If you're looking for a network independent mobile voice recording service that works everywhere, please read our eBook which highlights what a 3rd generation solution needs to look like.

1. Introducing the 3rd generation of mobile voice recording

2. Introducing the 3rd generation of mobile voice recording

3. smart guide Introducing the 3rd generation of mobile voice recording. 3
Introduction 3
An evolving market from
niche to mainstream 4
Evolving customer demands 5
Requirements overview 6
Summary 13
About Resilient plc 14
Contents

4. smart guide Introducing the 3rd generation of mobile voice recording. 4
Introduction
Selecting the best mobile voice recording solution for
your organisation is becoming increasingly important
since, due to changes in legislation and best practice,
the number of staff who will need to have their calls
recorded is due to increase significantly. As we outline in
this document, in the financial services sector alone, the
number of individuals who need to have their mobile calls
recorded is likely to grow from around 30,000 users today
to as many as 1.1 individuals. Identifying solutions for
the relatively niche market of 30,000 users is significantly
different from a solution to address a mainstream market
of over 1m users. As such, organisations should consider
not only their short-term requirements when selecting a
solution for mobile voice recording, but also how these
requirements may change as the adoption of mobile voice
recording becomes more mainstream.
This eBook outlines the market drivers that are fuelling
this increase in demand for mobile voice recording, and
then identifies the 15 characteristics of a 3rd generation
solution to these requirements. It also provides a summary
matrix which compares the capabilities of smartnumbers
mobile against the 1st and 2nd generation of mobile voice
recording solutions.
In January 2016, Ovum, the largest and most authoritative technology
analyst company in the UK, completed a detailed and independent review
of smartnumbers mobile by concluding that it represented the first solution
in what they have termed the ‘3rd generation of mobile voice recording’.
According to Ovum, smartnumbers mobile not only addresses all of the
shortcomings of current solutions on the market – comprised of what
they term 1st and 2nd Generation services – but also adds significant
additional business value that isn’t capable of being achieved with these
earlier solutions.

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Today, the FCA mandates that anyone directly involved in
equity trading needs to have their mobile calls recorded.
This is a fairly niche market of around 30,000 people in
the City of London, who pay between £50 - £150 per
month, including roaming charges, to have their mobile
calls recorded. It’s a well-served market by 1st and 2nd
generation solutions.
In January 2018, the European directive MiFID II will come
into force, which will expand the mandate for mobile
call recording to anyone in Financial Services involved in
giving advice that may lead up to a trade. This will include
IFA’s, relationship managers and wealth managers as well
as those involved in commodity trading. Together, these
increase the market for mobile voice recording in the UK
to an expected 500,000 people.
In parallel, banks are reviewing the impact of the PPI
mis-selling which has cost them £30bn in compensation
payments. The banks lost the support of the FCA by
being unable to prove they didn’t mis-sell PPI. As such
banks are looking to ensure all customer engagement,
via online, phone and mobile communication, is recorded
for dispute resolution. Many of the largest retail banks are
today exploring solutions to record the mobile phone calls
of all their staff, be these in branches, contact-centres or
business centres. This increases the market for mobile
voice recording by another 700,000 people to a total
market within the financial sector of 1.2m.
Similar growth is also expected in other sectors,
including legal, pharmaceutical and retail sectors where
dispute resolution is becoming increasingly important
for managing revenue and reputation. As this market
changes from being niche to more mainstream, the
customer requirements will also evolve. The following
pages outline the nature of these evolving requirements
and how a 3rd generation mobile voice recording service
addresses these requirements.
An evolving market
from niche to mainstream
The market for mobile voice recording is poised for substantial growth,
due to changes in regulation and best practice.

6. smart guide Introducing the 3rd generation of mobile voice recording. 6
Evolving customer demands
As the market increases 40 fold from 30,000 to 1.2m people, any solution
for mobile voice recording must reflect the changes in both capabilities and
commercials to support the demand of this expanding market.
While it may be acceptable to pay up to £150 per month to have the mobile
phone calls of the top city traders recorded, this is not a price-point that
can be considered for a solution for the masses.
Furthermore, the requirements of a solution to addresses this broader
market is not simply limited to price –there are many other factors that
come into play when taking a requirement for a niche and specialist market
into something that is much broader, as outlined in this eBook.
Resilient plc have over 300 major financial services firms
using their smartnumber services, in addition
to 2,000 customers in other sectors. Within the financial
sector, customers includes eight of the Top 10 global
investment banks, all UK retail banks and many wealth
managers, IFA’s, hedge funds and other specialist
service providers. In other sectors, our customers
include major defence organisations, retailers, law
and pharmaceutical companies.
In order to understand the requirements for the
next generation of mobile voice recording we undertook
detailed requirements capture from our customers, as
well from regulators, such as the Financial Conduct
Authority and industry analysts such as Ovum.
As a result of this research, a common set of
requirements for the next-generation of mobile voice
recording services has emerged. These are outlined in
the following pages:

