At GBW, we prioritise transparency and the protection of personal data. This Recording Policy outlines our practices regarding the recording of telephone calls and the handling of this data. Our commitment is to ensure compliance with legal standards and to foster trust with our clients and partners.

Telephone Call Data Handling

We record all incoming and outgoing telephone calls. A pre-recorded message informs participants at the start of each call that it will be recorded. These recordings serve several legitimate business purposes, including:

  • Deterrence and prevention of crime, particularly fraud.
  • Assistance to law enforcement bodies in criminal investigations.
  • Investigation of complaints or criminal acts.
  • Staff training and improvement of customer service.
  • Maintenance of business records, especially sales.
  • Monitoring compliance with regulatory obligations.
  • Establishment, exercise, and defence of legal claims.

This list is illustrative and may expand as necessary.

Security and Confidentiality

Recorded data is stored securely on our premises, accessible only by authorised management personnel for legitimate business purposes. We employ password protection and, where applicable, encryption to safeguard against unauthorised data access, alteration, or destruction.

We may engage third parties for the maintenance of our telephone systems, ensuring they process personal data solely for specified purposes and in compliance with our directives. Contracts with these entities include stringent data protection and confidentiality clauses.

Access and Disclosure

Access to recorded data is granted under specific circumstances:

  • Compliance with law enforcement requests.
  • Staff training enhancements.
  • Subject access requests by individuals.
  • Resolution of cash transaction discrepancies or verbal contract disputes.

Disclosure to third parties occurs only under legal obligation, with measures to limit data shared and protect incidental identities.

Retention Period

Recorded data is retained only as long as necessary for the purposes outlined in this policy and our Privacy Policy. Generally, telephone call data is kept for five years in compliance with money laundering regulations. Data is permanently deleted when no longer needed, with secure disposal of any physical recording media.

Subject Access Requests

Individuals have the right to access their personal data, including telephone call recordings and transcripts. Requests should be directed to or our postal addresses. We may obscure third-party voices in disclosures to protect privacy.

Requests to Prevent Processing

Individuals may object to our data processing practices. While we consider all objections, we may demonstrate compelling legitimate grounds for processing that override individual rights. For further details, please contact us as indicated above.

Contact Us

For enquiries or concerns regarding this policy, please reach out through our website contact form, email, call us at +44 020 3934 6384, or write to The Leadenhall Building, 122 Leadenhall Street, London, EC3V 4AB

This policy reflects our dedication to lawful, fair, and secure data handling practices, ensuring the trust and confidence of our clients and partners.