Recording and Transcription of Microsoft Teams Meetings Privacy Notice

This privacy notice is designed to help you understand how the Council processes your personal data when you attend a meeting on Microsoft Teams ('MS Teams') and that meeting is recorded or transcribed.

This privacy notice supplements the key information in, and should be read alongside, the Council's corporate privacy notice.

Who are we?

The Council is responsible for delivering a wide range of public services and functions. The Council uses MS Teams as its secure video conferencing platform allowing meetings, briefings and training to take place virtually. These meetings may involve employees, councillors and external participants.

All services at the Council may need to record or transcribe MS Teams meetings.

The Council has produced internal user guidance for employees on the use of the recording and transcription features in MS Teams.

Whose personal data do we process?

When a MS Teams meeting is recorded or transcribed, we will process the personal data of the individuals who are in attendance at that meeting. This may include:

• employees;
• councillors; and
• external participants

What type of personal data do we process?

Where you attend a MS Teams meeting that is recorded or transcribed, the personal data we process may include:

• Your name/ user name;
• Your photo;
• Your Email address;
• Your participation in the meeting, including video/background images/ audio/ chat.

In accordance with the user guidance, the meeting organiser/ chair will advise participants verbally before the recording commences that they are able to turn off their camera or use the chat function if they do not want their face/ voice to be included on the recording.

Why do we process personal data?

All services at the Council may need to record or transcribe a MS Teams meeting so that a formal record is made of the meeting, for minute taking purposes or for future use and circulation.

Recording meetings may also assist us with complying with our obligations under the Equality Act 2010 in terms of accessibility requirements and reasonable adjustments.

In accordance with the user guidance, where a MS Teams meeting will be recorded or transcribed you will be informed in the invitation to attend and the meeting organiser/ chair will inform the participants that the MS Teams meeting will be recorded or transcribed, and why, before the recording or transcription commences.

Where do we get your personal data from?

The personal data that is processed in a MS Teams recording or transcription will relate to the individuals attending the meeting through their attendance.

Who do we share your personal data with?

MS Teams recordings may be shared internally within the Council or, in some instances, externally, for example if the recording relates to an external training event.

In accordance with the user guidance, the meeting chair/organiser will inform the participants who the recording is likely to be shared with.

MS Teams transcriptions will be available to those who attended the meeting.

What is the legal basis for MS Teams Recordings?

The legal basis for each MS Teams recording and transcription will depend on which type of meeting being recorded and the reason for the recording being made.

In the context of most MS Teams meetings, briefings and training the lawful basis will either be:

• Public Task: The processing is necessary for the Council to perform a task in the public interest or for its official functions with a basis in law or
• Legitimate Interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

As set out above, in accordance with the user guidance, the meeting organiser/ chair will advise participants before the recording commences that they are able to turn off their camera or use of the chat function if they do not want their face/ voice to be included on the recording.

Updates

This privacy notice and the corporate privacy notice are updated from time to time to take account of changes in our services, legal requirements and to make sure they are as transparent as possible, so please check back here for the current version. You can see when this privacy notice was last updated here:  February 2024