Knowledge Capture Voice - Compliance Enabled Call Recording
Ever since 1875 when Sir Alexander Graham Bell first invented the telephone people have wanted to record conversations and retrieve them.
Whilst this basic requirement has not changed the reasons for recording calls and being able to quickly and efficiently retrieve them certainly has. Organisations today face more legal, financial, regulatory, audit, compliance, customer service and data analysis reasons for recording calls than ever before.
In a survey carried out in 2003 by IBM Business Consulting Services, it was revealed that CFO’s see managing governance, compliance and risk as one of their top five business concerns. When you consider that CFO’s rated this as their third most important business issue behind raising shareholder value and measuring/monitoring business performance you begin to get a sense of the impact compliance is having on corporations.
With legislation such as the Data Protection Act and the Freedom of Information Act forcing organisations to provide both employees and members of the public access to any company data that is relevant to them, including call recordings, the need to capture, index and archive
telephone conversations is proving stronger than ever. It has now reached the point where the recording of a telephone conversation is almost academic, it is the indexing and management of these calls that is proving business critical.
If we take for example an organisation with two hundred employees who also have an enterprise wide call recording system, the legislation surrounding the Data Protection Act entitles these employees to be given access to all call recordings that involves them. For nearly every
organisation that currently has a call recording solution the ability to comply with this one piece of legislation is almost impossible.
Even if just one or two employees asked for this data, the time, money and effort that would be spent trying to locate, identify, retrieve and supply all the telephone conversations relating to a specific employee from a badly indexed, tape based call recording solution would make the exercise an almost impossible task. If you then consider the feasibility of supplying this
information to tens or hundreds of employees, then the business might just as well sign a blank cheque and settle with the employees and regulators out of court, rather than trying to provide this information.
For the banking and finance organisations the legal and compliance regulations around call recording are even worse. Not only do they have to worry about the Data Protection Act and how this affects their employees and clients, but also the wealth of financial based regulations, such as those applied by the Financial Services Authority (FSA) which strongly advises its members to capture and archive telephone conversations.
Outside of industry specific requirements for telephone call recording and retention, there is the US lead Sarbanes-Oxley legislation, which is forcing all businesses in Europe with US based parent companies to ensure that company specific financial information is captured and protected from modification, deletion or mutilation. When company specific information includes telephone call recordings then the ability to comply with this regulation using a traditional call recording solutions is largely impossible.
One of the unique features of the Sarbanes-Oxley ruling is that for the first time an audit based compliance regulation states (and enforces) that anyone who knowingly alters, destroys or conceals a record, document or tangible object will be imprisoned for not more than 20 years.
“SEC. 802. CRIMINAL PENALTIES FOR ALTERING DOCUMENTS.
(a) IN GENERAL.—Chapter 73 of title 18, United States Code, is amended by adding at the end the following:
Ԥ 1519. Destruction, alteration, or falsification of records in Federal investigations and bankruptcy
"Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States or any case filed under title 11, or in relation to or
contemplation of any such matter or case, shall be fined under this title, imprisoned not more than 20 years, or both.”1 1 Sarbanes-Oxley Act of 2002
Following this ruling it is now no longer just a case of writing out a large cheque to settle for a business non compliance, it is the organisations Directors and Chief Executives who will also pay for this failure through a period of incarceration.
When Do You Delete?
The converse to being able to capture and retain telephone call recordings for legal and compliance reasons, is that businesses equally need to prove that data has been deleted once the lifetime of the data has expired.
The balancing act now is to ensure that data is held for the legally required period and is yet destroyed as soon as possible, to remove any potentially damaging or mitigating information without it being a risk to the organisation in the future.
If you imagine a telephone conversation that could have taken place between a financial adviser and his/her client, stating that an endowment policy would return an average 10% growth each year, and then on failure to deliver this promise the client decides to take legal action against the organisation, the potential of having this telephone conversation requested as evidence in a court of law could prove extremely damaging and expensive.
