Private space for confidential calls: GDPR and office design

Teams that discuss personal, financial or legal information need a private space for confidential calls because UK GDPR requires appropriate security for personal data, and the ICO records verbal disclosure as a type of data breach. An enclosed, acoustically rated pod or room close to the team is the practical answer in open-plan offices.

This article is general information for workplace planning, not legal advice.

Does UK GDPR cover conversations that can be overheard?

UK GDPR applies when a conversation discloses personal data that your organisation holds, and the security principle expects you to take reasonable steps to stop that happening by accident. Article 5(1)(f) requires personal data to be “processed in a manner that ensures appropriate security of the personal data”, including protection against unauthorised processing (legislation.gov.uk, UK GDPR Article 5). Article 32 asks controllers to implement “appropriate technical and organisational measures” and to consider in particular the risk of unauthorised disclosure (legislation.gov.uk, UK GDPR Article 32).

The law does not mention office layouts or phone booths. What it does is set a risk-based standard: if your staff routinely read out account details, discuss a colleague’s health or talk through a client’s legal position, the question is whether your arrangements make it likely that someone without a need to know will hear. The ICO’s own breach reporting shows this is not hypothetical, because it records “verbal disclosure of personal data” as a distinct incident type.

How often are verbal disclosures reported to the ICO?

Verbal disclosures are a smaller category than misdirected emails or unauthorised access, but they are reported every year. In response to a Freedom of Information request, the ICO published health-sector breach reports by incident type: verbal disclosure of personal data accounted for 98 reports in 2022, 86 in 2023 and 24 in the period from 1 January to 20 March 2024 (Information Commissioner’s Office, FOI response IC-295641, 2024).

Two points are worth keeping in mind. First, these are only incidents that organisations noticed and reported; a conversation overheard in an open office is rarely noticed by the speaker. Second, the figures cover one sector. Health is a useful indicator because its staff routinely discuss sensitive information, but HR, legal and financial teams in every sector handle similar material.

Looking at verbal disclosure as a share of all health-sector reports shows a steady presence rather than a falling trend, alongside the much larger category of unauthorised access.

Which teams need private space most?

The teams that need private space most are those whose everyday conversations include special category data, financial details or privileged information. The table shows typical examples and the kind of space that usually suits them.

Team	Typical confidential conversations	Suitable space
HR and people managers	Grievances, absence and health, performance, redundancy	Two- to four-person meeting pod or closed room
Payroll and finance	Salaries, bank details, debt and payment arrangements	Single booth for calls
Legal and compliance	Client matters, disputes, investigations	Single booth plus small meeting pod
Customer service and collections	Account details, vulnerability, card payments	Single booths near the team
Healthcare administration	Patient information, referrals, results	Single booth or focus pod
IT and security	Incident response, credentials, access reviews	Single booth or focus pod

For legal teams the duty is explicit. The Solicitors Regulation Authority’s guidance says paragraph 6.3 of its Codes requires firms to “keep the affairs of current and former clients confidential”, and that “all your staff members including support staff, consultants and locums, owe a duty of confidentiality” (Solicitors Regulation Authority). Similar professional duties apply to accountants, healthcare workers and financial advisers. For contact centres handling sensitive calls, see our guide to contact centre phone booths.

What appropriate measures look like in an open-plan office

Appropriate measures combine physical space, sensible layout and clear habits. The ICO’s guide to data security treats physical security as part of an organisation’s technical measures, covering access control and how visitors are supervised, and says organisations should “build a culture of security awareness” and run “periodic checks to ensure that your security measures remain appropriate and up to date” (Information Commissioner’s Office, A guide to data security).

For conversations, that translates into a short list:

• Provide somewhere to go. Staff cannot follow a rule to “take sensitive calls privately” if the nearest private space is two floors away or always booked.
• Place it close to the team. A pod within a few metres of the HR or finance team will be used; a meeting room down the corridor often will not.
• Control who passes by. Avoid positioning confidential spaces next to reception, visitor routes or kitchens.
• Set simple expectations. Include “take calls involving personal data in a booth or closed room” in data protection training and induction.
• Check it periodically. Ask staff whether they can hear calls from the booth at nearby desks, and adjust placement or add absorption if needed.

Acoustic panels and sound masking help reduce how far speech carries across the floor, but they do not create a closed space. Our comparison of acoustic panels and office pods explains where each fits.

How private is a phone booth or meeting pod?

A good pod makes normal speech inside much harder to understand outside, but no standalone pod is soundproof in an absolute sense. Privacy depends on the pod’s speech level reduction, the background noise outside, how close people sit to it, and how loudly the user speaks.

