Jason,
It has been awhile since my responsibilities involved a call center
environment.  However, I do recall that there are specific requirements
regarding interstate and intrastate activity (wiretap law). Also, I
recall some requirements pertaining to the Telephone Consumer Protection
Act (FCC) and specific state laws as well.  However, these may relate
more to call statistics (dropped calls and messages) than retention
periods. At the very least you may wish to consider the Statute of
Limitations for guidance regarding retention periods within the states
in which you operate. 
B. regards,
Michael Levey
SCANA 

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Jason C Stearns/NYLIC
Sent: Thursday, August 03, 2006 3:19 PM
To: [log in to unmask]
Subject: Retention requirements for recorded phone calls?

Good day:

Is anyone aware of retention requirements for phone calls that are 
recorded in a call center environment?   The only thing I can find is
NASD 
rule 3010, but we do not meet the requirements for this type of 
supervision.

We currently have several call centers that record all incoming calls. 
Each center has a different preference for how long they want to keep
the 
calls, but each is based on a business need (training, quality control, 
etc.) not a specific legal or regulatory requirement. 

I can think of many reasons not to keep the recordings beyond the
business 
needs (privacy concerns, storage limitations, discovery requests?) so I
am 
leaning towards keeping the recordings for as short of a period as 
possible.   I just want to ensure I am not overlooking anything.

Thanks,


Jason C. Stearns
Assistant Vice President - Records Management
Business Resilience Department 

New York Life Insurance Company
51 Madison Avenue - Room 1116
New York, NY 10010
Tel  212 576 4701
Email:  [log in to unmask]

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