UNICAF AND UNICAF UNIVERSITY

Recording Policy

1. Summary - Introduction

"UNICAF" and "UNICAF University" operates a telephone system which is capable for recording conversations. As many other organizations that operate call centers, this is a standard practice where telephone calls and/or live chat conversations are records for the achievement of quality monitoring, training, compliance and safeguarding purposes. Live Chat Conversations and/or Calls, incoming or outgoing, in the department of the Call Center and/or the Students Support might be recorded and will be retained and/or collected as per our Data Retention Policy and our Data Protection Policy. The use of these recordings is strictly limited for the purposes specified in this policy.

The chat recording along with the call recording facility and/or system and/or software, is automated and accommodates both outgoing and/or incoming calls of the Call Center and the Student Support Department of "UNICAF". This policy specifies that if a call is transferred to a department that do not have call recording system and/or software on its line, it means that recording will cease to act once the call is successfully transferred. Likewise, if a call comes in, or is a result of a non-call recorded line and then is transferred to one that is under the recording system and/or software, then the staff member should notify the caller that their call will be recorded.

All the employees working in the Call Center and the Student Support Department are responsible Purpose of this Policy

UNICAF and UNICAF University aims to maintain high standards and protect the public and staff. Within the framework of the foregoing, we need to record telephone calls, incoming or outgoing, in and/or from the Call Center and the Students Support Department, along with live chat conversations, and retain them for a limited period of time.

UNICAF and UNICAF University shall ensure that the use of these recordings is fair, is complying with all the requirements of the relevant legislation. This includes:

1. The Protection of Natural Persons Against the Processing of Personal Data and the Free Traffic of these Data Act of 2018 (Cyprus Legislation).
2. The European General Data Protection Regulation (GDPR);
3. The European Convention of Human Rights;
4. The Constitution of the Republic of Cyprus.

2. Scope of this Policy

All live chat conversations, along with all calls, incoming and/or outgoing to and/or from the Call Center and/or the Student Support Department, can be recorded. Under normal circumstances, a call will not be retrieved or monitored unless:

1. It is necessary to investigate a complaint;
2. It is part of a management 'spot check' that our standards are being met;
3. Provides assurance of UNICAF and UNICAF University quality standards and policies.
4. There is a threat to the health and safety of staff and/or visitors and/or for the prevention and/or detection of a crime;
5. It is necessary to check compliance with regulatory procedures; or
6. It will aid standards in call handling through use in training and coaching our staff.
7. It is for safeguarding purposes.
8. It is for helping to protect Officers and/or employees from abusive or nuisance calls;

3. Collection of Data

Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with the current "Protection of Natural Persons Against the Processing of Personal Data and the Free Traffic of these Data - Act of 2018, and the European General Data Protection Regulation. Data collected shall be:

1. Adequate, relevant and not excessive
2. Used for the purpose(s) stated in this policy only and not used for any other purposes;
3. Accessible only to managerial and/or senior staff and subject to the permission of the Head of the relevant Departments and/or the Data Protection Officer and/or the CEO;
4. Handled and managed confidentially;
5. Kept and/or stored securely; and
6. Not kept for longer than necessary and will be securely destroyed once the issue(s) in question have been resolved.

4. Advising callers that calls will be monitored/recorded

Where a call will be transferred from a non-recording line to a line where recording facilities and/or mechanisms and/or software are being used, we will inform the caller and/or the receiver of the call that the call will be monitored/recorded for quality/training purposes so that they have the opportunity to consent by continuing with the call or hanging up.

All the relevant staff, is totally and absolutely obliged to be aware of the current policy, and if he/she is questioned he/she must inform callers and/or receivers that the call is recorded for quality/training purposes. Any employee that might fail to comply with the requirements of this policy will face disciplinary procedure and appropriate measures and/or decisions can be taken by UNICAF and UNICAF University.

5. Related policies

1. Data Protection Policy
2. Data Retention Policy

6. Procedures for managing and releasing call recordings

The recordings shall be stored securely, with access to the recordings controlled and managed by the Data Protection Officer.

Access to call recordings can be given to Managers, Senior Directors, Heads of the relevant Departments, only for executing their tasks and duties for maintaining the quality of our standards and services, and/or any other purpose that is expressed by this policy.

Subject to our Data Protection Policy individuals may request access to their call recordings. As it is provided by our Data Protection Policy "UNICAF acknowledges individuals (data subjects) rights under the Data Protection Policy to access any personal data held on our systems and in our files upon their request, or to delete and/or correct this information if it is proven to be inaccurate, excessive or out of date." Therefore, the recordings will be stored in such a way to enable the Data Protection Officer to retrieve information relating to one or more individuals as easily as possible. Recordings of calls will be kept on file and periodically archived to external hard drives and stored in accordance with our data protection policy.

The browsing of recordings for no valid reason and/or purpose is prohibited by this policy.

Every individual has the right to access the information that we hold about him/her. This includes recorded telephone calls.

7. Consent

By agreeing and accepting the current policy you freely and unconditionally consent to receive calls from Unicaf. You also consent that when receiving a call from Unicaf and/or when you are calling Unicaf, subject to the current policy the call may be monitored or recorded for quality assurances purposes. You also consent that when you operate a conversation with Unicaf through the Live Chat, subject to the current policy the conversation may be monitored or recorded for quality assurances purposes.