Call Recording Notice

Hove Capital Limited records its telephone calls and video meetings as a matter of course. We do this to protect both you and us: an accurate record of what was said and agreed removes any later doubt. This notice explains what we record, why, how recordings are processed, and the rights you have. Where recordings contain personal data, we act as data controller and handle that data in accordance with the UK GDPR and the Data Protection Act 2018.

This notice should be read alongside our Privacy Policy and our AI Policy.

We record:

• Telephone calls placed to or from our business numbers
• Video calls and meetings held on platforms such as Microsoft Teams, Zoom, or Google Meet

Recording is automatic. Calls are recorded by default rather than started case by case, so you should assume that any call with us is being recorded. We do not capture audio outside of calls, we do not operate ambient or background recording of our working locations, and we do not record covertly.

Because recording runs by default, you are told that a call is recorded in one or more of the following ways:

• Written notice in the meeting invitation, in advance
• Verbal notice at the start of the call
• This published notice

You may decline to be recorded at any point, including part-way through a call. If you tell us you do not wish to be recorded, we stop the recording. You may also ask us to delete what has already been captured and we will do so unless we have a legal reason to retain it.

We record calls and meetings in order to:

• Keep an accurate record of requirements, specifications, and decisions agreed with clients
• Protect both parties by removing any doubt about what was discussed or agreed
• Resolve any later dispute about what was discussed or agreed
• Support internal training and quality
• Maintain records needed for legal, contractual, or audit purposes

We do not use recordings for marketing, profiling, or any form of automated decision-making about you.

Our lawful bases under the UK GDPR for recording and processing calls are:

• Legitimate interests: Keeping accurate records of business discussions with clients and suppliers. We have carried out and documented a legitimate interests assessment for this processing.
• Consent: Where legitimate interests are not appropriate, for example where a call may involve special category data, we rely on your consent, which you may withdraw at any time.

We use locally run AI models to transcribe and summarise call recordings. This processing takes place entirely on hardware we own and manage:

• Audio, transcripts, and summaries are processed on Company-managed devices and do not leave our infrastructure
• No recording, transcript, or summary is sent to any third-party or cloud AI service
• The models we run are never trained on your data, and your data is not shared with any model provider
• Transcripts and summaries support human-led work only; outputs are reviewed by a person before being relied upon

Our wider approach to AI, including the controls we apply to locally run models, is set out in our AI Policy.

Access to recordings, transcripts, and summaries is limited to authorised members of staff who need them for the purposes described above.

Where a call is held on a third-party platform such as Microsoft Teams, Zoom, or Google Meet and that platform's own recording feature is used, the platform provider processes the recording as part of delivering its service, under its own terms and our data protection arrangements with it. We do not otherwise share recordings with any third party unless we are legally required to do so.

Recordings are stored within the United Kingdom. No transfers outside the UK take place except where a call platform's own infrastructure requires it, in which case the safeguards described in our Privacy Policy apply.

Recordings, transcripts, and summaries are kept for up to 12 months from the date of the call, after which they are deleted. We retain material for longer only where a legal, contractual, or audit reason requires it, for example an ongoing dispute.

You have the same rights over call recordings as over any other personal data we hold, including the rights of access, rectification, erasure, restriction, and objection. These rights are described in full in our Privacy Policy.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. You will receive a response within one month. You may also complain to the Information Commissioner's Office at ico.org.uk.

Should you have any questions about this notice or about a specific recording, please get in touch:

• Data Protection Officer: [email protected]
• General enquiries: [email protected]
• Telephone: 01273 937117
• Address: Curtis House, 34 Third Avenue, Hove, BN3 2PD

Hove Capital Limited is registered in England under company number 13049782.