Overview and Governing Policy
The primary policy for offender telephone access is SOP 227.01 – Offender Access to Telephones (Facilities Division, effective 03/27/2023). The opening statement of policy is unambiguous: "Each facility shall provide offenders with reasonable and equitable access to telephones and this policy and procedure governs offender use of telephones." The Warden or Superintendent retains authority to "determine the appropriate supervision of offender telephone calls in a manner consistent with the mission of the facility."
Two additional telecommunications policies — SOP 105.04 – Telecommunications Policy Statement and SOP 105.10 – Long Distance Calling — address the infrastructure side of GDC phone services, including staff obligations and GDC's reserved right to monitor all voice communications.
The Offender Phone System
SOP 227.01 defines the Offender Telephone (Phone) System as "telephones and related equipment that are installed in GDC facilities to enable offenders to complete local, long distance and/or international collect, pre-paid, debit and free calls, and which may also be used by GDC for investigative purposes." A private Service Provider (a vendor under contract with GDC) operates this system. Certain large facilities have On-Site Offender Telephone System Staff employed by the Service Provider, while other facilities rely on a designated Offender Telephone System Facility Point of Contact — a GDC staff member — to address system matters. Statewide compliance with the vendor contract is overseen by an Offender Telephone System Compliance Monitor employed by GDC.
SOP 227.01 does not publish specific per-minute call rates, and the SOPs in this corpus do not contain rate schedules. Rate information would be embedded in the vendor contract, which is not an SOP.
Call Allow Lists and Approved Contacts
SOP 227.01 requires each offender to "submit a phone list, or Diagnostic/Permanent Offender Call Allow List ('Call Allow List') (Attachment 1), and Attorney Telephone Request Form (Attachment 2)." This is the mechanism by which contacts are added to an approved list before calls can be placed. The policy identifies two forms:
- Attachment 1 – Diagnostic/Permanent Offender Call Allow List (general contacts)
- Attachment 2 – Attorney Telephone Request Form (legal contacts)
The policy does not specify in the excerpted content how many numbers may be on the list, how long approval takes, or the process for challenging a denied contact.
Attorney Calls
SOP 227.01 defines Attorney narrowly as "the offender's Attorney of record or an Attorney employed by the Public Defenders Council." Calls from attorneys are treated as a distinct category. The policy states that "Emergency Telephone Calls from family and friends of offenders and calls from Attorneys will be directed to the offender's assigned counselor or the chaplain for verification and further action if needed." Offenders must submit a separate Attorney Telephone Request Form (Attachment 2 to SOP 227.01).
Critically, SOP 227.01 is the only policy in this corpus that addresses attorney call procedures. The policy does not explicitly state whether attorney calls are recorded or monitored, a significant gap discussed further below.
Emergency Calls
SOP 227.01 defines Emergency Telephone Calls as "calls involving death or critical illness of Immediate Family members or other matters as determined by the Warden or Superintendent." Immediate Family is defined as "parents, siblings, spouse, grandparents, grandchildren, or children."
Emergency calls from family and friends are handled through the offender's assigned counselor or chaplain for verification. The Warden or Superintendent has discretion to expand the definition of "emergency" beyond death or critical illness of immediate family.
SOP 227.01 also states: "No long-distance telephone calls for offenders will be made at the facility's expense without authorization from the Warden or designee." This provision is relevant to emergency calls placed by or for the facility on the offender's behalf.
Recording and Monitoring
GDC's right to monitor offender calls is established across multiple SOPs, signaling that this is a high-priority institutional prerogative.
SOP 227.01 defines the Offender Phone System as equipment that "may also be used by GDC for investigative purposes," establishing that the system is built with monitoring in mind.
SOP 105.04 – Telecommunications Policy Statement states explicitly: "The Georgia Department of Corrections reserves the right to investigate, retrieve and read any communication or data composed, transmitted or received through voice services, online connections and/or stored on their respective servers."
SOP 105.10 – Long Distance Calling repeats the same language verbatim: "The Georgia Department of Corrections reserves the right to investigate, retrieve and read any communication or data composed, transmitted or received through voice services, online connections and/or stored on their respective servers." The identical statement appearing in two separate SOPs (105.04 and 105.10) underscores that GDC treats this as a foundational, department-wide right.
SOP 105.10 further requires that managers "review monthly phone bills" and that "call detail should be reviewed to check for any unusual patterns or abuse" — a staff-level monitoring obligation.
None of the SOPs in this corpus expressly exclude attorney calls from recording or monitoring. This is a significant gap: the policy corpus does not contain a provision protecting attorney-client communications from interception on the offender phone system, as is required under professional ethics rules and often under court orders in other jurisdictions.
