Designing Legal Hold Automation Systems that Suspend Recording Deletion on Litigation Trigger

How-To-Articles
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Designing Legal Hold Automation Systems that Suspend Recording Deletion on Litigation Trigger

What This Guide Covers

This guide details the architectural implementation of an automated Legal Hold system for Genesys Cloud CX. You will build a workflow that intercepts the standard recording lifecycle, identifies media associated with specific agents or queues during a defined litigation period, and overrides the default retention policy to prevent deletion. The end result is a secure, auditable pipeline that preserves evidence without manual intervention, ensuring compliance with eDiscovery mandates.

Prerequisites, Roles & Licensing

Licensing & Permissions

  • Licensing Tier: Genesys Cloud CX 3 or higher (required for advanced Architect capabilities and extensive API access).
  • Admin Permissions:
    • Recording > Recording Policy > Edit
    • Recording > Recording > Edit (for testing)
    • Architect > Architect Flow > Edit
    • Integrations > Integration > Edit (for webhook/external system triggers)
    • Security > Role > Edit (to create a dedicated Legal Hold role)
  • OAuth Scopes:
    • recording:read
    • recording:write (specifically for metadata tagging)
    • architect:flow:edit
    • integrations:integration:edit

External Dependencies

  • Case Management System (CMS): An external system (e.g., Salesforce, ServiceNow, or a dedicated eDiscovery platform) that issues the “Litigation Trigger.”
  • Storage Backend: Genesys Cloud default storage or an integrated AWS S3/Azure Blob container if using Genesys Cloud Media Storage integration.

The Implementation Deep-Dive

1. Architecting the Legal Hold Metadata Model

Before configuring flows, you must establish a data model that distinguishes between standard recordings and those under legal hold. Genesys Cloud does not have a native “Legal Hold” boolean field on recordings that blocks deletion at the infrastructure level. Therefore, you must engineer a logical hold using custom metadata and policy isolation.

The Strategy: Tagging and Policy Segregation

We will use two mechanisms:

  1. Custom Metadata: A JSON attribute attached to the recording metadata via API.
  2. Recording Policy Override: A specific recording policy that retains data indefinitely (or for a legally mandated period, e.g., 7 years).

Step 1.1: Create the “Legal Hold” Recording Policy

Navigate to Admin > Voice > Recording Policies. Create a new policy named Legal_Hold_Indefinite.

Configuration Details:

  • Retention Period: Set to the maximum allowed (typically 3650 days or “Indefinite” if your tenant configuration permits).
  • Storage Location: Ensure this points to a secure, immutable storage bucket if you are using external storage integration.
  • Transcription: Disable automatic transcription unless required for discovery. Transcription jobs can inadvertently alter metadata or create secondary artifacts that complicate chain-of-custody.

The Trap: Do not apply this policy globally. If you apply an indefinite retention policy to all recordings, your storage costs will explode, and you will violate GDPR/CCPA “Right to be Forgotten” requests for non-litigated data. This policy must be applied dynamically only to affected recordings.

Step 1.2: Define the Legal Hold Trigger Event

We assume the trigger originates from an external Case Management System (CMS). The CMS sends a webhook to a Genesys Cloud integration when a case is opened. The payload contains:

  • case_id: Unique identifier.
  • hold_scope: agent_id, queue_id, or user_id.
  • start_date: ISO 8601 timestamp.
  • end_date: ISO 8601 timestamp (or null for open-ended).

Create a Webhook Integration in Genesys Cloud to receive this payload. Map the incoming JSON to integration variables.

2. Building the Automation Workflow in Architect

We will construct a flow in Genesys Cloud Architect that executes upon the webhook trigger. This flow does not handle voice traffic; it is a Data-Only Flow used for administrative automation.

Step 2.1: Ingest and Validate the Trigger

  1. Create a new flow: Legal_Hold_Processor.
  2. Add a System Trigger block: Webhook.
  3. Connect to an Assign block to parse the incoming payload.
    • Set variable hold_scope_type to {{trigger.data.hold_scope}}.
    • Set variable target_identifier to {{trigger.data.target_id}}.
    • Set variable case_reference to {{trigger.data.case_id}}.

Step 2.2: Identify Affected Recordings

This is the most complex step. You cannot simply “pause” deletion. You must find existing recordings and update their metadata/policy, and then ensure future recordings are tagged.

Sub-Step A: Tag Future Recordings (Queue/Agent Level)
If the scope is a Queue or Agent, we must modify the Recording Policy assignment for that entity. However, changing the policy on a live queue affects all incoming calls. We need a surgical approach.

Instead of changing the global policy, we use Recording Attributes. Genesys Cloud allows you to set custom attributes on recordings. We will create a custom attribute named LegalHoldCaseId.

  1. Navigate to Admin > Voice > Recording Attributes.
  2. Create a new attribute:
    • Name: LegalHoldCaseId
    • Type: String
    • Default Value: Empty
  3. In the Architect flow, use a Make HTTP Request block to update the Queue or Agent configuration if your CMS requires dynamic policy switching. Note: Genesys Cloud does not allow dynamic policy switching per call via API easily. The robust method is to tag the recording post-call.

The Trap: Attempting to change the Recording Policy on a Queue via API while calls are active can cause a brief window where recordings are lost or misrouted. Never change recording policies on high-volume queues during business hours. For legal holds, it is safer to tag recordings post-facto and rely on the retention logic to preserve them based on metadata.

Sub-Step B: Backfill Existing Recordings
We must find recordings already in storage that match the criteria.

