Fonolo Privacy and Security Statement

Privacy and Security for your Fonolo Call-Back Product.

Effective: Dec 14th, 2017

Fonolo takes both your privacy and the privacy of your data very seriously.

The Fonolo Call-Back service interacts with your telephony infrastructure in a variety of ways. It is important that you fully understand what data Fonolo has access to, and how this affects your business.

Fonolo currently offers four main call-back services: In-Call Rescue (ICR), Web Rescue (Web), Mobile Rescue (Mobile), and API call-backs (API) via three different deployment methods: Direct SIP (SIP), via the PSTN (PSTN), and using a hybrid appliance (Appliance).

Access to data can vary significantly between these various products and deployment models so, in order to be as transparent as possible, the differences between each are detailed below.

 

Collected Data

In a basic Fonolo installation, the only data collected and stored on the Fonolo system are the call-back phone numbers for each call-back recipient (a “caller”). In our experience working with numerous financial and health care organizations, a caller’s call-back phone number on its own (i.e. not associated with any other data) is not considered Personally Identifiable Information (PII), and therefore is not governed by affected regulations (for example, HIPAA).

This call-back phone number is stored during normal operation of the Fonolo call-back service, and for reporting purposes. This data is required for the Fonolo service to operate correctly.

 

Optionally Collected Data

Beyond phone numbers, Fonolo has the ability to prompt callers for additional information (such as their name or reason for their call), which can then be presented to agents during the call-back process. This data is optional and is not required for normal operation of the Fonolo call-back process.

The type of data, how it’s collected, and how it’s stored, can vary by product and deployment methods.

 

ICR

With In-Call Rescue, callers can be given the option of leaving a voice recording or inputting information via DTMF tones on their dial pad.  With SIP or Appliance deployments, it is also possible to directly accept additional information from a telephony system, via SIP headers.

In a basic SIP or PSTN deployment, this data is stored on the Fonolo cloud for the duration of the call-back process. In a basic Appliance deployment, this data is stored on the Fonolo Appliance, behind your own firewalls, and is not sent back to the Fonolo cloud.

Once a call-back has either completed successfully or has ultimately failed (and there are no additional call-back attempts to be made), this data is permanently deleted.

 

Web & Mobile Rescue and API Call-Backs

With Web, Mobile, and API call-backs, data can be collected directly from callers via our web components or API REST interface.

These web components and API interfaces are securely served from the Fonolo cloud, using industry standard encryption (HTTPS). Because these components originate from the Fonolo cloud, any data passed via these web components or API interfaces is processed and stored directly on the Fonolo cloud, for the life of the call-back process.

Once a call-back has either completed successfully or has ultimately failed (and there are no additional call-back attempts to be made), this data is permanently deleted.

 

Storing for Reporting Purposes

By default, all collected data (other than the call-back phone number) is removed permanently at the end of the call-back process, though Fonolo offers customers the option to store this data as part of the metadata collected, for reporting purposes.

With Fonolo, data is never stored by default. It is ultimately up to you (individual companies) to determine whether you would like to store collected data for posterity. Fonolo recommends taking care when storing data, in order to ensure that no sensitive data is ever stored on the Fonolo platform.

 

Additional Collected Data

In addition to the optionally collected data described above, Fonolo will store metadata related to the call-back process and to visits to websites or mobile applications that utilize the Fonolo Web or Mobile components.

Fonolo specifically logs:

  • The caller’s call-back phone number.
  • The duration of the call-back (hold time, talk time, etc.).
  • The inbound caller-ID information of the caller (the phone number and name component) when using the ICR service.
  • The IP address, user agent string, and referrer content, when using the Web, Mobile, or API call-back services.

This data is used for reporting purposes in the Fonolo Portal, and is directly accessible to you. It is also used directly by Fonolo for logging, debugging, and capacity planning. This data is never shared or resold to any third party, for any purpose.