Just to compound matters organisations also have to handle event based retention such as a mortgage being repaid early and the associated call recordings being deleted sooner than expected. During the course of a call recordings life several events could happen that would change the retention policy of the recording such as a client closes his/her account, an employee
leaves an organisation and a legal retention policy changes with the archival period of the recording being increased or decreased.
All of these events and situations have to be handled and it is now no longer as simple as keeping all telephone conversations and business data archived forever on a ‘just in case’ basis, as the compliance and financial implications of doing this are simply too high to be justified.
What Is The Answer?
Based on the detailed and specific requirements of all these laws and regulations the traditional call recording solutions of today simply cannot cope, and creates an exposure to every business that is performing call recording and also to those that are not recording calls, but should be. The existing technologies inability to index calls, retrieve them when required and store them on non-editable media, define and control retention periods, ensure secure and controlled access makes the call recording technology of today close to useless or a highly dangerous business liability at best.
The resolution to this issue was to take a step back from the historic standalone, proprietary call recording solutions and look at what would meet both the basic requirements of recording a call whilst also achieving the business requirements of the new millennium.
Call Recording for a New World
For a telephone call recording solution to succeed in today’s compliant business world it has to be able to achieve a number of requirements. These being:
(1) Ability to support business data indexing, (2) Ability to support strict user access restrictions,
(3) Ability to define and manage retention policies (with both time and event based retention),
(4) Ability to ensure recordings cannot be deleted during the defined retention periods and yet 100% removed following completion of the retention period,
(5) Ability to suspend deletion of call recordings based on external events i.e. audits, court orders.
(6) Ability to ensure recordings are archived on compliant storage devices (WORM). In the world of telephone call recording these requirements are a revelation. However, for other areas of most organisations the ability to meet all of these requirements has been in place for many years through the utilisation of an Enterprise Content Management solution.
Enterprise Content Management (ECM) systems are now seen as the tool of choice for telephone recording archival and it is not difficult to see why. ECM solutions have had to support business data indexing from day one and the ability to provide this for telephone call recording is no different. Capturing a telephone conversation without business data indexing is inconceivable in the world of Content Management solutions, as this would mean that business Content could only be found based on crude index fields, such as date and time, versus the wealth of business data that could be applied to speed up this search, for example the following index fields
could be used: client name, number, policy, call reason, call outcome and agent.
As well as providing a fast and effective method of retrieval, Content Management solutions have had to prove their worth in security and user access control, as the data contained on these systems has generally been extremely sensitive. For Enterprise Content Management solutions the concept of individual data object level security has had to be in place to support this capability which naturally lends itself for controlling access to individual business telephone call recordings. The idea of Records Management and data control has been an evolutionary step for most Enterprise Content Management solutions, and hence the ability to control data deletion, and define a call recordings retention policy is a feature that most solutions can easily demonstrate. When Records Management functionality is used with business data indexing, the potential to define call recording retention rules with event based retention is extremely simple and yet powerful, and a tremendous business asset to most corporate organisations. Put simply
Records Management immediately resolves the issue of knowing how long a recording should be archived for and when it is due for deletion.
The final feature of the Enterprise Content Management solutions that lend themselves perfectly for telephone call recording archival, is their ability to fully utilise a wealth of storage devices. Whether this be Write Once Read Many (WORM) Optical and Tape devices or the new
compliance focused storage devices as IBM’s Data Retention 450 (DR450) and EMC’s Centera. If you then consider that these solutions fall squarely into an IT departments remit, and are hence being regularly
monitored, backed up and disaster recovery optimized, then the worries that have existed with the traditional call recording solutions being ‘out of sight and out of mind’ in a dark corner of the telecoms room suddenly disappear.
Central Client File
With the introduction of Enterprise Content Management based call recording comes an additional benefit, and that is the ability for the first time to have one central client file of information.