The useful measure is speech level reduction to ISO 23351-1, a laboratory method that gives a single number for how much a booth reduces the A-weighted sound power of standard speech between 125 Hz and 8,000 Hz (ISO, 2020). For distraction and privacy, intelligibility matters more than loudness: research on open-plan offices found that the Speech Transmission Index explains the disturbing effect of speech much better than its level (Hongisto, CLIMA 2007 via AIVC). In practice, a pod that turns clear speech into an indistinct murmur at the nearest desk is doing its job.

The specialist pod manufacturers we work with give factory-rated noise reduction of 30–45 dB depending on model. For the most sensitive conversations, such as a dismissal meeting or a legal privilege discussion, a full-height room with a solid door may still be the right choice. Our guide to how soundproof office pods are explains how to compare figures.

How many confidential spaces does a team need?

The number of private spaces a team needs depends on how often its work involves sensitive conversations, not simply on headcount. A ten-person HR team may need more private space than a forty-person marketing team, because a larger share of its calls and meetings involve personal data.

A practical way to estimate demand is to audit a typical fortnight:

1. List the conversation types that involve personal, financial or privileged information, such as payroll queries, absence calls, client updates or account reviews.
2. Estimate how often each happens and how long it lasts. A ten-minute payroll call and a one-hour grievance meeting need different spaces.
3. Note where they happen today. If people are stepping into stairwells, car parks or empty kitchens, that is a sign of unmet demand and of risk.
4. Separate calls from meetings. Calls usually suit single booths; face-to-face conversations need a two- to four-person pod or a room.
5. Allow for peaks. Month-end in payroll, review season in HR and renewal periods in client teams can double demand for a few days.

Video calls add a second layer of risk: a screen showing a spreadsheet of salaries or a patient record can be seen by passers-by even when the audio is private. Positioning the desk in a pod so the screen faces the back wall is a simple fix worth including in the layout. For general ratios across the whole office, see our guide on how many phone booths per employee.

Choosing pods for confidential conversations

Choose single booths for calls and small meeting pods for face-to-face conversations, then specify glazing, seals and placement with privacy in mind.

• Single calls: the Smart Privacy Pod or a standard booth (about W1000 × D1000 × H2250 mm) suits one person on a call.
• One-to-ones and HR meetings: the Lounge L4 meeting pod (W2390 × D1906 × H2300 mm, up to four people) gives soft seating for conversations that need a calmer setting.
• Visual privacy: clear glass makes a pod feel open but shows who is inside. Frosted bands or film can be discussed as part of an OEM or custom pod order.
• Seals and door closing: continuous door seals matter more for privacy than wall thickness. Check them during maintenance.
• Booking rules: keep at least one pod walk-in only, so urgent sensitive calls are not delayed.

Browse the full range of meeting pods for larger confidential discussions.

Frequently asked questions

Is an overheard conversation a data breach?

It can be. The ICO records “verbal disclosure of personal data” as an incident type in breach reports. Whether a specific case is reportable depends on the data involved and the risk to the people concerned, so follow your data protection officer’s guidance.

Do we have to provide private rooms under UK GDPR?

The law does not require any particular room or product. It requires appropriate technical and organisational measures for the risk, so organisations that regularly discuss sensitive personal data should be able to show how they reduce the chance of being overheard.

Are glass-fronted pods private enough?

Glass affects visual privacy more than acoustic privacy, provided the glass and seals are well specified. If people should not be seen, consider frosted bands or film.

Which teams should get pods first?

Start with HR, payroll and finance, legal, and customer teams handling account or health details, because their routine calls carry the highest risk.

Conclusion

Confidential conversations need somewhere private and close by, and pods let you add that space quickly in an open-plan office. If you are planning for HR, finance, legal or customer teams, send us a quote request with the team sizes and floor plan, and we will suggest a mix of booths and meeting pods.

Sources

• legislation.gov.uk – UK GDPR Article 5, principles relating to processing of personal data (accessed October 2026)
• legislation.gov.uk – UK GDPR Article 32, security of processing (accessed October 2026)
• Information Commissioner’s Office – FOI response IC-295641, health sector breaches by incident type (accessed October 2026)
• Information Commissioner’s Office – A guide to data security (accessed October 2026)
• Solicitors Regulation Authority – Confidentiality of client information (accessed October 2026)
• ISO – ISO 23351-1:2020 Measurement of speech level reduction of furniture ensembles and enclosures (accessed October 2026)
• AIVC – Hongisto, Office noise and work performance (CLIMA 2007) (accessed October 2026)