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Can third parties be captured in a recording?

Yes. A conversation may contain information about people other than the primary customer, such as:

    • Family members
    • Household members
    • Representatives
    • Advocates
    • Colleagues
    • Professionals
    • Witnesses
    • Other people discussed during the conversation

The DPA identifies service users, customer employees and volunteers and representatives of third parties or partner organisations among the potential data subjects.

The organisation should consider this when preparing its privacy information, recording process and data minimisation controls.