7. smart guide Introducing the 3rd generation of mobile voice recording. 7
Requirements overview
In order to design the next generation of mobile call recording services we engaged very closely with our
customers to create a requirements checklist, incorporating each of the key elements that they have used
to select a mobile voice recording solution. This has enabled us to come up with the following fifteen key
requirements that are common across businesses both large and small.
While it should go without saying that any solution for Mobile Voice Recording needs to
ensure that an organisation can achieve compliance, there are in fact a number of UK/
European regulations that organisations are required to meet – and companies do not get
to pick and choose which they will and will not adhere to.
The requirements to meet the current FCA (COBS 11.8) mandate is well understood by the
UK financial services market. However, these requirements will soon be overtaken by the
MiFID II requirements that not only broaden the number of individuals that will be covered
by call recording regulation, but will also change the scope. For example, under FCA COBS
11.8 the organisation needs to retain call records for 6 months, while under MiFID II this
will be expanded to 60.
Furthermore, since many financial services companies using PIN-code verification of a
customer prior to any conversation, or to transact on the telephone, then mobile voice
recording would also fall under PCI/DSS regulations which prohibits the recording of
dial-tones associated with bank card verification.
Finally, there are also competing regulations, such as Article 8 of the 1998 UK Human
Rights Act, which states that it is illegal in the EU for companies to record personal
conversations, which presents a challenge of how to ensure that while business
conversations are recorded, personal conversations remain private.
Requirement 1
Compliant

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Requirements overview (continued)
As the market becomes mainstream, it becomes increasingly important that any solution is
simple to implement. Many of the organisations that will be required to record calls under
MiFID Il, such as Independent Financial Advisors, may have little or no dedicated IT support.
Therefore the implementation of any mobile voice recording solution needs to be simple and
easy - while being robust and reliable.
Requirement 3
Simple to Implement
The current FCA requirements for call recording have been in place since 2011 and since
that time a number of earlier generation approaches have been tried and tested with
various degrees of success.
The first generation of solutions were based upon software clients that could be switched
off, or bypassed. They usually relied upon tromboning of calls between the mobile handset
and a fixed-line call recording solution. This creates a delay in setting up calls and may
result in call echo which doesn’t provide a good user experience.
The second generation addressed many of these problems by enabling call recording within
the mobile network itself. With this approach, call recording is achieved within the call-flow
so the user cannot interrupt or bypass it. Additional benefits are that network-based voice
recording doesn’t impact call setup, call quality or the user experience.
Requirement 4
Network Based
While it may be acceptable to pay over £100 per month to have the mobile phone
conversations of the top city traders recorded, this isn’t a price point that will be acceptable
to the larger mainstream market. As the market moves from niche to mainstream,
businesses should expect the market price for call recording to fall to a £10 - £20 per
month premium over their existing monthly mobile spend.
Requirement 2
Affordable

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Requirements overview (continued)
Regulations dictate that all communications between financial services companies and their
clients – including telephone calls, SMS and other communication media such as instant
messaging and email. Within the scope of mobile voice recording it is therefore essential to
record both calls and SMS from the mobile phone of the regulated user. For 1st and 2nd
generation solutions, while they may have been able to record calls, many have found it
difficult or impossible to record SMS messages.
Requirement 6
Records both
Calls & SMS
While we all expect our telephone calls to operate when we travel overseas, it’s equally
important that for regulated conversations the mobile voice recording works internationally
too. However, this presents a number of technical challenges, since when roaming
internationally, the voice path usually don’t route via the home country, with CAMEL
ensuring call hand-off in-country. This makes it very challenging to guarantee that services
which sit in this voice path, such as call recording, will always make it back to the UK for
recording and compliance purposes.
This is a common short-coming of the 2nd generation of mobile voice recording, as many
solutions will work when the subscriber is in the UK, but cannot be guaranteed to work if
the subscriber is travelling internationally.
Requirement 5
Works in the UK
and Internationally
When mandating a solution for the city traders that require call recording today, it’s usual for
organisations to provide company-issued mobile devices for business use only. However,
as the market expands, and organisations take different approaches to mobility, then any
solution for call recording needs to work with mobility strategies including Bring-Your-Own-
Device (BYOD), Corporate-Owned-Business-Only (COBO), Corporate-Owned-Personally-
Enabled (COPE), Bring-Your-Own-SIM (BYOS) and variations of these.
In addition, and by implication therefore, any solution for mobile voice recording also needs
to work within the mobile device management (MDM) framework that organisations adopt
to manage corporate-provided and personal-provided devices.
Requirement 7
Support alternative
mobility strategies

