Information clause on telephone call recording
Version 2.0, effective from 24 July 2026. Personal data processing information for recorded phone calls.
Controller and contact
The controller of personal data processed in connection with telephone calls is Promente Sp. z o.o., ul. Teofila Lenartowicza 33-35, 85-133 Bydgoszcz, Poland, KRS 0000921564, NIP 9671448844, REGON 389986034.
For data protection matters and rights requests, contact kontakt@pro-mente.pl.
Notice before recording
Recording may begin only after the caller receives a clear message that the call is recorded, the purposes of recording and where to find this notice. If you do not want to take part in a recorded call, you may end the call and use email or the contact form. You may also ask whether another unrecorded channel is available for the matter.
Data categories
A recording may contain your voice, phone number, call date, time and duration, identification information you provide and the content of the conversation. Do not disclose health information or other special-category data by phone unless it is needed to handle your matter.
Purpose and legal basis
Recordings may be used only to monitor and improve service quality, document arrangements with a caller, train the people handling calls with access limited to those who need it, prevent abuse, and establish, exercise or defend legal claims.
The basis for ordinary personal data is Article 6(1)(f) GDPR. Our legitimate interests are service quality and security, reliable reconstruction of the conversation, and protection of the rights of Promente and the caller.
Article 6(1)(f) alone is not a basis for processing health data. If health data are disclosed, they may be processed only where an additional Article 9 basis applies: in particular Article 9(2)(h) where necessary for health care or management of health care services by people subject to confidentiality, Article 9(2)(f) where strictly necessary for legal claims, or Article 9(2)(a) where explicit consent is required.
If there is no proper Article 9 basis for health data disclosed during a call, we do not use them and delete or redact the relevant excerpt without undue delay where technically possible without undermining the integrity of necessary evidence.
Recordings containing health data are not used for general training unless the relevant excerpt has been effectively anonymized or another proper legal basis applies.
Recipients and international transfers
Access may be granted only to authorized Promente personnel, telephone system, recording-hosting and IT providers, legal advisers or auditors, and public authorities where required by law. Access is limited to what is needed for the purpose.
If a provider or its subprocessor processes data outside the EEA, a Chapter V GDPR mechanism is required, such as an adequacy decision or Standard Contractual Clauses with the safeguards required in the circumstances. Information about the current mechanism for the telephone system is available from the controller.
Retention
Recordings are kept for no more than three months from the call. If a recording is isolated during that period as evidence in a complaint, incident, claim or proceeding, the relevant excerpt may be kept until final resolution or expiry of the applicable limitation period. It is then deleted or effectively anonymized.
Voluntary use and objection
Using a recorded phone channel is voluntary. You may object, on grounds relating to your particular situation, to processing based on Article 6(1)(f) GDPR. An objection does not always require immediate deletion where the controller demonstrates overriding legitimate grounds or needs the recording for legal claims.
Your rights
Subject to the GDPR, you may request access, rectification, erasure or restriction and may object to processing. If consent exceptionally applies, it can be withdrawn at any time without affecting the lawfulness of earlier processing.
You may lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland, uodo.gov.pl.
Automated decisions
Recordings are not used to make decisions based solely on automated processing that produce legal or similarly significant effects, and they are not used for such profiling.