Introduction
HTS Group Limited and its subsidiary companies (“HTS”, “we”, “our” or “us”) are committed to protecting the privacy, security and confidentiality of personal information.
This Privacy Notice explains how we collect, use, store and share personal information.
This Privacy Notice applies to:
- HTS Group Limited;
- HTS (Property and Environment) Limited; and
- HTS (Housing and Regeneration) Limited.
The relevant HTS company will act as the Data Controller for the personal information it processes and will do so in accordance with applicable data protection legislation.
Information We Collect
HTS may collect, store and process the following categories of personal information:
- Name, address and contact details;
- Property information;
- Service requests and repair histories;
- Resident, tenancy and property-related information necessary to deliver repairs, maintenance and compliance services;
- Appointment and access information;
- Records of communications, including emails, letters, website enquiries and telephone calls;
- Telephone call recordings where calls are recorded;
- Complaint, feedback and customer satisfaction information;
- Photographs relating to inspections, repairs, defects and completed works;
- CCTV images and security system records;
- Vehicle registration details where relevant;
- Website, cookie and digital usage information, including information collected through analytics tools where consent has been provided;
- Vulnerability, safeguarding and communication needs information where necessary to support safe and effective service delivery;
- Information required to comply with legal, regulatory and contractual obligations.
Where special category personal information is required, such as health or vulnerability information, it will only be processed where necessary and lawful to do so.
How We Collect Information
We collect personal information directly from individuals wherever possible. We may also receive information from Harlow District Council, partner organisations, contractors, public authorities and members of the public where this is necessary for the delivery of our services and the performance of our functions.
HTS may collect personal information:
- Directly from individuals;
- From Harlow Council and other partner organisations;
- Through service requests and enquiries;
- Through appointments, inspections and service visits;
- Through repairs, maintenance and compliance activities;
- Through telephone calls, emails, correspondence and website forms;
- Through CCTV and security systems where applicable;
- Through contractors and suppliers acting on our behalf;
- Through photographs and records created during service delivery;
- From publicly available sources where appropriate.
In some circumstances, we may require personal information in order to deliver services, meet legal obligations or respond to enquiries. If this information is not provided, we may be unable to deliver the relevant service or respond effectively to a request.
Website Cookies
HTS uses cookies and similar technologies to help our website function, understand how it is used and protect online forms from spam and misuse. Non-essential cookies, including Google Analytics cookies, are only used where you have provided your consent through our cookie banner. You can accept or decline non-essential cookies and may change your preferences at any time through your browser settings. Our website also uses Google reCAPTCHA and Google Fonts.
How We Use Your Information
HTS may use personal information to:
- Deliver repairs, maintenance, environmental and property-related services;
- Arrange appointments and manage access to properties;
- Communicate with residents, customers and service users;
- Manage enquiries, complaints and feedback;
- Support resident, visitor and employee safety;
- Maintain accurate service and property records;
- Record property maintenance and compliance history;
- Verify works undertaken and service delivery activities;
- Monitor and improve service quality and customer experience;
- Prevent and detect fraud, crime and anti-social behaviour;
- Protect individuals, property and assets;
- Comply with legal, regulatory and contractual obligations;
- Establish, exercise or defend legal claims.
Telephone Call Recording
HTS may record telephone calls for legitimate business purposes, including:
- Staff training and quality assurance;
- Service improvement;
- Complaint investigation and resolution;
- Verification of instructions and information provided;
- Protection of customers, employees and the organisation;
- Prevention and detection of fraud or unlawful activity;
- Establishment, exercise or defence of legal claims.
Where calls are recorded, callers will be informed through an appropriate recorded message or other suitable means.
CCTV and Security Systems
HTS operates CCTV and other security systems at certain locations to help:
- Protect employees, contractors and visitors;
- Prevent and detect crime, anti-social behaviour and fraud;
- Safeguard property, equipment and assets;
- Assist with the investigation of incidents, complaints and disputes;
- Support health and safety obligations;
- Support fire prevention through the monitoring of heat signatures.
Where CCTV is in operation, appropriate signage will be displayed.
