The countdown is on until MiFID II compliance is required for the financial services industry, and one essential element of the legislation is mobile call recording. MiFID II can make for heavy reading, so it’s critical that you choose a call recording solution that will ensure you are 100% compliant with the directive.
In the fourth post in our MiFID II blog series, we’ve pinpointed five key points to consider when evaluating potential solutions or providers to assist you in achieving compliance.
1) Make sure your solution is compliant
This may sound obvious, but it isn’t something you can overlook. To achieve bulletproof compliance it is vital that you implement a solution that cannot be circumvented by the end user. Many companies believe that implementing call recording – whatever the specifics and technicalities of the solution – will tick the compliance box. The reality is far from this. If you implement a call recording solution that your users can easily bypass then, should a breach occur, the regulator could argue that your solution was not compliant in the first place.
2) Make it easy for your users
The key to user adoption is a solution that has minimal impact on users’ day-to-day behaviour, and one that is easy to transition to. Convoluted dialler systems and apps exist which can be used to record calls; however, these require the user to change their habits and navigate to the app before making calls. This makes it all too easy for them to accidentally make non-complaint calls. They also generally degrade the overall experience. Simplicity is key here, and the ideal solution requires no end-user training or changes to their everyday mobile phone experience.
3) Make it easy for IT
The amount of IT involvement for both implementation and ongoing management of a call recording solution must be carefully understood, so as not to introduce an unmanageable workload.
Where possible, you should look to deliver as much ease for your IT department as you do for your end users. Hosted solutions are ideal for this, as they remove the complexity of data storage and retention, which are key elements for MiFID II compliance. At the same time, reducing the maintenance aspects of recording and monitoring can provide a cost benefit of avoiding an on-premise system.
Another aspect that’s often overlooked is the deployment of the solution to all mobile devices. The installation and configuration of an app-based solution can add a significant layer of cost onto the business. A network-level call recording solution means there are no apps to install and configure on mobile devices. Hence, you will never have to schedule installations, worry about compatibility with updates or even consider which devices are compatible with your call recording solution. This means effectively you can almost remove IT from your call recording considerations.
4) Understand the technical components
While it’s possible to avoid any IT concerns when choosing your call recording solution, it is still vitally important to understand how your solution works. Your provider should be transparent about the elements that make up their solution, including where and how the call recording data is stored and how they will roll that solution out to you. This will enable you to identify any potential points of failure in the proposed solution, such as application crashes or call forwards, which could hamper call quality. Additionally, a reputable vendor should allow you to trial the solution for yourself – which is invaluable for your compliance personnel who would need to periodically log in and audit call recordings when the solution is in place.
5) Consider how your solution will be supported
Another key factor to consider is the support offered to you by your call recording vendor. This is often the area where vendors fall down, and the most common reason for this is that they don’t control every element of the call recording solution. A typical call recording system comprises:
- Call recording solution (or overarching licensing in the case of hosted solutions)
- Some form of ‘per seat’ licensing
- A data storage solution to retain recorded calls
- A mobile network connection and associated tariffing
- Compatible mobile devices (if your solution is not hosted)
The ideal solution will be delivered by a vendor that fully manages all of these elements, meaning you won’t have to liaise with multiple suppliers to manage and coordinate different parts of your solution.
Having different contractual arrangements, mechanisms and escalation paths for provisioning and service support, as well as multiple invoices reconcile, is less than ideal and it’s easy to see how this can become problematic. The more you can consolidate your call recording solution under one umbrella, the easier it will be for you.
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