Call Recording Privacy Notice
HTS Group Limited (HTS) is committed to protecting your privacy when you use its services. This Privacy Notice explains how HTS (as the ‘Data Controller’) collects, processes and protects your personal data generally in its Call Centre and who this information may be shared with. There is a telephone call recording system in operation in HTS and this Privacy Notice explains how, when and why incoming and outgoing calls to the following areas are monitored:
• Repairs and Maintenance Department
• Business Support Department
When calls are transferred from any of the above service areas to any other departments in HTS, once the connection has been made, the recording stops – neither are internal calls recorded.
What information is collected?
We collect and retain, as necessary, personal information including the recording of phone calls which may include personal details which you provide to us.
The source(s) of personal information provided during a phone call may include:
• Information provided directly by you (e.g. name, postal and/or email address, health conditions etc)
• Information provided by another member of the public (e.g. complaint or concern)
• Information provided by an elected Councillor on behalf of you
• Information provided by other organisations (e.g. Emergency Services, Landlords)
Why we collect your personal information and how it is used?
We require this information to understand your needs and to provide you with a better service. If you fail to provide the necessary information required, we may not be able to comply with our its statutory duties or to provide you with the necessary and relevant services.
Calls are recorded under the legal basis of legitimate interest and consent. However, if you do not want your call to be recorded, you may state this at any time during the call and we will stop the recording immediately. In this situation, you may be advised to contact us by in writing. In exceptional circumstances, for example when we determine that continuing to record could cause harm or distress to you, you may be transferred to a non-recorded phone. Also, if a call is transferred to another department not listed above the call recording function will stop.
Please be advised that we also collect information for the following reasons:
• Quality and Training Purposes
Written records only provide partial information. A call recording provides a more rounded view and allows us to better understand your experience and assess the processes applied. This can help identify any improvement areas and ensure the quality of service provided by our employees. By using the information within the recording to inform training subjects and individual employee continuous improvement plans, we can improve our services to you.
• Complaints and Disputes
Some calls are verbally resolved. However, where information is entered onto an electronic system, this becomes the established record. In the event of a complaint or dispute, a call recording, may provide additional information to help us investigate any allegations and protect the interests of the data subject.
• Legal Claims
For use in the defence of any legal claim
• Employee Safety and Wellbeing
HTS has a duty of care to its employees and will not tolerate unreasonable or behaviour. Therefore, call recordings may be used in any investigations into staff safety issues.
Where is the information retained/stored?
Call recording data is stored securely and in an encrypted manner within the UK
How long is the information retained/stored?
In line with the HTS Retention and Disposal Policy, all call recordings will be held securely for 130 days unless the recording forms part of an ongoing investigation. In this case you will be informed that we will retain the recording until it is no longer required for this purpose after which it will be securely destroyed.
Will the information be shared?
There may be times when HTS will be required to share your personal information with a third party (e.g. subcontractors working on behalf of HTS, Harlow District Council etc) or where there is a legal obligation for the information to be shared (to stop a crime or fraud). Where there is a need to share your personal information, we will ensure that there is an Information Sharing Agreement in place to protect your information. Where the information is of a sensitive nature, for example about your health, explicit consent will be requested before this information is shared, unless we are required, or permitted, to share this by law.
Further information on how we process your information can be found on our overarching privacy notice page https://www.htsgroupltd.co.uk/privacy-notice/.
For reporting purposes, your personal information may be converted (‘anonymised’) into statistical or aggregated data in such a way that ensures that you are not identifiable.
Complaints or queries
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. If you have any concerns, questions or comments please contact the Data Protection
HTS Group Limited
Mead Park Industrial Estate
If having exhausted the complaint process you are not content that your request or review has been dealt with correctly, you can appeal to the Information Commissioner’s Office to investigate the matter further by writing to:
Information Commissioner’s Office