This central client file can now include telephone calls, faxes, emails, scanned documents such as letters and signed contracts, electronic documents i.e. MS Word and Excel files plus also digital images and video. This change in mind set introduces the potential for a truly 360 degree view of your clients and their business information.
It is no longer the case of having ‘islands’ of data such as emails on one server, call recordings on a disconnected proprietary system, faxes in a paper tray and paper documents in filling cabinets combining to form a unmanageable array of unstructured business data. With the concept of a central client file comes the ability to unify all this data and information into one central location, which can be quickly located, retrieved and used at precisely the times when needed i.e. at the time of the client’s phone call.
This shift in business process changes an organisations entire dynamics. The concept of having all unstructured business information in one central client file removes the current delays in having to search for information, the need to place callers on hold or worse having to call a customer back once you have located all the necessary information, thus incurring additional cost for the business and frustration for your clients.
Knowledge Capture Voice – Compliance Enabled Call Recording
Integritie have over the last few years established themselves as global providers of Enterprise Content Management solutions. In doing so Integritie have experienced first hand the frustrations organisations face daily in searching for call recordings with little or no indexing information, centrally controlling and managing the recordings and especially with the lack of functionality to define recording retention policies and long term cost effective storage mediums.
Based on these experiences and from direct customer requirements Integritie have created a unique call recording technology called Knowledge Capture Voice. Knowledge Capture Voice squarely addresses these issues and moves call recording up to the next business level. Knowledge Capture Voice instantly differs from traditional call recording solutions, in that it is primarily a software based solution versus a telephony solution, and as such comes with the facility to index calls either manually or automatically with both telephony data i.e. date, time, extension number and call duration, plus also meaningful business data such as client reference number, name, policy number, claim, call reason and call outcome.
The ramifications of this is that organisations can now for the first time find recorded conversations with index fields that are meaningful to the business and will enable fast and accurate call retrieval, versus the anguish of having to listen to all calls captured on a tape for any given date and time.
During the creation of Knowledge Capture (KC) Voice the format of the call recordings were also reviewed, and it was felt that having recordings captured in proprietary formats that only users with
the licenced software could play was wrong, and in direct contradiction to the principles of being able to centralize and share call recordings. Based on this finding call recordings in KC Voice are captured in an open format, which is common to all PC’s such as WAV and ADPCM. This means that calls can be shared around an organisation (assuming the necessary security privileges are present), and if desired emailed to a third party for review and potentially rapid dispute resolution. Knowledge Capture Voice also took the bold step to not supply a call recording repository, but instead encourage the release of call recordings and index data straight into an existing
Enterprise Content Management solution such as IBM’s Content Manager, OnDemand, FileNet, Documentum and Hummingbird.
By taking this bold step Integritie felt that customers could leverage their existing Enterprise Content Management solution investments, achieve fast and accurate call recording retrieval via the respective application clients, ensuring highly controlled and stringent security levels, and recording access restrictions whilst also achieving the utopia of having a central client file of unstructured customer information.
The utilisation of having call recordings archived into an organisations Enterprise Content Management solution has also meant that long term call recording archival could be handled by cost effective storage devices such as Optical, SAN and tape through common IT hardware interfaces such as IBM’s Tivoli Storage Manager. This shift in open data formats and open storage devices has enabled call recording solution managers to enjoy the benefits of having recording storage options, rather than limited proprietary and expensive storage devices which traditional call recording vendors have promoted.
The final piece of the solution jigsaw that has been achievable through the combined abilities of having call recordings indexed with meaningful business data and also archived into Enterprise Content Management solutions, is the potential to define recording retention periods.
Through tools such as IBM’s Records Manager it has now become possible to assign a retention policy to a call recording, and for the Records Manager application to monitor each and every recording in the system, and prompt a system administrator when calls are due to expire or to place a suspension order on a call(s) should an audit or investigation be taking place.
This one piece of combined functionality has revolutionized how call recordings are captured, archived and managed and has brought voice recording from the 1800’s straight up to the 21st century, delivering a truly compliance enabled recording solution.
Further Information
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