This policy and procedures apply to the recording of telephone calls by The Oxford Open Learning Trust.


This policy and procedures are made under the company’s Data Protection Policy to set out how the organisation will comply with data protection requirements when recording telephone calls.

Objectives of making audio recordings

The purpose of telephone call recording is to provide an exact record of the call which can:

  • help monitor for and assess child protection issues
  • help identify staff training needs;
  • help protect staff from abusive or nuisance calls;
  • help improve staff performance;
  • establish the facts in the event of a complaint either by a customer or a member of staff and so assist in resolving it;

Which calls will be recorded?

The Oxford Open Learning Trust will aim to record all calls between its customers and itself.  This includes

  1. Calls to and from your student adviser
  2. Calls to and from your tutor

Calls that are not routinely recorded

  1. Calls between The trusts administration staff
  2. Calls between the administration staff and the tutors

What if the caller objects to the call being recorded?

Due to safeguarding the Trust considers the recording of the above call types to be essential.  If you do not wish to have a call recorded please email the office or tutor with your enquiry.

How long will the recordings be held?

Recordings are automatically deleted after 3 years.

Who can monitor calls?

Monitoring of the call recordings may only be undertaken by authorised personnel and those who were part of the original call.  The authorised people are.

  • The Customer Service Manager
  • The Head of Operations
  • The Safe Guarding Officer
  • Directors of the company

Any playback of recordings will take place in a private setting and staff will be given the opportunity to listen to their own recordings in order to receive positive feedback and developmental support through coaching and training interventions.

When using a recording for training purposes we will obtain the prior consent of the employee involved and consider any data protection implications for any third parties.

Secure storage for recordings

Recordings shall be stored securely, with access to the recordings controlled and managed by The Head of Operations. The system for playback will be accessed by login and will be restricted to authorised personnel as above.

Subject access

Callers have the right to access personal data that relates to them. Requests for access to recorded calls should be passed immediately to the Customer Service Manager and a transcript or recording will be provided within one calendar month.  You will need to provide details of the call including the time, date and telephone number.

Employees who want access to recordings of their calls should speak to the HR manager.

Access by other parties

Recordings are not generally shared with third parties except in response to subject access requests. The organisation has the discretion to share personal data with the Police and HMRC in the investigation of offences. It may be obliged to share recordings if there is a legal obligation to do so.

Policy owner

The person responsible for this policy is Greg Smith, Head of Operations.

Policy in force dates

This policy was adopted 03/12/2021

It will be reviewed as required