Ring Janine: data protection pack

1. Who is who

The customer (the plumber, salon, clinic) is the data controller for their callers' data: they decide why calls are answered and what is done with the bookings. Ring Janine is the data processor: we operate Janine on the customer's instructions and only for the purposes in the contract. Callers are the data subjects. This split is standard for answering services and CRMs and it is what the data processing agreement below records.

2. What data Janine handles

Not collected: date of birth, health details, ID numbers, card numbers. Janine's scripts tell her not to ask for them; a clinic persona takes "pain 1 to 10" as triage, not a medical record.

3. Lawful basis

For the customer: performance of a contract (the caller rang to book a service) and legitimate interests (answering the phone, following up a quote, sending a review link once). Marketing texts beyond that (the 90-day win-back) rely on the soft opt-in under PECR reg. 22: existing customer, similar service, opt-out in every message ("reply STOP"). Recording relies on the consent line played at the start of every recorded call.

4. Retention

Default 90 days, set per customer. A nightly job wipes transcripts, captured details and recording links older than that; the call's outcome, timing and score are kept as statistics with no personal data. Bookings that went to the customer's own calendar or sheet are then the customer's records under their own retention. Deletion on request: any caller can be erased across every record by phone number within 72 hours, and the recording is deleted at Twilio at the same time.

5. Sub-processors

Action before launch: confirm the Supabase region and pin Twilio recordings to Ireland, then fill in the two "to be confirmed" cells.

6. Security

Every webhook and dashboard link carries a random 36-character token; a wrong token gets a 403. All tables have row-level security on with anonymous and authenticated roles revoked; only the server-side service role reads or writes. Secrets (Twilio, Anthropic, Stripe, Google) live in Supabase's encrypted secret store, never in code or chat. Recordings are only reachable through Twilio's authenticated URLs. Access to the database is limited to Ring Janine staff with two-factor on the Supabase account. Incidents: the customer is told within 48 hours of Ring Janine becoming aware, the ICO within 72 hours where required.

7. Recording consent line

Played before the greeting whenever recording is on: "Calls may be recorded for training and quality." The customer can change the wording but not remove it while recording is on.

8. Subject access requests

A caller (or their solicitor) asks for their data: the customer, as controller, tells Ring Janine the phone number. Ring Janine exports every record matching that number as caller, owner or recipient, plus any recording, as a JSON and MP3 bundle within 5 working days so the customer can respond within the statutory month. No charge.

9. Data processing agreement (clauses attached to the customer contract)

1. Subject matter and duration. Ring Janine processes personal data on behalf of the Customer to answer calls and messages, book appointments, send confirmations and reminders, for the term of the service.
2. Instructions. Ring Janine processes only on the Customer's documented instructions (this agreement, the setup form, the Customer's texts to Janine), unless required by law.
3. Confidentiality. Ring Janine staff with access are bound by confidentiality.
4. Security. Ring Janine maintains the measures in section 6 and will not reduce them during the term.
5. Sub-processors. The Customer authorises the sub-processors in section 5; Ring Janine gives 30 days' notice of any change and the Customer may object.
6. Data subject rights. Ring Janine assists the Customer with access, erasure and objection requests within 5 working days.
7. Breach. Ring Janine notifies the Customer without undue delay and within 48 hours of becoming aware.
8. Deletion. At the end of the service Ring Janine deletes the Customer's data within 30 days, except where law requires retention, and confirms in writing.
9. Audit. Ring Janine provides the information reasonably needed to demonstrate compliance, and allows an audit once a year on 14 days' notice.
10. International transfers. Transfers outside the UK take place only under the UK IDTA or Addendum to the EU SCCs, as held by the sub-processors listed.

10. ICO

Cinco Recycling Limited must hold an ICO data protection fee registration covering the Ring Janine service (tier 1, £52/year for a small company) and list "telephone answering and appointment booking" among its processing purposes. Check the register at ico.org.uk/ESDWebPages/Search and add the purpose if it isn't there.

11. Privacy notice wording for the customer's website

"Calls to this number may be answered by an AI receptionist provided by Ring Janine. Your number, what you say and your booking details are used to book your job and send you a confirmation by text, and are kept for 90 days. Calls are recorded only when you are told so at the start. You can ask us to delete your details at any time by texting this number."

Questions about this pack: [email protected] or ring 07360 266999.