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*Call Recording and Data Protection Policy

C1 Broker – Data Protection and Compliance Framework

Dear Client and Strategic Partner,

At C1 Broker, trust, transparency and legal compliance form the foundation of all our professional relationships. As part of our commitment to service quality, regulatory compliance and the protection of both our clients and our organisation, certain telephone communications may be recorded.

This notice explains the legal basis, purposes and safeguards associated with the recording of telephone calls, in full compliance with applicable European Union and Portuguese data protection legislation.

 

 

1. Legal Framework

The recording and processing of telephone communications by C1 Broker are carried out in accordance with:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR)

  • Law No. 58/2019 of 8 August (implementation of the GDPR in Portugal)

  • Law No. 41/2004 of 18 August, as amended, concerning privacy in electronic communications

  • The Portuguese Insurance Distribution Legal Framework (Law No. 7/2019)

  • Article 35 of the Constitution of the Portuguese Republic, which guarantees the protection of personal data.

These legal instruments ensure that any processing of personal data is carried out lawfully, fairly and transparently, while safeguarding the rights and freedoms of individuals.

 

 

 

2. Notification of Call Recording

In accordance with the principle of transparency established in Article 5 of the GDPR, clients and other participants in telephone communications are informed at the beginning of the call that the conversation may be recorded.

By continuing the call after receiving this information, the participant acknowledges that the recording may take place under the conditions described in this policy.

 

 

 

3. Purposes of Call Recording

Telephone recordings may be carried out exclusively for legitimate and lawful purposes, including:

  • Ensuring the quality and continuous improvement of our services

  • Training and supervision of staff members

  • Verification and documentation of contractual information provided to clients

  • Prevention and resolution of disputes

  • Compliance with legal and regulatory obligations applicable to insurance intermediaries

  • Protection of the legal interests of C1 Broker, its clients and its employees.

The recordings will not be used for purposes incompatible with those described above.

 

 

 

4. Legal Basis for Processing

The processing of personal data through call recording is based on the following legal grounds under Article 6 of the GDPR:

  • Legitimate interests of C1 Broker in ensuring service quality, contractual security and dispute prevention (Article 6(1)(f) GDPR);

  • Performance of a contract or steps prior to entering into a contract with the client (Article 6(1)(b) GDPR), where applicable;

  • Compliance with legal or regulatory obligations applicable to the insurance intermediation sector, when relevant.

Where necessary, the legitimate interest of the company is carefully balanced against the rights and freedoms of the individuals involved.

 

 

5. Categories of Personal Data Processed

During recorded telephone communications, the following personal data may be processed:

  • Voice recordings

  • Identification data voluntarily provided by the client

  • Information relating to insurance products or services

  • Any other information provided during the course of the conversation.

Only data strictly necessary for the stated purposes will be processed, in accordance with the principle of data minimisation.

 

 

6. Data Retention

Telephone recordings are retained only for the period strictly necessary to fulfil the purposes described above and to comply with legal or regulatory obligations.

In general, call recordings are stored for a limited period defined in the internal data retention policy of C1 Broker. After this period, the recordings are securely deleted or irreversibly anonymised.

Where recordings are necessary for legal proceedings, regulatory investigations or dispute resolution, they may be retained for the duration required under applicable law.

 

 

 

7. Data Security

C1 Broker implements appropriate technical and organisational measures to ensure the confidentiality, integrity and security of recorded communications.

These measures include, among others:

  • Restricted access to recordings

  • Secure storage systems

  • Encryption and access logging where applicable

  • Internal compliance monitoring procedures.

Access to call recordings is strictly limited to authorised personnel whose functions require such access.

 

 

8. Data Subject Rights

In accordance with the GDPR, individuals whose data is processed have the following rights:

  • Right of access to their personal data

  • Right to rectification of inaccurate or incomplete data

  • Right to request erasure of data, where legally applicable

  • Right to restriction of processing

  • Right to object to processing based on legitimate interest

  • Right to lodge a complaint with the Portuguese Data Protection Authority (CNPD).

Requests relating to these rights will be handled in accordance with applicable data protection legislation.

 

 

9. Contact for Data Protection Matters

For any questions or requests regarding the processing of personal data, including telephone recordings, please contact:

 

Data Protection Officer (DPO)
C1 Broker Portugal
Email: dpo@c1broker.pt

 

 

10. Compliance and Accountability

The recording of calls forms part of the broader compliance and data protection framework implemented by C1 Broker, which includes:

  • internal data protection policies

  • privacy and information security procedures

  • compliance monitoring mechanisms.

These measures are designed to ensure full compliance with applicable data protection legislation and to protect the interests of clients, partners and employees.

Call recording forms part of our comprehensive compliance framework, described in our Compliance Policy, as well as in our Privacy Policy and the corresponding Legal Notice.

To this end, we have a dedicated Digital Compliance department whose objective is to ensure that our processes, technologies and communication systems — including the automatic recording of calls — comply with the highest standards of security, confidentiality and information integrity.

We are committed to remaining at the forefront of best practices in digital security and data protection, providing our clients with the peace of mind that their information is properly safeguarded.

On our website, you can find transparent and easily accessible detailed information about:

  • Legal Notice

  • Privacy Policy

  • Terms and Conditions

  • Cookies Policy

  • Customer Service Regulations (SAC)

  • Robinson List

  • Legal Consent

Our objective is not control, but rather legal certainty, proper contractual management and protection against potential incidents or disputes.