I propose to take Questions Nos. 286, 287, 288 and 289 together.
I am advised by Revenue that the disposal of call recording records was undertaken without a corresponding disposal authorisation from the Director of the National Archives. Revenue’s current request to the National Archives for a disposal authorisation for call recordings is to address this administrative oversight and to put in place the correct authorisation for future disposals.
I am further advised by Revenue that, in 2024, the pre-recorded message for all calls to the Local Property Tax (LPT) helpline stated, “This call will be recorded for training and quality purposes”. The pre-recorded message did not refer to retention for “verification purposes”. This pre-recorded message was in place for the whole of the year 2024 and this was the sole basis and purpose for the recording of such calls. On 29 January 2025, the LPT helpline was moved to Revenue’s new contact centre telephony platform. At this time, the pre-recorded message changed to “For quality and customer satisfaction purposes, inbound and outbound calls may be recorded”, so as to align with other Revenue telephone services.
Revenue does not consider the destruction of the call recordings, in accordance with the “Schedule of Records” and “Records Retention and Disposal Policy” published on Revenue.ie, to be a personal data breach for the purposes of Article 4 (12) of the General Data Protection Regulation (GDPR).
Revenue has advised that the retention period of 6-12 months is considered sufficient time for any queries/disputes regarding the call recording to come to light and to address potential disputes about the detail of the call. Accordingly, the deletion of the call recordings in accordance with this policy does not constitute further processing incompatible with its original purpose.
Furthermore, Revenue’s lawful basis for the use of and access to taxpayer information which these call recordings contain are set out in Section 851B(2) of the Taxes Consolidation Act 1997. Where subsection (c) states that taxpayer information shall be adequate, relevant and not excessive in relation to the purposes for which it is processed. Revenue had regard to this provision in support of its decision to delete the recordings.
As Revenue does not consider the disposal of call recordings in accordance with the record retention schedule to be a personal data breach, therefore when call recordings are disposed of Revenue does not notify the Data Protection Commission.
