Short answer: Recording a work call is processing personal data. In Uzbekistan it is governed by Law ZRU-547 "On Personal Data". The practical rule: get written consent from employees, tell customers the call is recorded, store data in Uzbekistan, restrict access and consult a lawyer. This article is not legal advice.
Which law applies?
Uzbekistan's main personal data law is Law ZRU-547 "On Personal Data", adopted on 2 July 2019. According to an overview by the international law firm DLA Piper, the law:
- Generally requires the data subject's consent for processing.
- Obliges data owners and operators to protect the data.
- Since 16 April 2021, requires personal data of Uzbek citizens to be stored in databases inside the country.
- Provides for liability for violations.
Uzbekistan's Constitution also guarantees the privacy of telephone conversations. So recording should cover only work calls and rest on a lawful basis.
What should you do to record employee calls?
The safest path is to make recording open and documented.
- Give employees a work phone and company SIM, and ask them not to use it for personal calls.
- Add a clause about call recording and its purpose to the employment contract or a separate document.
- Get the employee's written consent.
- Write internal rules: who may listen, how long recordings are kept, when they are deleted.
Should customers be told?
Yes, notice is recommended. A call includes the customer's name, number and other personal data.
Practical options:
- A short voice message on inbound calls, or a spoken notice from the rep: "This call is recorded for quality purposes".
- A clause on call recording in the contract, public offer or the website's privacy policy.
- If the customer objects, offer another channel.
Where must the data be stored?
Personal data of Uzbek citizens must be stored on servers inside the country. dooCall stores recordings encrypted on servers in Uzbekistan, and only the owner and authorised users can access them. Even so, the company itself remains responsible for consent and internal rules.
Cases that need extra care
- Healthcare. Patient health information is sensitive; restrict access tightly.
- Debt calls. Never discuss the debt with third parties; allow no threats or insults.
- Location. Tracking an employee's movements is personal data too; limit it to working hours and get separate consent.
- AI analysis. Before sending recordings to a third-party service for analysis, check that consent and internal rules cover it.
Rules differ in other countries
If your company operates in the CIS or elsewhere, check each country's law separately. For example, some US states require the consent of all parties to record a conversation, and in the EU the GDPR requires a lawful basis and transparency. Assuming "legal here means legal everywhere" is risky.
Short checklist
- Work phone and company SIM.
- Employment contract clause and written employee consent.
- Customer notice wording.
- Privacy policy on the website or in the offer.
- List of access rights to recordings.
- Retention period and deletion procedure.
- Lawyer review.
Frequently asked questions
What if an employee doesn't consent? Discuss it with a lawyer. The right approach is to explain the purpose and consider an alternative arrangement, not to force it.
Can a recording be used as evidence in court? That is for a lawyer and the court to decide.
Does dooCall collect consent itself? No. dooCall is a technical tool; consent and notice are the company's job.
Sources
- DLA Piper, Data Protection Laws of the World: Uzbekistan: https://www.dlapiperdataprotection.com/index.html?t=law&c=UZ
- Text of Law ZRU-547, Lex.uz: https://lex.uz/docs/4831939
- dooCall official site: https://doocall.uz
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