Privacy Notice – Telephone Call Recording

1. Purpose

Ghosh Medical Group records telephone calls to support the delivery of safe, effective, caring, responsive and well-led services, in accordance with Care Quality Commission (CQC) regulations, General Medical Council (GMC) guidance, and UK data protection legislation.

2. Scope

This policy applies to all incoming and outgoing telephone calls to and from the practice and to all patients, service users, carers, members of the public, and staff.

3. Why We Record Telephone Calls

Incoming calls are recorded to:

• Ensure the accuracy of information, requests, and advice should a query arise
• Support staff training and supervision
• Assist with complaints and incident investigations
• Provide evidence of abusive, threatening, or inappropriate behaviour

Outgoing calls are recorded to:

• Ensure accurate communication and continuity of care
• Support learning and service improvement
• Assist with complaints, incidents, and duty of candour processes
• Provide evidence where abusive or unacceptable behaviour occurs

4. Lawful and Proportionate Processing

Call recording is lawful, necessary, and proportionate, supporting patient safety, quality assurance, and effective governance, in line with UK GDPR and health and social care regulations.

5. Transparency

Callers are informed that calls may be recorded at the start of the call.
This Privacy Notice is available via the practice and on request.

6. Choice and Alternative Access

If you object to call recording, you will need to end the call once informed.
Alternative communication methods remain available, including attending the surgery in person, to ensure services remain accessible and responsive.

7. Confidentiality and Access

• Recordings are treated as confidential information
• Access is restricted to authorised staff only
• Staff are trained in confidentiality and information governance
• Recordings are used only for purposes related to care delivery, safety, and governance

8. Storage, Retention and Deletion

(CQC – Safe & Well-Led)

Telephone call recordings are stored securely on the practice phone system

• Recordings are held for a maximum of 30 days
• If a recording is not required for action, such as a complaint, incident, safeguarding concern, or investigation, it is automatically deleted after 30 days
• Where a recording is required for a specific purpose, it will be securely downloaded by the provider and retained in line with relevant NHS and data retention guidance
• Secure deletion processes are in place to ensure recordings are not retained longer than necessary

This ensures data is handled in a safe, proportionate, and well-governed manner, consistent with CQC expectations.

9. Data Sharing and Transfers

• Call recordings are not transferred outside the European Economic Area (EEA)
• Recordings are not shared with third parties unless required by law, regulation, or for safeguarding or complaint investigation purposes

10. People’s Rights

Individuals have the right to:

• Request access to their personal data
• Request correction of inaccurate information
• Raise concerns about how their information is handled

Requests are managed openly, fairly, and without delay.

11. Governance and Oversight

• Call recording forms part of the practice’s information governance and quality assurance framework
• Use of recordings supports learning from incidents, complaints, and feedback

Oversight is maintained through management review, staff training, and audits