selfphoneng/docs/admin-guide/legal.md

Emergency calls and recording law

This page explains what SelfPhoneNG does and what the law expects of you as the operator of a phone system. It is not legal advice. Rules differ by country, state and type of business: check with counsel for your situation.

Emergency calls (E911)

In the US, two federal rules apply to multi-line phone systems like this one:

• Kari's Law (47 CFR 9.16):
  • anyone must be able to dial 911 directly, with no prefix like 9 first;
  • when someone does, the system must notify someone on site (front desk, security) where that's set up.
• RAY BAUM'S Act (47 CFR 9.16(b)): a 911 call must carry a dispatchable location: the street address plus floor or room where that's needed to find the caller.

What SelfPhoneNG does

• 911 and 9911 always work from every extension.
  • This holds even if the extension may only call internally, is on do-not-disturb, or every trunk is busy.
  • Nothing you set can turn this off.
• It tells people. When someone dials 911, SelfPhoneNG:
  • emails the addresses in Settings → Emergency → Email these people;
  • rings the phones under Ring these phones;
  • shows a red banner on every admin's dashboard;
  • fires the emergency.call webhook.
• It sends a caller ID that has an address.
  • voip.ms gives the 911 operator the street address registered on the number used as caller ID.
  • That number is the extension's own Emergency caller ID (user → Emergency tab), or else the company's Default emergency caller ID (Settings → Emergency).

What you must do

1. Register an E911 address at voip.ms for every number used as an emergency caller ID (DID → e911). This address is what the 911 operator gets.
2. Pick a default emergency caller ID on Settings → Emergency. The dashboard stays red until you do, and until that number's E911 address note is filled in on Phone numbers (a reminder that you registered it).
3. Give people in other places their own number.
   • Anyone who works somewhere else (another building, at home) needs an emergency caller ID whose E911 address is where they are.
   • Otherwise 911 is sent to the main office. Remote workers without such a number should call 911 from a mobile phone, and must be told so.
4. Fill in each person's Location (e.g. "2nd floor, room 210") on their Emergency tab.
   • It goes into the notification email, so whoever is on site can meet the responders.
   • The 911 operator does not receive it. voip.ms only passes the registered street address. If a room number is needed to find someone in your building, register it in the voip.ms address itself.
5. Test the notifications, never 911 itself.
   • Settings → Emergency → Test notifications sends the email, rings the phones and shows the banner, all marked TEST. It dials nothing.
   • Never place a real call to 911 to test.
6. Canada: 911 works the same way through voip.ms. Check voip.ms's E911 documentation for Canadian rules.

Call recording

Recording calls without the right consent can be a crime. In the US:

• Federal law and most states are one-party consent: one person on the call (you) agreeing is enough.
• Several states need everyone on the call to agree, for example California, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania and Washington. A call between states can bring the stricter rule in.
• Other countries have their own rules; in the EU and UK, recordings are also personal data under the GDPR.

What SelfPhoneNG does

• Nothing is recorded unless you turn it on. You can record:
  • every call to a number (Phone numbers → Record every call);
  • a queue's calls (the queue's Record calls switch);
  • one person's calls with outside numbers (Users & Extensions → the user → Calling → Record calls: calls from outside, calls to outside, or both). The setup wizard never turns recording on.
• Settings → Recording → "Notice played before a recorded call" plays a sound you upload (e.g. "This call may be recorded for quality and training") to everyone who calls a number set to record, before anything else. Upload it on Sounds & music.
• Queue and per-person recordings play no notice of their own. Only numbers set to record play it. If you record a queue or a person, make sure the callers still hear it: send them through a number that plays the notice, or through an announcement that says it (Sounds & music → Announcements: play a sound, then go on). For calls a person makes to the outside, tell them to say the call is recorded.
• Retention. Recordings and voicemail are deleted after the number of days you set there. 0 keeps them.

What you should do

• Set the notice whenever anything is recorded, even in one-party states. It's the simplest way to have consent from everyone.
• Tell your staff their calls are recorded (a written policy).
• Keep recordings no longer than you need them, and limit who can sign in as an admin: admins can play every recording.