Information captured by CCTV and security systems may be accessed and reviewed where necessary and may be disclosed to law enforcement agencies, insurers, professional advisers or other authorised organisations where lawful and appropriate.
Property Access, Repairs and Maintenance Systems
HTS uses electronic systems and management software to deliver repairs, maintenance, compliance and environmental services.
These systems may contain:
- Resident names and contact details;
- Property and tenancy-related information;
- Appointment and access arrangements;
- Service requests and repair records;
- Communication histories;
- Vulnerability, safeguarding and communication needs information where necessary to support safe and effective service delivery;
- Photographic evidence relating to inspections and works.
This information is used to:
- Deliver services effectively and safely;
- Schedule and complete repairs and maintenance activities;
- Manage access arrangements;
- Protect residents, customers and employees;
- Investigate complaints, incidents and disputes;
- Demonstrate works completed;
- Meet contractual, legal and regulatory requirements.
Where photographs are taken as part of inspections, repairs, maintenance or compliance activities, HTS will seek to minimise the collection of personal information and will only use photographs where necessary for service delivery, quality assurance, complaint handling, insurance purposes, health and safety, regulatory compliance or the establishment, exercise or defence of legal claims.
Lawful Basis for Processing
HTS processes personal information in accordance with the UK GDPR and the Data Protection Act 2018.
In most cases, HTS processes personal information because it is necessary to perform contractual and property management services on behalf of Harlow Council, comply with legal obligations, or pursue legitimate interests associated with the delivery of repairs, maintenance, compliance and environmental services.
The lawful bases relied upon may include:
- Performance of a contract;
- Compliance with a legal obligation;
- Legitimate interests;
- Protection of vital interests;
- Consent, where required or appropriate.
Where special category personal information is processed, HTS will identify an additional lawful condition under Article 9 UK GDPR and Schedule 1 of the Data Protection Act 2018.
Sharing Personal Information
HTS may share personal information where necessary and lawful to do so.
Recipients may include:
- Harlow Council;
- Contractors and service providers acting on behalf of HTS;
- Software and system providers;
- Professional advisers, insurers and auditors;
- Regulatory authorities;
- Law enforcement agencies;
- Courts and tribunals;
- Government bodies;
- Other organisations where required by law or necessary for service delivery.
Personal information will only be shared where there is a lawful basis to do so and appropriate safeguards are in place.
International Transfers
HTS does not routinely transfer personal information outside the United Kingdom.
Where personal information is transferred internationally, appropriate safeguards will be implemented to protect the information in accordance with applicable data protection legislation.
Data Retention
HTS will retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, contractual, operational, insurance and business requirements.
Retention periods will vary depending on the nature of the information, the purpose for which it was collected and any applicable legal or regulatory requirements.
When determining how long information should be retained, HTS will consider:
- The purpose for which the information was collected and is used;
- Legal and regulatory requirements;
- Limitation periods for potential legal claims;
- Insurance requirements;
- Business and operational needs;
- The risks associated with retaining or deleting the information.
Where personal information is no longer required and there is no legal, regulatory, contractual, insurance or operational reason to retain it, HTS will take reasonable steps to securely delete, destroy or anonymise the information.
Your Rights
Individuals have rights under data protection legislation, including the right to:
- Be informed about how personal information is used;
- Request access to personal information;
- Request correction of inaccurate information;
- Request erasure of information in certain circumstances;
- Request restriction of processing in certain circumstances;
- Object to processing in certain circumstances;
- Request portability of information where applicable;
- Withdraw consent where processing is based on consent.
Requests will be considered in accordance with applicable data protection legislation.
Contact Us
If you have any questions about this Privacy Notice or how HTS processes personal information, please contact:
Data Protection Lead
HTS (Property and Environment) Ltd
Mead Park Depot
River Way Industrial Estate
Harlow
Essex CM20 2SE
Email: data.protection@htsgroupltd.co.uk
Telephone: 01279 446900
Complaints
If you are unhappy with how HTS has handled your personal information, please contact us in the first instance.
You also have the right to complain to the Information Commissioner’s Office (ICO):
Website: www.ico.org.uk
Telephone: 0303 123 1113