Recording and consent policy
1. How Smart Recording works
- Recording starts when the lead is connected to the agent and ends at hang-up. Ringing, voicemail greetings and machine audio are never recorded.
- The lead's state sets the rule. We use the state the customer sends, then the address, then the area code. If the state is unknown, we treat the call as needing everyone's consent.
- States where everyone must agree: California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Nevada, New Hampshire, Oregon, Pennsylvania, Washington. On these calls only the agent's side is recorded until the lead agrees. By default the agent asks for consent live. A recorded announcement is an option the customer turns on, and it plays only to leads whose consent record covers a recorded voice. If the lead says no, their side is not recorded.
- In other states both sides are recorded from the start. New York telemarketing calls must still say at the start whether the call is recorded. The agent says it in the opening line.
- We store who agreed, when, and the audio of the consent.
2. The customer's part
- The customer chooses whether to record, the consent method, and how long recordings are kept.
- Collections calls: keep recordings 3 years. Medicare sales calls: 6 years. Health care: sign our business associate agreement first. Card payments: pause recording or turn on card redaction.
- The customer gives any notice its own privacy policy or industry rules require.
3. Consent for calls and texts
- Live sales calls to consumers: check the National Do Not Call Registry with your own subscription, and your own do-not-call list. Some states require prior express written consent for all sales calls (Connecticut) or for calls made with automated dialing (Florida, Oklahoma, Maryland).
- Recorded, artificial or AI voice in a sales call: prior express written consent, naming your business and the number, and saying that agreeing is not a condition of buying.
- Texts: opt-in from the person to your business, for that program. STOP and the other opt-out words always work.
- Consent records must show who agreed, the number, the exact words shown or read, when and where, and the seller named. Mark a record that covers a recorded or artificial voice with
recorded_voice: true. The call screener line and the recorded consent announcement play only for those leads.
4. Our use of recordings
We use recordings and transcripts only to provide the service to the account that made the call. We do not listen to them except to support that account at its request, to answer a legal request, or to investigate a report of illegal calls.