Touch Call Recording as a Service in action in a high-pressure, cross-border business

For over a decade, Touch has been working with a listed, €4 billion Scandinavian bank to solve two huge call recording challenges:

1. Find equilibrium between a number of differing regulatory regimes so as to maintain market leadership in all the territories it wants to serve customers
2. Deploy a consistent, high-standard compliance process despite having a highly heterogenous tech stack.

Headquartered in Stockholm and utilising a decentralised model where local branches have significant decision-making power, this is a major financial services brand. With over 12,000 staff operating in Sweden, Norway, the Netherlands and the UK, and additional operations in the United States and Luxembourg, the organisation provides a range of services, including retail and corporate banking, trading, mortgages, and a range of wealth management investment and asset management services.

Well capitalised and rated highly by international credit rating agencies like Fitch, Moody’s and S&P, the organisation operates under strict financial regulations across multiple jurisdictions. That means its internal compliance teams need to constantly be across everything they need to be, including:

• EU-wide regulations like MiFID II, GDPR and DORA
• SEC and FINRA rules in the US

and also, a wide set of country-specific rules, such as:

• UK local FCA rules and the UK’s implementation of GDPR
• Luxembourg—CSSF
• Sweden—Finansinspektionen
• and Norway, Finanstilsynet.

A mixed operating environment—and one that needed urgent modernization

As stated, the organisation was trying to be compliant in a number of markets with a complex infrastructure. Highly conscious of the potential risk of exposure to fines from financial authorities (and the concomitant danger of reputational damage if failures became public), in 2013 the company decided it needed a better call recording process than it currently had.

A quick look at its previous process spells out why. The Bank had standardised all its office telephony on Mitel’s MX-One business communications and telephony platform, while Microsoft Teams was increasingly used for internal and external meetings, as well as more and more interaction with clients.

Which meant great flexibility, but that different channels were ending up being used as part of the same customer dialogue. The clear risk here was call record ‘silos and incomplete compliance documentation and archives, but in at least some cases it had become a fear that some of those Teams calls would not be recorded--which if ever unfortunately were to occur, would have been an immediate MiFID II misstep.

‘Things had to change’

Completing this unsatisfactory picture was that while managers were stressing the need for recording of all client calls when regulations demanded it, a lot of what was available to team members was out-of-date, clunky on-premise apps.

Things had to change. This major Nordic institution was now in real risk of being asked for lost or failed recordings it could not produce for compliance or audits--and as things stood, due to the lack of robust call recording workflows, Teams meetings could not legally be conducted with customers.

After an extensive audit of the modern call recording marketplace, in 2013, starting in Norway but extending across the Group from 2020, a number of channels have now been secured using proven Touch solutions.

How Touch secured this major account win

To get set for a better, long-term future, the organisation set up a call migration team comprised of technical consultants, legal, and purchasing teams.

Stakeholders had a range of selection criteria that a potential new compliance and call recording partner would need to meet to even be considered.

These included:

• Specific technical requirements which included that all encryption keys should match or be upgraded to its high level of security
• Any new potential provider also had to be able to seamlessly work from day one with its tailored, customer-managed interval key store.

There were also several custom Teams-related security adaptations demanded, while any solution partners needed—as table stakes—also to:

• demonstrate high levels of trust from existing clients, as well as a bulletproof, proven security track record.

These all needed to be maintained to ensure compliance with storage obligations in things like MiFID II, so the whole library of existing recordings would have to migrated to any new platform—plus, both past and new recordings would, ideally, be accessible through the same interface.

Moving to a better future with Touch’s proven technology and sector insight

Touch was able to meet all these criteria, as well as offer:

• private cloud data protection hosted in the Nordics
• an already-advanced encryption model
• unsurpassed call recording expertise.

Sealing the deal: a highly competitive set of commercials, including high budget flexibility that meant it could easily accommodate the user’s preference to support both Capex and Opex-based billing going forward.

The key point here was that a strategic decision had been made to pivot from in-house IT operation to managed services, but only if the new service could be delivered and kept to a high quality with stringent SLAs and continuous QA (quality assurance).

The Touch journey so far

From signing the contract to launch, service activation, performance validation and historic data migration took just four months. In other words, years of recordings were transformed, giving the bank a seamless record that covers all applicable years.

But step one was to add in coverage of recordings from not just the Mitel fixed voice infrastructure but also all conversations and customer interaction via mobile devices. This was the spur for the first part of the rollout, which was the delivery of comprehensive mobile call and SMS recording, using Telia networking, in 2013.

Things took a major step forward in 2020, when—starting in Norway again—there was a comprehensive Mitel recording rollout with Touch, replacing NICE at 52 offices and involving over 700 users, soon followed by (2023-2024 timeframe) Sweden added.

This was accompanied in parallel by a migration, again starting in Norway, from Mitel to Teams involving no less than 3,200 users. And in all cases, access is carefully controlled, with only registered users being able to access calls made to their designated customers and contacts, but compliance officers having full access to recordings for their department (or for the whole company), depending on their role and operational privileges.

The customer was more than happy to see its entire call bank being comprehensively and safely imported into the Touch Storage Centre and made accessible to users through the Touch Web-Portal.