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Recording, Consent and Card Data on a Voice Line

Your agent will take inbound calls from callers in the EU and the US, records audio for QA, produces transcripts for the LLM, wants to collect a card number to complete a purchase, and wants to run in shadow mode on existing recordings before launch. Legal asks you to "make it compliant".

State plainly that you are not giving legal advice, then:

  1. Design the opening of the call and the consent and opt-out behaviour.
  2. Design card capture so card data stays out of audio, transcripts, traces and prompts.
  3. Specify retention, access and vendor requirements.
  4. What is different for shadow mode on past recordings and for an outbound callback feature?

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