Issues as we see it:
1. Data protection - what are the rules concerning storage and then transcription should a person request their files.
The Data Protection Act covers data in whatever format hard copy, audio, visual, electronic. Thus recorded interviews and appraisals are covered by the DPA and subject to the same laws.
What are the rules? -The 4th, 7th and 8th Data Protection Principles cover storage, accuracy, destruction and transferrance.
As regards transcription, firstly the Data Subject has a right to request the data in its original format and secondly transcription could run the risk of breaching the Duty of Confidentiality law if not approached correctly. The added complication with audio is that the permission of all parties who spoke needs to be obtained before the audio can be released - (all parties are Data Subjects under the Act). Under the DPA the data subject could also request all CCTV images of thems as they entered and exited the building.
Effective HR departments are used to requests from interviees requesting their data - your Data Protection Compliance Manager (also required under the Act) should be able to advise. I think the concerns about the frontline are misplaced, the law and its accedence are easily achieved.
Have you seen examples of where this has been successfully adopted. >>
The Department of Constitutional Affairs used tape recordings recently, the tape recordings, interview notes and databases were easy for interviewee to obtain. The problem is one of education many IT depts and some HR depts do not understand their obligations under the Act.
2. Will people feel able to openly discuss matters if it is recorded, what if some of the information is "sensitive" and would not normally be recorded on a document. >>
Confidentiality is confidentiality in whatever form, some people feel uncomfortable being recorded but have no problem if its written down. Its still recorded whichever way you look at it, I suppose this is just historical and experiential.
3. Where is the agent's record of the appraisal if the only copy is on .wav file attached to their HR record. You cannot assume that every agent has an MP3 player and that every agent will accept a recorded appraisal. >>
Policy decision required, provided the agent is able to access the recording at work there shouldnt be a problem. I am unaware of any 'right' to a hard copy of your appraisal. Yes agents can refuse being recorded which kinda defeats the point of having it if the company havsnt got at 'work around'.
|