The Estonian Data Protection Inspectorate (AKI) wants to know whether Estonian ministries and other public sector organizations record calls made to their various helplines or other phones. If so, the AKI is requesting details about the reasons why as well as the legal grounds for doing so.

To satisfy certain legal grounds, the AKI is also asking respondents to provide analyses demonstrating how the ministry or public body's interests are weighed up against the individual callers' rights to privacy.

"If the recording of telephone calls is not a legal obligation, what alternative measures have you considered to achieve the same objectives?" the AKI is asking the authorities.

The Inspectorate is also seeking information on how callers are informed that their conversations are being recorded and for how long those recordings are kept.

The AKI's questions also concern how recordings of phone calls are deleted after the retention period, as well as who processes these recordings and how they can be accessed.

"Is any personal data transferred to third countries? If so, what are the appropriate safety measures?" the Inspectorate will ask.

The AKI justifies the monitoring by the need to identify potential gaps in the processing of data from people who contact Estonia's public authorities by phone. If necessary, the Inspectorate will then make specific recommendations to service providers in line with the results of its investigation.

"The recording of telephone calls is a form of processing personal data, for which there must be a legal basis," the AKI said.

As a result of the investigation, the AKI will produce an assessment of whether the collection and processing of data by ministries and public bodies meets all the necessary requirements.

The authorities are required to respond to the AKI's questions regarding the recording of telephone calls by May 5.

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