  1. Add a Make HTTP Request block to query the Recordings API.

    • Method: GET
    • Endpoint: /api/v2/recordings/recordings
    • Query Parameters:
      • agentIds: {{target_identifier}} (if scope is agent)
      • queueIds: {{target_identifier}} (if scope is queue)
      • startTime: {{trigger.data.start_date}}
      • endTime: {{trigger.data.end_date}} (or current time)
      • pageSize: 100

  2. Add a Loop block to iterate through the returned recordings.

  3. Inside the loop, add a Make HTTP Request block to update each recording’s metadata.

    • Method: PATCH
    • Endpoint: /api/v2/recordings/recordings/{{loop.current.id}}
    • Body:
      {
  "customAttributes": {
    "LegalHoldCaseId": "{{case_reference}}"
  }
}

The Trap: The Recordings API paginates results. If you have 10,000 recordings, a single GET request will only return the first 100. You must implement pagination logic in Architect using a While loop or a recursive flow call to fetch all pages. Failure to paginate results in incomplete legal holds, which is a catastrophic compliance failure.

Step 2.3: Implementing the Deletion Blocker

Genesys Cloud automatically deletes recordings based on their assigned Recording Policy. Since we cannot stop the background job that deletes recordings, we must ensure that recordings under legal hold are assigned to the Legal_Hold_Indefinite policy.

However, the PATCH endpoint for recordings does not allow changing the policyId directly for all recording types. For voice recordings, you must use the Recording Policy Assignment API.

  1. Create a scheduled flow or a webhook-triggered flow that runs periodically (e.g., nightly).
  2. Query all recordings with customAttributes.LegalHoldCaseId not empty.
  3. For each recording, check if its current policyId matches the Legal_Hold_Indefinite policy ID.
  4. If not, update the recording’s policy.

Note: Changing the policy on an existing recording moves the physical file to the new storage bucket associated with that policy if storage locations differ. This operation is heavy. Limit this to nightly batches.

3. Integrating with External Storage for Immutability (Optional but Recommended)

For high-stakes litigation, Genesys Cloud’s internal deletion safeguards may not be sufficient. You should integrate with AWS S3 or Azure Blob Storage using Genesys Cloud Media Storage.

Step 3.1: Configure Object Locking

  1. In your AWS S3 bucket, enable Object Lock in Compliance Mode.
  2. Set the default retention period to match your legal hold duration.
  3. In Genesys Cloud, configure the Recording Policy Legal_Hold_Indefinite to use this external storage destination.

The Trap: Object Lock in Compliance Mode cannot be overridden by anyone, including Genesys Cloud administrators. If you misconfigure the retention period, you cannot shorten it. Ensure your legal team approves the retention duration before enabling this.

Step 3.2: Automating the Tag-to-Storage Move

When a recording is tagged with LegalHoldCaseId, the nightly batch job should also update the recording’s storage location if it is not already in the immutable bucket. This requires a two-step process:

  1. Update the Recording Policy to point to the immutable bucket.
  2. Genesys Cloud will replicate the recording to the new bucket.

Validation, Edge Cases & Troubleshooting

Edge Case 1: The “Race Condition” on Deletion

The Failure Condition: A recording is created at 23:59. The legal hold trigger arrives at 00:01. The nightly deletion job runs at 00:15. The recording is deleted before the hold is applied.
The Root Cause: The hold application is asynchronous and batched.
The Solution: Implement a Pre-Deletion Hook. While Genesys Cloud does not offer a direct pre-deletion hook, you can mitigate this by:

  1. Setting the default retention for all queues to a minimum of 24 hours.
  2. Running the legal hold application flow every 15 minutes instead of nightly.
  3. Ensuring the Legal_Hold_Indefinite policy has a retention period longer than the maximum gap between hold triggers and application jobs.

Edge Case 2: Transcription and PII Redaction Conflicts

The Failure Condition: A recording is under legal hold. The system is configured to auto-redact PII (credit cards, SSNs) and auto-transcribe. The redaction process modifies the audio file, potentially altering the original evidence.
The Root Cause: Redaction creates a new audio file, replacing the original. If the original was the evidence, it is now gone.
The Solution:

  1. In the Legal_Hold_Indefinite policy, disable automatic redaction and transcription.
  2. If transcription is required for discovery, generate it manually on a copy of the file stored in the immutable bucket, outside of the Genesys Cloud lifecycle.
  3. Document this exemption in your legal hold policy.

Edge Case 3: Agent Termination and Historical Records

The Failure Condition: An agent is terminated. Their account is deactivated. A legal hold is issued for that agent’s historical calls. The API query for agentIds fails because the agent no longer exists.
The Root Cause: Deactivated users are often excluded from standard user lookups or have their ID recycled (rare but possible).
The Solution:

  1. Store the agent_id in a permanent database (e.g., SQL table) when the hold is triggered, regardless of the agent’s current status.
  2. Use the Historical Recordings API which indexes recordings by agentId even if the user is deleted, provided the recordings were created while the user was active.
  3. Query recordings by startTime and endTime combined with queueId if the agent ID is no longer resolvable.

Edge Case 4: Cross-Region Data Residency

The Failure Condition: The litigation requires data to remain in a specific jurisdiction (e.g., EU). The recording was made by a US agent but involves an EU customer. The recording is stored in a US Genesys Cloud region.
The Root Cause: Genesys Cloud stores data based on the organization’s region, not the customer’s location.
The Solution:

  1. Ensure your Genesys Cloud tenant is in the correct region from the start.
  2. If you have a multi-region setup, use Architect to route calls to the correct region based on customer location.
  3. For legal holds, verify the storage bucket’s geographic location. If using external storage, ensure the bucket is in the compliant region.

Official References