Do financial firms need to retain call recordings until the end of time?

Call recording retention periods

There is a distinct lack of clarity on retention periods for call recordings in the financial services market and depending on who you speak to, you get a different answer. Some say call recordings must be retained for 6 months whereas the original FSA policy document suggests 3 years and according to a quick Wiki search, an article published by The Economist stated 7 years. Following the LIBOR scandal there has also been rumours circulating of unlimited retention policies with a similar story in the insurance industry where there has been talk of keeping recordings as long as the term of the actual policy itself which could run in to decades.

Having worked with customers to deploy call recording solutions in banks and insurance firms for the last 25 years, we agree that retention periods vary greatly amongst firms depending on the organisations internal policies, the products they sell and the markets they operate and are regulated in. 

Balancing upgrade needs with retention policies

From a technology perspective, over the years the costs associated with retention and storage have come down significantly. For example a 30 Terabyte resilient NAS (Network Attached Storage) server, capable of storing over 7 million hours of call recordings, can cost less than £10,000 today. Whilst costs may have reduced in this area, longer retention rates do create a problem for those firms seeking to upgrade their call recording infrastructure. They find themselves in a position where they need to maintain older legacy call recording systems so that they can still retrieve recordings from years back should the regulator demand it, whilst also installing and supporting the newer systems alongside this.

This is obviously not ideal as firms find themselves paying out for multiple support contracts across different systems and in some cases from different suppliers. It also requires internal staff to be skilled up in yet another product to ensure the right calls are easily and quickly accessible in the event of a regulator request. This becomes even more problematic for those firms who have to comply with the Dodd-Frank Act, as regulators expect requests for data relating to specific trades to be supplied within just 72 hours. In this instance we are increasingly starting to see financial firms turning to speech analytics technology to assist with one-off investigations to help pinpoint calls related to a specific trade using key word and phrase spotting.

Streamlining storage, archiving, playback and retrieval of call recordings

To add further complexity we then have the legislation surrounding mobile phone recording when deals or trades are being executed away from landlines. Regardless of which original source a bank needs to retrieve and playback a call, be that from a mobile phone, from an older legacy NICE call recording system, from a cloud based solution or from a newly installed Red Box Quantify recording system, the idea is that it can all be done using one simple portal. There is obviously a lot going on in the background to make this work, for instance metadata for calls must be checked, exported and imported to the new replay system. Firms going down this route will also need to determine whether the solution will reside on site or in a hosted data centre environment. The viability of this approach needs to be carefully assessed from a costing and internal resourcing perspective, but once the initial exporting and converting of older audio files is finished, the hard work has more or less been done.

There is certainly an argument to be made for taking a more streamlined approach and simplifying a bank’s call recording infrastructure using a single portal to access everything. There are significant time savings as call recordings regardless of which platform or technology they were captured by, can be more quickly and easily retrieved from one place. There are also cost savings to consider as banks are no longer stuck supporting multiple systems. Less internal resource time is taken on managing and maintaining internal user requests for support, as only one portal needs to be dealt with rather than a plethora of differing technologies across multiple platforms.

In a world where technology is advancing at phenomenal pace, doesn’t it make sense to at least look at where technologies can be streamlined and simplified to free up time to look at the really important stuff.
 

By Atiq Rehman, Consultancy & Training Manager, Business Systems (UK) Ltd

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