Revised and Edited post from our contribution on Bobsguide
With MiFID II, call recording and retention of calls is no longer a ‘nice to have’, but a serious FCA requirement extended under the financial legislation of the Markets in Financial Instruments Directive (MiFID II).
According to Article 16 (6) –
- “Investment firms must arrange for records to be kept of all services, activities and transactions undertaken which are sufficient to enable the competent authority to fulfill its supervisory tasks (…) and in particular to ascertain that the investment firm has complied with all obligations including those with respect to clients or potential clients and to the integrity of the market.”
Also important to note that that Article 16 (7) states that:
- “Investment firms must take all reasonable steps to record relevant telephone conversations and electronic communications that are made with, sent from or received by equipment provided by the investment firm to an employee or contractor.”
Meaning that, regardless of the original source, whether it being on a mobile phone, legacy Call Recording system, cloud based solution or a newly installed recording system, Financial firms must
1. Record communication from all available mediums
2. Store recording in a way that is safe and secure
3. Allow for the information to be retrieved should the competent authority demand it
They must also be able to ensure the quality, accuracy and completeness of the records of all telephone recordings and electronic communications.
For more information on how to adhere to MiFID II compliance with Mobile Call Recording download our comprehensive checklist.
Longer retention rates create a problem for firms needing to upgrade their Call Recording infrastructure. Not only will they have to pay for multiple support contracts across different systems to maintain older legacy systems, they will also need to purchase, install and support the newer ones. In addition, internal staff will also be required to skill up for yet another product to ensure the right calls are easily and quickly accessible in the event of a regulator request.
If you are faced with the challenge of retaining and retrieving calls, there are a number of options available to help you preserve historic call recording audio and data:
1. Leave your calls in the legacy platform (not advisable)
This is a short-term option. In the long term, hardware or software component failure can lead to additional work trying to retrieve or rebuild your system.
If your call recorder has reached end of life and is no longer supported, adopting this method is risky. If the system breaks, all calls could be lost, with the potential of failing to comply with regulatory mandates or company data security policies.
2. Migrate recordings to the new platform (better option)
With this option, you’ll have all your recordings located in one place. However, not many systems will allow you to access historical calls, especially if recorded on a system from a different manufacturer to the existing one.
The new system may require the original files to be converted to a standard file format, and careful scoping will be required to ensure data integrity is maintained during the process. It should also be noted that conversion of audio formats can significantly increase file sizes.
3. Migrate recordings with an alternate data management solution (best option)
Access old and new recordings, using an alternative replay system that can access existing recordings without having to convert the original format.
A legacy Call Recording retrieval solution, such as Wordwatch, can ensure the long term retention, retrieval and replay of past and current audio files, via one centralised access portal. As a standalone portal, Wordwatch can access and replay legacy audio files while maintaining call metadata and integrity from multiple recording systems (NICE, Verint, Red Box and even from mobile recording solutions such as Teleware, O2 and smartnumbers) as all calls remain on the original file structure and format.
This means compliance and IT teams can efficiently search, extract and playback audio recordings from multiple legacy and live call recorders, regardless of manufacturer and location. It also means that end-of-support and end-of-life issues will not impede their call recording infrastructure and assets.
Streamlining your Call Recording infrastructure
There are great benefits to be gained when adopting a more streamlined approach and simplifying an organisation’s Call Recording infrastructure using a single portal to access everything. Not only is less internal resource required to manage and maintain user requests for support, less budget is required to support multiple systems, resulting in substantial overall savings.
In a world where technology is advancing at phenomenal pace, it certainly makes sense to look at where technologies can be simplified freeing up your time to look at the really important stuff instead.
For additional help on Extracting Calls from your old call recording solution, download our checklist or get in touch with our team of professionals and get the help you need with your legacy solution.