Recording of calls and online meetings

Incoming and outgoing calls made by telephone and MS Teams, as well other types of online meetings, may be recorded and such recordings may be retained in order to meet regulatory requirements and as a record of the call. When a recording is made of a call or online meeting, only the audio will be recorded – no images or video will be recorded. You can read below how we manage recordings of calls via telephone and MS Teams, as well as other types of online meetings. (These hereinafter are collectively referred to as “calls”).

Purpose and legal basis for recording of calls and retention of recordings
Call recordings are made and retained in order to keep a record of the contents of our communication with you and such recordings are used for the purposes set out below: 

We make and retain recordings of calls relating to investment services in order to adhere to our obligations as set out in the MiFID II regulation and the Market Abuse Regulation pursuant to Article 6(1)(c) of the General Data Protection Regulation. Additionally, we make and retain recordings of calls in order to keep a record of what has occurred, been said and agreed during the call pursuant to Article 6(1)(f) of the General Data Protection Regulation. 

Details of recording
When you call an employee, you will be notified that if the call is being recorded. When you speak to us about investment services, we may in some cases record the call without notifying you that we are doing so. In the event that this happens, you will have previously been informed about our policy on making recordings in connection with your contractual relationship with us. When conducting online meetings, you will receive notification that the meeting will be recorded in the invitation to the meeting sent to you by email containing the meeting link. 

How we use individual recordings in specific instances:

Complaints handling and security incidents
We may review call recordings in order to investigate specific issues, including when you have raised a complaint, a security incident (including cases of potential fraud) or threats to you) has occurred, or threats have been made against you, the bank or its employees, pursuant to Article 6(1)(f), cf. Article 6(4).

Compliance and risk management 
We may review a randomly selected sample of call recordings in order to verify and ensure that Danske Bank complies with internal and external rules in relation to compliance and risk management, pursuant to Article 6(1)(f), cf. Article 6(4). 

Retention and erasure of your personal data
The MiFID II regulation requires us to retain call recordings relating to investment services for a duration of 5 years. The Swedish Bookkeeping Act requires us to retain those call recordings that constitute bookkeeping records for a duration of 7 years following the year of recording. Retention in both these instances is pursuant to GDPR Article 6(1)(c). We retain call recordings that contain a range of assignments for 10 years in order to maintain our rights within the general limitation period pursuant to GDPR Article 6(1)(f).

Calls will be deleted 60 days after the retention period ends. This 60-day period allows us to initiate cases in which the recordings are part of the case management and where contact in relation to the case is received immediately prior to the expiry of the retention period. 

If you or your interlocutor at Danske Bank makes a request to exercise their rights as set out in GDPR (e.g. by requesting access to a call recording), we will review the call recording as part of this request and then retain the file insofar as it is necessary to do so in order to document our compliance with our obligations, as well as to aid the handling of any resultant complaints, pursuant to GDPR Article 6(1)(f). If you request that we limit processing of a call recording pursuant to GDPR Article 18, this will require us to retain the recording for the period during which the limitation applies pursuant to GDPR Article 6(1)(c). If a recording is involved in a specific complaint or security incident, the call recording in question will only be erased once these cases have been closed in accordance with the limitation rules, pursuant to GDPR Article 6(1)(f).  If the recording is related to several different purposes, it will be retained in accordance with the longest applicable retention period.

Right to object
In some cases, you are entitled to object to our processing of your personal data in relation to the recording of calls, pursuant to GDPR Article 21. This includes in those cases when we have recorded a call based on our legitimate interests pursuant to GDPR Article 6(1)(f).  

Other information and your rights
In certain circumstances, you have a the right to of access, the right to rectification and the right to request the erasure of your personal data and/or restrict processing thereof. Find out more about the responsibilities pertaining to data protection, the sharing of data and your rights in our “Information about the processing of personal data”. article.