Recording of phone conversations

Incoming and outgoing calls may be recorded and stored for compliance with regulatory requirements and documentation.

Below, we have outlined how we process personal data in relation to phone conversations.

Purpose and legal basis for recording and storage of phone conversations

Telephone conversations are recorded and stored to document the content of our telephonic communications with you and are used for the purposes listed below:

We record and store phone conversations for the purpose of documenting what has been said, happened, and agreed during the conversation, c.f. Article 6(1)(f) of the GDPR. 

Notification of recording

When you call a recorded employee, you will be informed if the conversation is recorded.

The use of individual recordings in specific cases 

Handling complaints and addressing security incidents

We may listen to recordings to investigate specific cases, such as complaints from you and security incidents, including cases of potential fraud or cases of threats to you, the Bank or our employees, c.f. Article 6(1)(f) of the GDPR, c.f. Article 6(4) of the GDPR, and section 5(2) of the Danish Data Protection Act.

Compliance and risk management

We may listen to samples of recordings for the purpose of checking and ensuring MobilePay’s compliance with internal and external rules in relation to compliance and risk management, c.f. Article 6(1)(f) of the GDPR, c.f. Article 6(4) of the GDPR, and section 5(2) of the Danish Data Protection Act.

Retention and deletion of your personal data

We store phone conversations recorded for the other purposes for 6 months, c.f. Article 6(1)(f) of the GDPR.

If you or your MobilePay conversational partner exercise their rights set out in the GDPR, for example by requesting access to a recorded phone conversation (before it is automatically deleted), we will review the recording and retain it to the extent necessary to ensure documentation of compliance with our obligations and/or to meet any related complaints, c.f. Article 6(1)(f) of the GDPR.

If you request that we restrict the processing of a recorded conversation (before deletion of the recording) according to GDPR Article 18, we are obliged to store the recording for the duration of the restriction, c.f. Article 6(1)(c) of the GDPR.

If a recording is involved in specific disputes or security incidents, the recording will not be deleted until the case(s) or incident(s) has been finally settled in accordance with the applicable statute of limitation, c.f. Article 6(1)(f) of the GDPR.

Right to object

In certain circumstances, you have the right to object to the processing of your personal information in connection with recording and storage of phone conversations according to Article 21 of the GDPR. This is the case, for example, when the recording is based on our legitimate interests, c.f. Article 6(1)(f) of the GDPR.

Other information and your rights

In certain circumstances, you have the right to access, rectification or erasure of personal data and/or to restrict the processing. Read more about the data controllership, our sharing of personal data and your rights in our privacy notice.

Read more about MobilePay and GDPR in general