Customer service: access to audio recordings of conversations via transcripts is permitted

Personal data contained in audio or video recordings made during customer service interactions may be provided to users who request it, including via a transcript of the conversation, provided that any details enabling the identification of other individuals have been redacted. This is laid down by the Data Protection Authority at the conclusion of proceedings against an electricity supplier.

Following a call on 6 August 2025 with a customer service representative, a customer requested access on 8 August to their personal data contained in the recording of the call. The company, however, had rejected the request, considering that, in weighing up the conflicting interests, the need to protect the privacy of the operator took precedence. According to the company, the operator had, on several occasions, provided details that would have allowed them to be identified, such as their name and employee number. In this regard, the Data Protection Authority notes that the contract between the energy company and the provider of the customer care service stipulates that the sole purpose of recording conversations is to assess the quality of the service provided.

The operator would therefore have expected that his information would not be processed for other purposes, such as providing it to the client. The company had also noted that sharing the recording could have exposed the employee to disciplinary action. The customer could, in fact, have taken such action against the employee’s employer, namely the provider of the customer service.

The Data Protection Authority points out, first and foremost, that the concept of ‘personal data’ also includes the sound of the voice contained in a recording of a telephone conversation, and that such information may be subject to the right of access. Consequently, if the data subject so requests, the data controller is obliged to provide a copy of the data being processed, whilst taking into account the need not to infringe the rights and freedoms of others.

In the case in question, the Data Protection Authority concludes that the purely professional nature of the telephone call and the content of the conversation – the gas supply contract signed by the customer – would have enabled the company to comply with the request without compromising the operator’s right to privacy. This could have been achieved by obscuring any information that might identify him, such as his name and employee number, or by using voice-altering techniques to disguise his voice. Furthermore, in this specific case, the company could also have provided a transcript of the conversation whilst ensuring that the operator’s personal information was redacted.