KIA&B 2017 Vol. 22, No. 4 | Page 13

Faculty Response: I’m quite sure they need a disclaimer about the recording but in general I feel having the voice documentation saved is so much better than written documentation if an E&O claim were to come up with a client. Faculty Response: There are several angles to approach the issue of retaining conversations and voice mails with customers. I believe the first question is if there is a legal obligation to provide the customer with notification that the call is being recorded. I’m not sure if there is a legal requirement but based on the number of times you hear “this call may be recorded for quality assurance,” it is certainly a common practice if not a legal requirement. The key to preventing E&O claims is follow-through and doing what you say you are going to do to meet your customers needs. Sound agency procedures with appropriate follow-up and verification procedures are key along with good documentation. Documentation is the most important item in being able to successfully defend a claim. With that said, a recording of customer conversations and voice mails can be a double-edged sword that could help or hurt an agency’s claim. If an agency procures the coverage requested by the customer, offers additional coverage options, provides increased limits, etc. and it is documented via a voice electronic system then great. But, what if the agency does not and a claim occurs and those voice files are subpoenaed and clearly show that the customer requested something that was not delivered? The “he said, she said” claims will be settled more definitely and let’s hope the agency is on the right side. I think retaining customer conversations could prove helpful but only as a supplement to written documentation and follow- up with the customer. At this point we do not have any specific E&O procedures for implementing a voice recording system. The next generation E &O seminar material which are already thinking about will explore technology related issues such as this one so we can better provide risk management guidance for the way today’s agents do business. Faculty Response: I will weigh in based on my general understanding, without the benefit of special research. It is my general understanding that there are a number of states where it is illegal to have a call recorded without prior notice, permission to record it, and/or a regular signal on the call to indicate recording. If it is not known where someone is calling from, when a call is placed or where they are when a call is received (such as if generated by or made to someone using a cell phone), there is no way to know what state law is applicable as the laws of state where the call is made and where it is received can apply, and may differ. Thus, to avoid having to sort through and remain current on possibly changing state laws on this issue, risk failing to comply with applicable laws, and uncertainty around which state law applies, it has become common practice for businesses that record calls to notify callers that a call may be recorded. Penalties for violating these laws can be quite significant; I have not researched this for quite a while but recall that in some states there used to be criminal penalties for violations. It also is unpredictable if and where any Bremen Farmers’ Mutual Insurance Company Serving Kansas since 1888 • Homeowners • Agri–Pak (Farmowners) • Preferred Homeowners • Inland Marine • Dwelling Fire • Business Owners • Online quoting, application submission, and document view available Curtis Holle • President Steve Meier • VP/Claims Mgr. Bryce Peters • Underwriting Mgr. 201 Brenneke St. | Bremen, KS 66412 T: 800.562.5712 | F: 785.337.2414 www.bfmic.com Email: [email protected]