REGULATION ON THE PROCEDURE FOR AUDIO RECORDING AT Belavia
General provisions
The Regulation on the Procedure for Audio Recording at Belavia - Belarusian Airlines establishes the procedure for conducting audio recording at the facilities of Belavia - Belarusian Airlines (hereinafter referred to as the «airlines») and defines the purposes, procedure for conducting, using, storing, ensuring security, access, disclosure upon requests, and destruction of audio recordings.
This Regulation has been developed in accordance with the Law of the Republic of Belarus No. 99-Z dated 07.05.2021 «On the Protection of Personal Data» and the Labor Code of the Republic of Belarus.
Audio recording refers to the process of obtaining audio information at the workplaces of the airline's employees, carried out using special devices intended for analyzing the quality of customer service, and its storage for subsequent use.
Audio recording is conducted openly. Information plates (notices) about the conduct of audio recording and/or a brief purpose of the audio recording are placed in areas where audio recording is carried out. When conducting audio recording of telephone lines, the client is notified by means of a voice message stating that the telephone conversation may be recorded.
Audio recording is not used to collect information about the private life of a specific person that is not related to the performance of official duties.
Main purposes of recording
The audio recording system is open and serves as an element of the company's overall security system, aimed at ensuring public order, workplace safety, maintaining labor discipline, preventing emergency situations, ensuring the objectivity of investigations when necessary, protecting the interests of the airline, and ensuring the quality of customer service.
The purposes of using the audio recording system at the airline are:
- ensuring the safety of employees and customers;
- improving the quality of customer service;
- preventing, detecting, and investigating incidents, including service quality complaints and disputes between employees and customers;
- exercising internal quality control over the provision of services;
- maintaining labor discipline.
If necessary, audio recording materials obtained using the airline's technical equipment may be used as evidence in criminal, administrative, or civil proceedings to prove the commission of an unlawful act.
Procedure for organizing and locations of audio recording
The decision to conduct audio recording is made by the General Director of the airline.
Audio recording is conducted with respect to audio signals (voice information) in the work area of the relevant customer service points of the airline.
Audio recording is carried out by the airline's technical equipment in automatic mode.
The audio recording system must ensure the preservation of the recording archive for subsequent analysis, playback of previously recorded information, and prompt access to the audio recording archive for a specific period of time and from specific recording devices.
Audio recording is not permitted in domestic and plumbing facilities, restrooms, employee changing rooms, and other places related to the personal needs of the airline's employees and customers.
In order to prevent possible conflict situations, as well as to control the quality of services provided, audio recording may be carried out together with video recording.
Procedure for storage and use of audio recordings
The technical means of audio recording ensure:
- protection against unauthorized access;
- differentiation of access rights by roles;
- recording and logging of user actions (viewing, extraction, copying, deletion).
Audio recording is carried out around the clock and continuously. According to the airline's Register of Personal Data Processing, the storage period for audio recordings shall not exceed 180 days, after which the audio recording is subject to destruction, unless it has been:
- classified as materials of an internal investigation or proceedings related to a customer complaint;
- retained upon a substantiated request from an authorized government authority in accordance with the procedure established at the airline.
Information recorded by the airline's audio recording system may be provided to government authorities and other state organizations only upon written requests in cases stipulated by applicable legislation.
