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FSA guidelines on call recording

In March 2008 the Financial Service Authority has introduced in its policy statement the requirement for all companies that meet certain criteria[1] to keep a recording of their telephone conversations. In March 2010 this requirement has been extended to also include mobile phones conversations.

In brief, these policy statements define the following guidelines:

1. A firm must take reasonable steps to record relevant telephone conversations and keep them for a minimum of 6 months.

2. Call recordings must be stored in a medium that allows the storage of the information in a way accessible for future reference by the FSA, and so that the following conditions are met:

2.1 the FSA must be able to access the records readily;

2.2 it must be possible for any corrections or other amendments, and the contents of the records prior to such corrections and amendments, to be easily ascertained;

2.3 it must not be possible for the records to be otherwise manipulated or altered.

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It is important to note that the FSA is not responsible for certifying telephone systems that comply with the guidelines above or label them as ‘FSA compliant’. However, it is the responsibility of any FSA regulated firm (and their suppliers) to make sure that their telephone system complies with the FSA guidelines. In particular, the service provider must put in place adequate steps, agreed with the client, to avoid that call recordings can be manipulated and if any changes to the records are made these amendments must be easy to identify and trace.

[1] To read the complete guidelines please refer to Policy Statement “Telephone Recording: recording of voice conversations and electronic communications” – COBS 11.8

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