Recording of Phone Conversations and Online Meetings
Phone conversations and online meetings can be voice recorded and stored to comply with regulatory requirements and for documentation purposes. Below, we have outlined how we process personal data in the context of voice-recorded conversations via telephone and online meetings ("Conversations").
Purpose and Legal Basis for Recording and Storing Conversations
Conversations are recorded and stored to document the content of our communication with you and are used for the purposes listed below:
We record and store conversations related to investment services to comply with our obligations under the MiFID II regulation and market abuse regulation, see GDPR Article 6(1)(c).
Additionally, we record and store conversations to document what has been said, occurred, and agreed during the conversation, see GDPR Article 6(1)(f).
Notification of Voice Recording
When you call our employee, you will generally be informed if the conversation is being recorded. In certain cases, specific incoming and outgoing conversations related to investment services are recorded without informing you before the conversation. In these cases, you have been previously informed about the recording in connection with a contractual relationship.
During an online meeting, you will be notified of the recording when you log into the meeting.
Use of Individual Recordings in Specific Cases
Handling complaints and addressing security incidents
We may listen to recordings when necessary to investigate specific cases, such as complaints from you or security-related situations, including potential fraud or threats to you, the bank, or our employees, see GDPR Article 6(1)(f), see GDPR Article 6(4).
Compliance and risk management
We may listen to recordings in some cases to check and ensure Danske Bank's compliance with internal and external rules, see GDPR Article 6(1)(f), see GDPR Article 6(4).
Retention and Deletion of Your Personal Data
Under the MiFID II regulation, we are required to retain recorded conversations related to investment services for seven years, see GDPR Article 6(1)(c). They will then be automatically deleted, see GDPR Article 5(1)(e).
We store conversations recorded for other reasons for 5 years, see GDPR Article 6(1)(f).
An additional 60 days are added to the retention periods before the recordings are deleted. The 60 days allow Danske Bank to begin handling cases received just before the end of the retention period.
If you or your Danske Bank conversation partner exercise rights defined under the GDPR, such as requesting access to a recorded conversation (before it is automatically deleted), we will review the recording and retain it as necessary to ensure documentation of compliance with our obligations and/or to address any related complaints, see GDPR Article 6(1)(f).
If you request that we restrict processing of a recorded conversation (before the deletion of the recording) according to GDPR Article 18, we are obligated to retain the recording for the duration of the restriction, see GDPR Article 6(1)(c).
If a recording is involved in specific disputes or security incidents, it will not be deleted until the case is finally resolved in accordance with the applicable statute of limitations, see GDPR Article 6(1)(f).
If the recording serves several different purposes, it is retained according to the longest retention period.
Right to Object
In certain circumstances, you have the right to object to the processing of your personal data in connection with the recording and storage of conversations according to GDPR Article 21. This is the case, for example, when the recording is based on our legitimate interests, see GDPR Article 6(1)(f).
Other Information and Your Rights
In certain circumstances, you have the right to access, correction, or erasure of personal data and/or to restrict processing. Read more about the processing of personal data and related rights in our privacy notices Privacy notice - Danske Bank.
