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VERACODE CALL AND SCREEN RECORDING POLICY

Last Updated September 12, 2019

Contents

Introduction

Applicability and Scope

Policy

How Will the Recordings Be Used?

How Will This Policy Affect Staff and Customers?

Performance and Risk Management

Communicating the Policy - Managers & Employees

Procedures for Managing and Releasing Call Recordings

Breaches and Non-Compliance

Information and Training

Violations of Policy

Introduction

This policy outlines Veracode’s call and screen recording process.

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

  • 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
  • Assist in quality control to identify any issues in processes, with a view to improving them
  • Are accurately and efficiently transcribed onto the customer relationship management system (CRM) or to other databases.

Applicability and Scope

This Policy applies to all Employees (as defined below). It also applies to all Contractors (as defined below) to the extent such Contractors are responsible for dealing with Veracode information or third party confidential information in connection with their services to Veracode.

Policy

This policy applies to all staff including agency workers. All customer centric outbound calls as well as calls via the Automatic Call Distribution (ACD) – covering all Veracode Offices and Home Workers – may be voice and screen recorded. This will include;

  • All external incoming calls via direct dialed calls made to a sales or BDRs extension.
    • Recording will be limited to the staff only when calls are received from California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania and Washington unless consent from all parties has been received.
  • All external outgoing calls made by the Sales or BDR team, including calls made through third party software.
    • Recording will be limited to the staff only when calls are dialed to California, Connecticut, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Pennsylvania and Washington unless consent from all parties has been received.
  • All internal incoming and outgoing calls made by the Sales or BDR team, including calls received through third party software.
  • Meetings, such as a web based demonstration, will be recorded after all parties on the call have given consent to the recording.

The advisement message is; ‘Thank you for calling Veracode; please be advised that your call may be recorded for quality assurance purposes'

Recording automatically stops when:

  • The Veracode associate finishes the call
  • The call is transferred to a non-Veracode Associate extension (i.e. when a Veracode Associate is no longer part of the call)

Recording will be manually stopped when:

  • Any person expresses the desire to not be recorded

Stopped recordings will automatically recommence when:

  • The Veracode associate commences a new call.

How Will the Recordings Be Used?

Recordings will be used as part of the quality management process within the Sales and BDR team. Veracode Associates and managers calls will be discussed as part of the one to one process or in the context of account/opportunity strategy.

Recordings will also be used to assist in Sales and BDR quality control to identify any issues in processes, with a view to improving them.

Recordings will be deleted after 365 Days. However, some may be saved if they have important information for the effective management of the account and/or opportunity. where calls have been abusive or otherwise problematic, or where complaints have or are expected to result. Good examples of calls will be saved as well. These calls will be saved for as long as necessary and deleted only at the discretion of the Manager concerned.

Recordings will not be sent or forwarded except in exceptional circumstances and with the approval of a Regional Vice President in the organization.

How Will This Policy Affect Staff and Customers?

Recordings constitute the personal data of both the caller and the Veracode Associates. Therefore they will be managed in such a way that the rights of data subjects (callers and Veracode Associates) can be fulfilled, and all the obligations of the data controller (Veracode) are observed, as per Veracode data protection policy.

Every inbound caller is informed that the call is recorded and why before the conversation is opened. This will be done through a pre-recorded message in Veracodes telephone welcome message before connection is made to a Veracode Associate.

A caller may request that their call is not recorded. In this situation the Veracode Associate will manually terminate the call recording or the caller may be advised to contact Veracode either in writing or by email.

Monitoring outbound and inbound call recordings may only be undertaken by authorized personnel, for example an individual’s direct supervisor or manager, in order to assess individual performance in relation to agreed call handling standards or in order to improve services. This exclude web based conference calls that are associated with the team and not to an individual user. in this case the recording is available across the platform.

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

Recordings identified as suitable for training purposes should not be played back in a public arena without the prior consent of the employee involved and subject to appropriate data protection consideration of any third party rights involved.

Data is not routinely collected for the purpose of disciplinary investigations; however any recordings which are considered relevant in disciplinary proceedings cannot be disregarded and may still be referred to. As such employees responding to disciplinary procedures should be allowed access to such data, subject to appropriate data protection consideration of any third party rights involved.

The Company will also ensure that, where appropriate, recording data is used to support employees in the investigation of any complaints or allegations resulting from calls, subject to data protection consideration of any third party rights involved.

Performance and Risk Management

This policy will be reviewed annually (or in response to any legislation change) to ensure it is achieving its aims.

Leadership with individuals who are affected by this policy will be responsible for ensuring this policy is complied with through 1 to 1‘s.

Communicating the Policy

Managers

As part of the induction processes it is a manager’s responsibility to ensure that all employees are aware of the areas that are subject to recording and monitoring and that Company telephone systems should not be relied on as confidential if used for the discussion of private matters.

Managers must ensure that employees are made aware of the Company’s procedures in relation to private telephone calls and are provided with appropriate information as stated in this policy and any associated policies.

All employees who are involved in the use, handling and storage of call and screen recording data must be given appropriate training and guidance. It is important that this includes access to training and guidance in the application of relevant policies; for example, the Company’s Data Protection Policies, and in particular Data Protection, Employment Records.

In areas where recording takes place Managers must ensure that where appropriate employees are provided with access to a sample of their recordings along with appropriate feedback, coaching and training.

Where a recording has been identified as part of a disciplinary investigation, managers should seek further guidance from the HR team. Employees must be informed of any recordings which form part of such investigations and be provided with the opportunity to respond. The employee and his or her representative must be informed of the data protection consideration in respect of any third party who may be identifiable in the evidence.

Employees

All employees must adhere to the Veracode’s Call Policy.

Employees must adhere to the Veracode’s procedures in relation to private telephone calls as outlined in the Employee Handbook, therefore the recording of calls will not form any infringement on an individual under their right to privacy.

Procedures for Managing and Releasing Call Recordings

The recordings shall be stored securely, with access to the recordings controlled and managed by the Business Systems.

Browsing of recordings for no valid reason will not be permitted.

In the case of a request from an external body in connection with the detection or prevention of crime e.g. the police, the request should be forwarded to the General Council who will respond to the request for information.

Breaches and Non-Compliance

Recording will be used in any disciplinary investigation in exactly the same way as other items of evidence are used currently.

Any breach of these guidelines may result in action being taken.

Information and Training

Training on how to access call and screen recording will be available within the Sales and BDR documentation to those managers who require it. All additional questions should be directed to the Business Systems.

Violations of Policy

Violations of this Policy will be treated as a performance issue and may result in disciplinary action, up to and including termination of employment in accordance with applicable corporate policies or, in the case of Contractors, termination of the contractual or other business relationship.