 

Audio Processing / Recording

During normal call-back operation, Fonolo is involved in both receiving inbound phone calls and placing outbound phone calls, between your call center agents and call-back recipients (i.e. the call-back process).

As such, Fonolo is present in the voice path of a phone call for the entirety of the call-back process, as well as for the remainder of the call.

 

Direct SIP Deployments

When deployed via SIP, the voice paths for these calls pass through the Fonolo cloud, directly from your telephony infrastructure, over the Internet. This SIP traffic can be optionally encrypted using secure SIP (SIPS) / secure RTP (SRTP) standards, as well as via an optional IPSec Lan-to-Lan VPN.

It’s important to note that even when encryption is being used, the voice traffic is ultimately decrypted for processing purposes once it has been received on the Fonolo cloud.

This voice traffic is never recorded or stored in any way on the Fonolo cloud; it simply passes through the Fonolo cloud, and is processed in real-time.

 

PSTN Deployments

When deployed via the PSTN, Fonolo utilizes various Tier 1 and Tier 2 telephony providers for inbound termination (for receiving phone calls) and DIDs (phone numbers), as well as for outbound termination (for placing phone calls).

Voice traffic for your call-backs will travel via the Public Switched Telephone Network (PSTN), and be routed to the Fonolo cloud. Ultimately, Fonolo has no control over how these calls are routed via the PSTN, and relies on the various upstream carriers to transmit the telephony data.

This voice traffic is never recorded or stored in any way on the Fonolo cloud; it simply passes through the Fonolo cloud, and is processed in real-time.

 

Appliance Deployments

When deployed via the Fonolo Appliance, the voice path for your call-backs will travel directly between your telephony system and the Fonolo Appliances, which are situated on your network, behind your firewalls. No audio is sent back to the Fonolo cloud.

This voice traffic is never recorded or stored in any way on the Fonolo Appliances; it simply passes through the Fonolo Appliances, and is processed in real-time.

 

Debug Audio Recording

Fonolo offers an optional debug recording feature that permits the recording of the last five minutes of the holding process of a call-back (where Fonolo is waiting on hold in the queue). These recordings are often used to debug connectivity or call routing issues between Fonolo and your system.

These debug recordings are of the hold process ONLY; Fonolo never records any aspect of the conversation between callers and agent. Furthermore, debug recording is disabled by default on all accounts.

This feature is also only available on SIP and PSTN deployments; it is not available to companies deployed using Fonolo Appliances.

 

Confidentiality

During normal call-back operation, sensitive information (such as credit card information, or health care details) could be shared between your call center agents and the call-back recipient. Care should be taken to avoid breaking any compliancy regulations while using call-backs.

Fonolo does not currently hold Payment Card Industry (PCI) or Heath Insurance Portability and Accountability Act (HIPAA) compliancy certifications. As such, Fonolo recommends deploying Appliances in cases where PCI or HIPAA compliancy is required.

The Appliances provide a simple solution to preserve your existing compliancy requirements, by deploying on premise, behind your firewalls. No sensitive voice traffic or collected data will ever leave the Appliance or be sent back to the Fonolo cloud.

 

The Fonolo Web Portal

All aspects of the Fonolo call-back service can be managed directly via the Fonolo Portal. The Portal is hosted in the Fonolo cloud, and protected using industry standard encryption (HTTPS).

There are several security and privacy features built-in to the Fonolo Portal, including:

  • Support for individual employee accounts, with separate defined roles, which limit the scope of their access to configuration and data.
  • Support for complex password requirements for all Portal logins.
  • Support for temporary and permanent account lock-outs after repeated login failures.
  • Support for limiting repeated use of the same password when changing passwords.
  • Optional support for two-factor authentication for all Portal logins, using Time-based One-Time Passwords (TOTP).
  • Optional support for globally limiting IP access to all logins for a single organization (i.e. for limiting access to an office IP block).

It is ultimately up to you (individual companies) to determine whether these optional security controls are right for your environment, and which individuals / what roles should have access to the Fonolo Portal.