“This call may be recorded for training purposes…if you consent say ‘Consent’.”

The Danish Data Protection Authority (Datatilsynet) has ordered a company to cease recording phone calls for training purposes until it implements a technical solution that makes it possible to obtain the caller’s consent for doing so.

In this case the complainant called the company’s customer service and was informed that the call would be recorded for training purposes. He was not asked to consent. After requesting that the recording be stopped, he was informed that this was not possible.


  • If you intend to record calls for documentation purposes (to show what the representative told the caller) you need to disclose this clearly.
  • As a default position, Datatilsynet holds that the legal basis for recording calls for educational purposes is consent.
  • In exceptional circumstances, there may be a legitimate interest which necessitates recording without consent and where processing may take place on the basis of the interest-weighting rule in Art 6 (3) GDPR .

Read the full decision.