Call Types and Payment Methods
SOP 227.01 identifies that the phone system supports "local, long distance and/or international collect, pre-paid, debit and free calls." No SOP in this corpus specifies the rates charged to offenders or their families for collect or debit calls, the terms under which free calls are provided, or caps on call duration.
Special Populations
Hearing-Impaired Offenders
SOP 227.01 provides for two accommodation types:
- TTY Phones – "Telephones with equipment (Teletypewriter) for offenders with hearing impairments."
- Video Relay Service (VRS) – "A telephone service using interpreters connected to callers by video hook-up that is designed to provide persons who are deaf and use American Sign Language with telephone services that are functionally equivalent to those provided to users who are hearing."
Foreign Nationals / Limited English Proficiency
SOP 227.01 defines Interpreting Phone Service as "telephone services using professional interpreters to communicate with the limited English proficient offender in his/her language." The policy also cross-references SOP 222.06, Consular Notification, for foreign nationals requiring consular contact. Consular calls appear to be treated as a distinct category with their own procedure.
Boot Camp Offenders
SOP 227.01 states plainly: "Boot Camp Offenders will only have access to phones in emergency situations." This is a near-total restriction on telephone privileges for this population, limited to the emergency call framework described above. SOP 210.04 (Boot Camp – Rights and Standards) does not address telephone access in the excerpted content, but SOP 227.01 governs.
Telephone Access in Restrictive Housing
Multiple restrictive-housing SOPs cross-reference SOP 227.01, signaling that telephone access in special management settings is governed by the same underlying policy framework, but privileges may be reduced based on phase or housing tier.
- SOP 209.08 – Administrative Segregation (Tier II) lists SOP 227.01 as a related directive, indicating the phone access SOP applies to Tier II segregation with such modifications as that program imposes.
- SOP 209.09 – Special Management Unit (Tier III Program) similarly lists SOP 227.01 as a governing authority. The Tier III program uses a five-phase incentive system where privileges are progressively expanded; phone access is likely among those privileges, but the specific phone allotments per phase are not detailed in the excerpted content.
- SOP 209.11 – Restrictive Housing Assignment – Juvenile Offender Administrative Segregation (RHA-JOAS) also cross-references SOP 227.01 (cited as IIB01-0007) as a governing directive.
None of the restrictive-housing SOPs in this corpus specify the exact number of calls permitted per week for each phase or housing level. Readers seeking that detail should request the full text of SOP 209.09 and related phone access provisions.
Staff Telephone Conduct and Oversight
For staff, SOP 105.10 governs long-distance calling on state lines. It prohibits personal long-distance calls except in emergencies, requires employees who make personal calls to reimburse the state, and permits "appropriate disciplinary action." Calls to directory assistance are to be prohibited unless a number cannot be obtained by other means (internet directories). Managers must review monthly GTA phone bills for "unusual patterns or abuse."
SOP 104.47 – Employee Standards of Conduct establishes a broader framework requiring all employees to annually sign a "Communications Device Acknowledgement and Agreement Statement" (Attachment 2), which governs employee use of any device "that allows for the transfer of information." This applies to personal cell phones brought into facilities, a security concern related to contraband phone smuggling, though that specific subject is not the primary focus of SOP 104.47.
Gaps and Conflicts
1. No explicit attorney-client call privilege protection. No SOP in this corpus states that attorney calls are exempt from recording or monitoring. SOP 227.01 creates a separate attorney call category and request form, but does not prohibit monitoring of those calls.
2. Call rates not addressed. No SOP specifies per-minute rates, connection fees, or rate caps for collect, debit, or pre-paid calls. This information resides in the vendor contract.
3. Warden discretion is broad but undefined. SOP 227.01 gives the Warden/Superintendent authority over "appropriate supervision" and over expanding the definition of emergencies, without specifying minimum access floors that cannot be reduced.
4. Restrictive housing phone allotments not specified. SOPs 209.08, 209.09, and 209.11 cross-reference SOP 227.01 but do not specify in the excerpted content the number of calls permitted per phase.
5. Boot Camp phone restriction vs. "reasonable and equitable access." SOP 227.01's general mandate of "reasonable and equitable access" is in tension with the same SOP's blanket restriction for Boot Camp offenders to emergency calls only. The SOP resolves this internally, but the result is a population-specific carve-out from the general access standard.
6. No call duration limits stated. The SOPs do not specify maximum call lengths, though these are typically set by the vendor contract.