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"This call may be recorded": what are you required to announce?

Many businesses record phone calls for training or as proof of agreements. That is allowed, but not in secret: a call recording contains personal data and therefore falls under the GDPR. Callers must hear it up front.

Updated 3 July 2026

The core of the rules

  • A recorded call is a processing of personal data (the voice and what is said). The GDPR therefore applies.
  • You must inform callers in advance that recording takes place and for what purpose. A spoken notice at the start of the call is the usual solution.
  • You need a legal basis, and recording must be proportionate: do not record more or keep it longer than the purpose requires.
  • Arrange internally who can access recordings and when they are deleted; that too is part of the GDPR obligations.

Please note: this is a practical summary, not legal advice. The full explanation is available from the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl); when in doubt, consult a privacy lawyer, especially if you want to use recordings for anything beyond the original purpose.

What the notice should contain

  • That recording takes place, before the conversation properly starts.
  • For what purpose: training, quality improvement or documenting agreements. Name the real purpose, not a catch-all.
  • Where the caller can find more information, for example the privacy statement on your website.

Example scripts

1. Short (for the welcome message)
Welcome to [company name]. This call may be recorded for training purposes. You will find more information in the privacy statement on our website.
2. Complete
Welcome to [company name]. To train our staff and improve our service, this call may be recorded. Recordings are treated confidentially and deleted after [retention period]. Want to know more? See the privacy section at [website].
3. With an alternative for those who object
Welcome to [company name]. This call may be recorded for quality purposes. Rather not? Please say so to our agent at the start of the call, or ask your question by email at [email address].

Put the notice in the right place

The notice must play before the substantive recording starts: practically, right in or after your welcome message, before the menu or the queue. Most businesses simply combine it with the welcome message; that is one recording and covers every incoming caller.

Frequently asked questions

Does the caller have to give consent?

Not always: besides consent, the GDPR has other legal bases, such as the performance of a contract or a legitimate interest. Informing callers, however, is always required. Which basis fits your situation is exactly the question to take to the Data Protection Authority's guidance or a lawyer.

Does this also apply if I only record occasionally?

Yes. As soon as you record customer calls, you are processing personal data and the rules apply, regardless of how often you do it.

Does my privacy statement need updating too?

Yes: it should state that you record calls, for what purpose, how long you keep them and what rights callers have. The spoken notice then refers to it.

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