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Mobile Recording: now is the time to act

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4th Mar 2011
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Until now, firms regulated by the Financial Services Authority (FSA) have not had to record mobile calls and texts, largely due to the perceived technical complexity involved.

However, the recent announcement of the FSA Revised Policy Statement (10/17) has effectively closed this loophole. As of 14 November 2011, regulated organisations must record all relevant electronic communications in order to meet their regulatory obligations. 

Arguably, this is no more than mandating what should already have been considered good governance or best practice, both in terms of protecting the business and ensuring a good customer experience.

The new regulation supports disaster recovery and contingency planning, for example, by enabling traders and other key staff to work securely from remote locations. By accurately recording all interactions between the organisation and its customers, such a solution also substantially reduces the risk of misinterpreted information and potential costs and reputational damage arising from dispute resolution.

In-line solution         

So what might a best practice solution look like? Ideally it should be a global solution, which works seamlessly, wherever the user may be. It should also enable the firm to record highly sensitive information on their existing in-house recording platforms where they already record fixed line calls to ensure a comprehensive search facility. 

This can be achieved by re-routing all calls and text messages via the existing corporate infrastructure, while having minimum impact on the user experience. The system must also be completely automated so that it automatically records every interaction 100% of the time rather than relies on an individual agent or trader to activate the recording process.

This requires a true in-line recording solution, one which ensures that the recording platforms sit between the two parties on the call. In short, without the recording there should be no call. 

From the individual employee’s perspective, recording mobile calls can help to drive up productivity by making enterprise mobility and flexible working a reality. Staff can do their job regardless of where they are, in the certain knowledge that all customer mobile communications are secured and fully compliant in exactly the same way as controlled, fixed-line environments.

A tight deadline

It might seem that the deadline of 14 November 2011 is some way off. Yet a brief look at the required timetable for implementation shows that any delay would be a high-risk strategy.  

First, any best practice organisation will want to factor in at least one month’s contingency, to avoid missing the deadline. 

Second, those large groups of users that are affected - typically 1,500-2,000 in most of the investment banks, for example – will need to have their devices configured. There will also need to be a period of user acceptance and almost certainly some user training. A sensible organisation will want to allow at least one month for this.

Third, most of the available solutions will demand some hardware integration in the customer’s environment, which will also require the ordering of new links and possibly new voice recording platform licenses. Current estimates are that this will take around three months.

Already this pushes deployment back beyond June 2011. And of course this does not take into account the fact that each organisation will need to factor in the extended process of supplier evaluations, internal budget approvals and signing supplier contracts. To say nothing of whether the chosen supplier has sufficient capacity to meet their requirements, while meeting the similar demands of other clients.

In order not to get caught out, it quickly becomes apparent that any regulated organisation that has not already yet started to act – and with some sense of urgency – needs to do so very soon. 

Matthew Chalk is a finance sector manager at Vodafone Global Enterprise. Click here to read his blog.

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