coaching our staff. However, this will only be permitted if the recording is edited so that the caller remains anonymous and the member of staff who was party to the call agrees to its being used in this way.

If it becomes clear that a communication is private or the person making the call says that they do not wish to have their call recorded, the call recording will be stopped.

Collecting information

Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with data protection law. It will be:

  • adequate, relevant and not excessive
  • used for the purpose(s) stated in this policy only and not used for any other purposes
  • accessible only to managerial staff after securing permission from the Head of Secretariat
  • treated confidentially
  • stored securely
  • not kept for longer than necessary and will be securely destroyed once the issue(s) in question have been resolved.

Advising callers that calls are being monitored/recorded

Where call recording facilities are being used, we will inform the caller that their call is being monitored/recorded for quality/training purposes so that they have the opportunity to consent by continuing with the call or hanging up.

Where can I find out more?

You may find the following related link useful:

Privacy Policy

Or for further information on the policy please contact us.