This Privacy Notice is a public document available to anyone and applies to customers of Housing Maintenance Solutions (HMS), a wholly owned subsidiary of Torus 62 Limited. The purpose of the notice is to explain how the organisation collects and processes personal information in order to conduct normal business activities as a building and maintenance contractor. Normal activities can be summarised as:
We also provide additional optional services associated with our core activity including:
2. Who we are
Housing Maintenance Solutions (HMS) is a wholly owned subsidiary of Torus 62 Limited whose operational office is located at Unit 4, Electric Avenue, Stonebridge Park, Liverpool L11 0EL. Tel: 0800 678 1894. The company Data Protection Officer can be contacted at firstname.lastname@example.org. HMS delivers building and construction services to over 15,000 properties in the Liverpool region for the company and employs around 300 staff. HMS forms part of the the company structure which also includes Torus Foundation and Torus Developments working together to deliver services to our customers.
3. How we collect your information
HMS collects information from you via a variety of sources, including forms, phone calls, written communication or via digital methods such as websites and customer portal.
Our Customer Service Centre phone calls are recorded for training and monitoring purposes and our recordings are held for a period of three months.
We operate a continuous CCTV system at all our office premises for the detection and prevention of crime and recordings are held for two months. CCTV / sound recordings and / or use photography may be used to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.
Photographs may be taken and used for general marketing providing individuals give consent for business related purposes.
4. What information we collect about you
The information we require from you, includes:
The above information is required for us to deliver services as detailed in section 1. Without this information we would not be able to provide our services and so you would not be able to become our customer as we could not meet our obligations to you or our obligations to our clients.
Additional information may be requested including:
5. What processing we do with information collected
The information we require from you is to provide services to our customers and ensure compliance with activities carried out on behalf of our clients.
The processing activities we conduct can be summarised as:
HMS operates a range of information communications systems and technologies for efficient operation of the business both for own processing purposes and on behalf of our clients. Personal information is stored and managed within those systems which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practice cyber security standards.
Information held on IT systems is data protection compliant.
6. Lawful Basis
HMS only processes your personal data where we have a proper lawful basis to do so.
We rely on two main lawful bases for our processing activities.
In certain instances, where our processing relates to something not covered above, we may rely on your consent as the lawful basis for that processing. Where you have given consent, you may withdraw your consent at any time by contacting email@example.com.
7. Additional services
HMS conducts a number of additional voluntary services including organising community events.
For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about HMS, contact information for the Data Protection Officer and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
8. Property information
Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information.
We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.
As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
9. How we will communicate with you
HMS needs to communicate with our customers and this will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. Repair services can be accesses via digital platforms (online) to allow convenient access such as ‘My Account’ – the company's secure online self-service portal for Torus tenants.
If you use the ‘My Account’ service it is important that you keep your account & password secure and do not share your ‘My Account’ details with any other person.
HMS will operate an opt-in mechanism for receiving direct marketing. You may remove your consent to receive direct marketing or object about direct marketing to firstname.lastname@example.org.
We will only discuss or communicate your tenancy or lease details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
10. Who we share data with and how long we keep information
HMS shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to complete responsive or planned property repairs.
We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
HMS may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.
11. What we will not do
We will not send you unsolicited marketing material.
We will not sell your personal data on to third parties.
We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that.
We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.
12. Your rights, the right to complain and the ICO
You have the right to request a copy of the data we hold about you. Please contact email@example.com if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service.
We will respond within one month of receiving your request. It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search.
You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting our Customer Services team on 0800 678 1894 or via e-mail to firstname.lastname@example.org
You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to email@example.com. Where your data is no longer required for the purpose for which it was originally collected, you have the right to request that we delete your data. This is sometimes known as ‘the right to be forgotten.’ If you believe this applies to your data and you would like us to delete it, please contact firstname.lastname@example.org.
Where you contest the accuracy of the data that we hold about you, where you have objected to the processing that we carry out in pursuit of our legitimate interest, or where we no longer require your data but you do need it for a legal claim, you have the right to block or suppress our
processing of your data. This means that we will cease our normal processing of your data and process only the minimum to ensure that the restriction is respected going forwards. We will continue to store your data. If you believe this applies to your data and you would like us to restrict our use of it, please contact email@example.com.
You have the right to a structured, commonly used and machine readable copy of your personal data that we use to manage your tenancy, your account with us and your property. You have the right to have this data delivered to you or to a third party of your choice. Please contact firstname.lastname@example.org if you would like a copy of your data in this format and our team will be happy to help.
You have the right to object, on grounds relating to your particular situation, to processing that we do in pursuit of our legitimate interest to ensure that tenancy obligations are complied with. We will re-evaluate our processing, and unless we can demonstrate compelling legitimate grounds to continue, we will stop processing your data for those purposes. If you would like to object to this processing please contact email@example.com. with your reasons and one of team will be in touch.
We may use your personal data to send marketing information about products or services that we think that you might be interested in. If you would prefer not to receive direct marketing from us, you can let us know at any time by contacting firstname.lastname@example.org.
We do not make any solely automated decisions that produce legal or similarly significant effects for you using your personal data. If this changes, we will let you know.
You can find more information about your rights, and data protection in general, on the website of the Information Commissioner’s Office here: https://ico.org.uk
You have the right to complain about any matter relating to our service, including how we use your personal data:
In the first instance please contact our Customer Services team on 0800 678 1894 or e-mail email@example.com.
If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk
13. Further information
For further information about HMS, please see our website at www.hmsworks.co.uk (including website terms & conditions and information about website cookies) or contact our Customer Services team. This privacy notice will be subject to amends at times and will be available online at www.hmsworks.co.uk.
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