Call Recording and Monitoring

The Call Recording & Monitoring Policy (the “Policy”) provided to you includes the current processes and procedures that are required to be followed if you are engaging in any type of call recording or monitoring.


From a business perspective, call recording and monitoring have many positives which can result in increased sales numbers.

But, there are federal and state laws that regulate call recording and monitoring. The main focus of these laws is privacy and ensuring that somebody who is being recorded or monitored consents to such recording or monitoring.

  • Currently there are 12 states that require consent of all parties to the conversation before a call can be recorded/monitored.
    • The 12 “all-party” consent states are currently: California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania, and Washington.

Purposes of Recording & Monitoring

The Company only allows recording/monitoring to take place under extremely limited circumstances

  • Below is a list of approved recording/monitoring purposes:
    • Improving customer service
    • Assessing and improving processes
    • Creating visible accountability for performance
    • Maintaining quality standards
    • Improving efficiency and productivity
    • Creating a record of transactions to demonstrate compliance
    • Improving training with respect to service calls
    • Helping a representative in a live situation

REMEMBER - Except for the purposes listed above, no recording/monitoring may take place.

Requirements of Recording & Monitoring

  • Frequency
    • In addition to limiting the purpose of recording/monitoring, the Company also requires the frequency of any recording/monitoring to be LIMITED.
    • The goal is NOT to record/monitor every single call, but instead to use this function in a way that will reasonable help your group achieve the goals it has set out in engaging in recording/monitoring
  • Inbound Calls
    • An automatic, pre-recorded disclaimer message must be played for all inbound calls that are intended to be recorded/monitored
      • Example: “This call may be recorded and monitored for quality assurance purposes.”
    • Must be done through a pre-approved call recording vendor (i.e. Five9, Marchex, etc.)
  • Outbound Calls
    • No recording or monitoring can take place in the states that require consent from all parties
    • You must work with a pre-approved vendor to ensure compliance

  • Use/Retention of Recordings
    • The use and retention of call recordings is limited to achieve the approved purposes identified earlier
      • Any unauthorized use or retention of recordings is a violation of the Policy
    • Inbound Calls
      • Recordings can only be stored for a maximum period of 90 days
    • Outbound Calls
      • Recordings can only be stored for a maximum period of 30 days
    • At the end of the maximum storage periods, all recordings must be securely disposed
    • You may not download or virtually save any recording without approval from the Legal Department
  • Access to Stored Recordings
    • Only approved individuals may access stored recordings
    • Employees/independent contractors are not allowed to access stored recordings

  • Recording as a Service
    • If your business unit provides call recording as a service to customers consult with the Legal Department before offering such service
      • There are additional requirements for this type of service
  • Webinars
    • Prior to recording webinars, you must obtain approval from the Legal Department and the unit’s General Manager
    • Only educational webinars can be recorded
    • All recorded webinars must include a written and verbal disclaimer at the start of the presentation, notifying all participants of the recording/monitoring
    • Storage of recorded webinars is allowed only for the customer’s use

Audit & Conclusion

  • Audit
    • The Legal Department will audit your call recording, monitoring, and retention practices to confirm compliance with the Policy

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