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Requirements overview (continued)
Although organisations will often spend significant amounts to comply with mobile voice
recording regulation, many see limited benefit of this investment to the organisation
itself. One of the ways in which the business can benefit their investment in mobile voice
recording is through integration with the corporate CRM system.
With this approach, every call between the regulated organisation and their customers
is automatically recorded in CRM, so that the complete 360º view of the customer is
maintained and the efficiency and productivity of their front-line staff can be measured.
In some cases, such as with Salesforce.com, the organisation may also drill-down into
customer recorded to retrieve and play the recorded conversations for training and quality
purposes. As such, an expenditure on compliance can quickly become a real asset to the
organisation as they grow their customer relationship function and capabilities.
Requirement 8
Support for CRM
While there are an increasing number of regulations that will mandate the need to record
business conversations, there are other regulations, such as Article 8 of the European
Convention on Human Rights that expressly prohibit organisations from recording
personal calls.
Therefore, any solution for mobile call recording needs to ensure that regulated calls are
recorded for compliance while personal calls remain private. In the past this was achieved
by providing staff with a second mobile phone for business use. However, technology
has now overtaken this and a growing number of ‘dual persona’ solutions now exist that
provide separate business and personal communications on one device – ensuring that
while business calls are recorded, personal calls remain private.
Requirement 9
Record business
calls but not
personal calls

11. smart guide Introducing the 3rd generation of mobile voice recording. 11
Requirements overview (continued)
Under MiFID II, the requirement to store regulated conversations increases from the six months
mandated today by the FCA, to a minimum of five years. This is a substantial increase in the
time required to archive recordings, and in the capabilities of solutions capable of managing
and retrieving such recordings. A number of financial service companies will already have
solutions in place to record their fixed-line conversations and would look to use this investment
to manage their mobile voice recordings. In this way, an organisation could manage all their
fixed and mobile call recordings in one software suite, with word search, speech analytics and
other discovery tools working across both fixed and mobile call recordings.
Requirement 10
Support fixed-line
solutions for
storage & retrieval
With the dramatic reduction in cloud storage costs, and the increasing number of tools that
are available for cloud-based discovery and analytics, more financial services organisations
are looking for a 100% cloud-based solution for the storage and retrieval of call recordings.
Furthermore, as it becomes clear that organisations such as the UK Ministry of Defence are
starting to use cloud-based services for critical organisational requirements,
it is clear that concerns about security and reliability have been addressed.
However, different cloud vendors focus on different markets, with the likes of Symantec,
AWS, Bloomberg Vault and others addressing different segments of the market with different
capabilities – and price-points. Furthermore, some of these solutions will host recordings in
the UK and others in Europe while some base their archive and storage facilities in the US. It’s
therefore important that any solution for mobile call recording provides a choice of cloud-based
storage and retrieval options so that the organisation can choose, based upon their budget,
requirements and regulatory constraints, the right solution for them.
Requirement 11
Support cloud-
based solutions for
storage & retrieval

