Privacy Policy

We collect personally identifiable information, like names, postal addresses, email addresses, etc., when voluntarily submitted by our visitors. The information you provide is used to fulfil your specific request, unless you give us permission to use it in another manner, for example to add you to one of our mailing lists.

The Site may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information.

We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation.
We may do so when:

• Permitted or required by law
• Trying to protect against or prevent actual or potential fraud or unauthorized transactions
• Investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

Your personally identifiable information is kept secure. Only authorized employees have access to this information. All emails and newsletters from this site allow you to opt out of further mailings.

The Legal Position Regarding Telephone Recording

There are a number of laws which require certain obligations to have been met before telephone calls can lawfully be monitored.

(1) Regulation of Investigatory Powers Act 2000 "RIPA"

An interception is only lawfully carried out if one of the following applies

(i) The person intercepting the call has reasonable grounds for believing that it has the consent of both the caller and the intended recipient of the call to intercept; or
(ii) The interception is carried out by a business in compliance with the Lawful Business Practice Regulations (see below.)

(2) The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (the "Regulations")

Interception is authorised if the business which is intercepting the call has made all reasonable effort to inform potential users that their communications may be intercepted, and the interception is then carried out:

(i) To establish the existence of facts (eg to evidence a business transaction);
{ii) To assess or demonstrate that standards "which ought to be achieved" are achieved (eg quality control and training standards);
(iii) To prevent or detect a crime, or for purposes of national security;
(iv) To assess compliance with regulatory practices or procedures applicable to the business;
(v) To investigate or detect unauthorised use of the communications system; or
(vi) To determine whether communications are relevant to the system controllers business.

(3) The Data Protection Act 1998 ("DPA")

Recording (and use of recordings) where Company X would be able to establish the identity of either party to the call, either directly from the recording or from other information which it is conceivable that Company X could obtain, would require you to first:

(i) Have informed that party how the recording would be used;
(ii) Obtain consent for the recording to take place (This may be implied from the fact that the customer has been notified and not object, but it is you should obtain explicit consent if the call reveals any information classified as sensitive by the DPA, ie details of race/ethnic background, political opinion, religion, trade union membership, physical/mental health, sexual life, offences committed or legal proceeding bought.)
(iii) The obligations in relation to processing of that data also apply, so that the data must be kept for longer than necessary, under secure conditions and must be accessible to the customer at their request.

(4) The Employment Practices, Data Protection Code

This regulates employer or employee relations and so is more relevant to the monitoring of calls from your staffs point of view. The code states that employees should be informed about any monitoring of their calls and that their consent should be obtained as required under the DPA. The code does provide exemptions from this obligation, for instance where monitoring is necessary to investigate criminal activity, but with provisos, for instance specific examples of criminal activity should have been identified before monitoring begins.

5) Human Rights Act 1998

The Act provides that "everyone has the right to respect for his private life and family life, his home and his correspondence". Legal cases involving the monitoring of phone calls have recommended that to ensure that this right is protected employees whose calls are monitored should be given access to a private line over which personal calls can then be made, during their lunch break for example.

(6) Codes of Practice FSA Handbook Code of Business Handbook and Direct Marketing Associations Code of Practice

Neither code adds any material requirements to the points made above.

(7) Telecoms License obligations The Service Provision License

Private and business use of a telephone system is regulated by certain DTI licenses. These include a similar requirement to that set by the Regulations that "every reasonable effort" to inform parties to a telephone conversation that recording may take place should be made.

A general overview of interception, recording and monitoring of communications.

The interception, recording and monitoring of telephone calls is governed by a number of different pieces of UK legislation. The requirements of all relevant legislation must be complied with. The main ones are:

Regulation of Investigatory Powers Act 2000 ("RIPA")
Telecommunications (Lawful Business Practice)(Interception of Communications) Regulations 2000 ("LBP Regulations")
Data Protection Act 1998
Telecommunications (Data Protection and Privacy) Regulations 1999
Human Rights Act 1998

***Effective 8th March 2012***

If you have any questions, concerns, or comments about our privacy policy you may contact us using the email below: