IDA Forsikring Forsikringsformidling F.M.B.A. – Violation Found (Denmark, 2024)

IDA Forsikring Forsikringsformidling F.M.B.A. (a controller) is a Danish insurance company. To improve the controller’s customer services, including their quality, as well, to assess the employees’ performance, the controller was recording incoming telephone calls of customer service. The audio files with recordings were analysed and converted into a text by a data processor. For this purpose, the processor used a speech recognizing software. The software was developed by the processor for past 8 years to optimize the analysis. According to the processor, the conversation recordings were not used in order to train the software. In order to analyse the employees’ conduct during calls with customers, the software picked up the word used by the employees. This was because the controller implemented a dedicated policy (“conversation tree”) to standardize contact with their customers. Hence, once the analysis was done, the call was assigned with a quality score. Consequently, the controller created and developed a list of positive and negative words (a dictionary) based on experience from approximately 30 million calls. However, according to the processor, the conversation recordings were not used in order to train the software. Additionally, the analysis of call let the controller to create a statistics on number of inquiries regarding specific topics. The statistical data allowed the controller to improve the customer service (for example by updated the FAQ section). Moreover, using the statistical data the controller was able to better know the clients behaviour and accordingly adapt their marketing and customer services, for example change the content of the newsletter bearing in mind the actual interest of the customers. The controller claimed they did not use the software to profile employees or customers, since the controller was analysing the conversation, not the individual. Due to the subject of services provided by the controller, the conversation include