Virtually all I am thinking about at the moment is the General Data Protection Regulation – I’m doing so much training on the subject!
One subject that came up in a recent training session was around those companies that routinely record telephone calls. You’ll be familiar with the sorts of thing – when you call you hear a pre-recorded message letting you know that the contents of your telephone call are going to be recorded for “training purposes”.
In many organisations that use this technology the HR professionals within the business are likely to have an exemption from their phone calls being recorded but what about line managers? If two employees were having a conversation would their conversation for example, about an individual employee, be recorded? Would then there be Data Protection implications because the subject of that conversation could make a Subject Access Request and ask to hear the audio of that conversation? Would the managers concerned even realise that that was the case?
The same is also true of things like using work mobile telephones to message or using apps like WhatsApp messages. If personal data was included and somebody did a Subject Access Request, you would have to look through these as well. Do managers appreciate that what they are writing could be seen?
What about personal devices? If a personal device is being used for work purposes the Information Commissioner’s attitude is that this becomes something that relates to the workplace and should be captured in a Subject Access Request. This is a really significant training point for managers who are unlikely to appreciate this.
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