12. smart guide Introducing the 3rd generation of mobile voice recording. 12
Requirements overview (continued)
Many of the 1st generation mobile voice recording services were based upon a separate
client on the phone, usually using IP voice, and using the internet to carry and record these
calls. However, while VoIP may be acceptable for inter-company calls, where quality and
reliability may not be as important as with client calls, the technology and requirement for
high-quality, consistent data access renders it unsuitable for use within this regulatory and
compliance market.
2nd generation of solutions, being network-based, overcame this shortcoming by ensuring
that all calls used GSM so that regulated conversations could take place anywhere with a
mobile signal.
3rd generation mobile voice recording enables call recording on both GSM and VoIP calls so
if the subscriber is in an area served only by the GSM network, then conversations may take
place over GSM. However, if the subscriber is overseas and wishes to eliminate international
roaming charges, or they are working in an area with poor mobile network coverage, so
long as there is a good wifi access they can choose to use a VoIP client and still have their
calls recorded.
Requirement 12
Uses the GSM
network for reliable
call quality
The 2nd generation network-based solutions for mobile voice recording operated by
requiring customers to replace their existing SIM card with a specialist SIM card that
provided, at a significant premium, mobile voice recording. Not only were these recorded
calls charged at a premium, but in fact all calls were charged at a premium, even if only a
handful of these need to be recorded.
Furthermore, by splitting off these regulated users to a separate network agreement
often impacts the corporate mobile contracts and the ability to meet corporate spend
commitments – increasing the mobile costs still further. While this approach may be
acceptable for the very top tier of the market, it’s not a solution that will prove acceptable for
the mainstream. Instead, mobile call recording as service should work across all UK network
operators, using the SIM that is already in the phone.
Requirement 13
Works across all
network providers

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Requirements overview (continued)
Many of the 1st Generation of mobile voice recording solutions require a client to
be running on the user’s phone, and as such work only on a small number of
handsets. Some solutions will work only with Blackberry devices, others will work
only on Android.
Any 3rd generation solution for mobile call recording, especially if serving a large
enterprise estate needs to work on any smartphone that may be present in this
estate – be it iOS, Android or Windows phone.
It is usually the case that the subscriber’s business mobile number is already in
the public domain – on business cards, website, marketing literature or stored
within the contact directory of their customers. Therefore it’s essential that any
solution for mobile voice recording does not require the customer to change their
mobile numbers, and that instead the solution can be deployed using existing
mobile numbers.
Requirement 14
Works across all
mobile handsets
Requirement 15
Number Retention

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Summary
The following are the requirements of the mainstream market which
constitutes the 3rd generation of mobile voice recording;
? = Some vendors may, others will not, meet this requirement
Requirement Description
1st Generation
App-Based
2nd Generation
Network Based
3rd Generation
smartnumbers
1 Compliant to FCA, MiFID, PCI (DSS), UK Human Rights Act (2008) ? ? ✓
2 Affordable ? ✗ ✓
3 Simple to Implement / Simple to Use ✗ ✓ ✓
4 Network Based ✗ ✓ ✓
5 Works in the UK and Internationally ? ? ✓
6 Records both calls and SMS ? ? ✓
7 Supports alternative mobility strategies ? ✗ ✓
8 Supports customer relationship management (CRM) ✗ ✗ ✓
9 Record business calls, not personal calls ? ✗ ✓
10 Support fixed-line solutions for storage & retrieval ? ? ✓
11 Support cloud-based solutions for storage & retrieval ? ? ✓
12 Uses the GSM network for reliable call quality ✗ ✓ ✓
13 Works across all network providers ✗ ✗ ✓
14 Works across all mobile handsets ✗ ✓ ✓
15 Enables the business to keep their mobile numbers ? ✓ ✓

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About Resilient plc
Resilient are the people
behind smartnumbers
We are a pioneering provider of smart voice services that
help the public and private sector improve organisational
agility, resilience and compliance. Our team of industry
thought-leaders are creating voice services which
underpin business transformation, enabling our customers
to operate more efficiently, securely and robustly.
Our Customers
Our smartnumber services have been adopted by
the leading organisations within the financial services,
technology, defence and security sectors. More than
2,000 organisations today take their fixed and mobile
voice services over the smartnumbers cloud in order
to protect revenue and reputation and achieve
regulatory compliance.
What We Do
Our smartnumber services overlay both fixed and mobile
networks enabling them to be deployed by organisations
without changing their numbers, their network or their IT
infrastructure. For fixed-line customers, we protect critical
calls into the organisation, especially during disruptive
events. For mobile estates, we enable mobile engagement
to be driven by business rules, priorities and imperatives.
Together, we combine fixed and mobile services to drive
the benefits of Fixed & Mobile Convergence (FMC) to the
heart of the organisation.

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Find out more
To find out more about the 3rd generation of mobile
voice recording, call our sales team on
0203 3162 3030 or visit www.smartnumbers.com