How To Configure Switchvox for GDPR Compliance
Background
European Union regulation 2016/679, or General Data Protection Regulation (GDPR), is implemented as of May 25, 2018. The implications of this regulation, and the steps each organization may need to take in order to comply, will vary. Digium does not provide legal advice and is unable to identify or confirm what steps are appropriate for your business. Customers concerned with GDPR compliance should seek appropriate counsel regarding their compliance plan.
As is the case with virtually all PBX systems, Switchvox contains Call Logs which record Caller ID information (Name and Phone Number). The GDPR significance of this, or other collected data, must be assessed based on the specific business operations - who will be placing calls into and out of the system, and at what localities. The appropriate configuration of a Switchvox installation is ultimately the responsibility of its owner.
Digium Technical Support provides personalized configuration assistance to customers with an active Switchvox Subscription Agreement. We cannot advise on the suitability of any changes as it relates to GDPR compliance, but will provide configuration guidance to those with active Subscriptions on the implementation of any specific configuration changes requested.
We have prepared this article to that end. Select Switchvox customers concerned with GDPR compliance have elected as part of their plan to prevent the storage of any Caller ID information on all Incoming Calls. The steps below outline how to accomplish this by using an IVR to strip out all Caller ID information. Please note that, in addition to preventing this data from being stored, this configuration will also prevent it from being displayed to users receiving the calls. This may be a desirable consequence, depending on your compliance plan objectives. Switchvox does not provide a configuration which will permit display of Caller ID information on user phones and at the same time also prevent it from being logged.
Steps
Create a new IVR to be configured for this purpose.
Login to Switchvox Web Interface as the Administrator
Go to Tools > IVR Editor > Create IVR Menu
Give the new IVR a name (such as "Mask Incoming Caller ID", or any other label you wish)
Save the IVR Menu
First, you may wish to completely mask the Caller ID Name:
Click on Create Action
Select Action Type: Alter Caller ID
Click Next
General Settings:
How do you want to modify the Caller ID? > Choose 'Replace With' from the drop-down box.
Which part of the Caller ID do you want to modify? > Choose Caller ID Name
Use this text to modify the Caller ID > You can put any text in this field that you would like to display on all calls routed through this IVR. If you would like to replace it with XXX, you simply enter XXX here. If you would like to use something that indicates it is an incoming call, or a certain type of call (such as "Customer"), you can enter any meaningful text here.
Save Settings
Next, you may wish to mask the Caller ID Number.
Click on Create IVR Action
Select Action Type: Alter Caller ID
Click Next
General Settings:
How do you want to modify the Caller ID? > Choose 'Replace With' from the drop-down box.
Which part of the Caller ID do you want to modify? > Choose Caller ID Number
Use this text to modify the Caller ID > You can enter zeros if you wish to completely mask the Caller ID number. Enter 0000, or similar.
Save Settings
Note: Order is important in an IVR! The Alter Caller ID actions must be placed at the top of the IVR, as the first actions in the list.
Next, you should add an action to route the call to the desired extension number. This can be another IVR, Call Queue, Phone Extension or even an External Number. The appropriate number is the same as where the incoming call would have first been routed before the introduction of this new IVR currently being created.
Click on Create Action
Select Action Type: Dial Extension
Click Next
Enter in extension manually: Enter the extension you wish to route the call to (this can be your Main IVR with Options, or any other extension).
Here is an example IVR:
At this point, you will need to route the incoming calls to this IVR before passing them to another extension. To do this, you will assign an extension number to this IVR.
Go to Setup > Extension > Manage
Click Create Extension
Select Extension Type: IVR (Interactive Voice Response)
Click Create Extension
Enter any unused extension number in the Extension field
In Route to IVR Menu, select the IVR you just created, "Mask Incoming Caller ID" in our example
Select IVR Menu Entry Point: IVR Menu Beginning
Click Save IVR Extension
Finally, configure the call route for the incoming calls to use this new IVR.
Go to Setup > Call Routing > Incoming Calls
Modify existing Call Routes (click on the yellow pencil), or Create Single DID Rule.
The Rule Name and Note can be any label you wish (this is informational)
Incoming DID to Match: enter the incoming phone number (or DID) without any spaces or other characters.
Incoming Provider: you can select a Provider if you have more than one, or leave it at Any Provider.
Incoming Call Type: Voice Call (or Voice Calls and Faxes, if this extension is used for faxes).
Extension to Route Call: enter the extension number of the IVR you created (in our example, it is Mask Incoming Caller ID (8002)).
Save Single DID Route
Note: If you want to mask the Caller ID information on ALL calls coming into your system, then you will have to Modify ALL Incoming DID routes to go to this IVR. You will also need to modify the Default Routes to go through this IVR as well. If you have multiple different routes that need to have the Caller ID information masked, then you will need to make an IVR for each or create additional logic to handle that routing via a secondary IVR.