Hill is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person. Hill processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process personal data. We will comply with all relevant data protection laws.
OUR PROCESSING ACTIVITIES
We do not sell customer’s personal data to third parties and will only use your personal information to provide you with details of our own products, properties or developments which we believe will be of interest to you. We may also use your information to contact you:
• For legitimate purposes aligned with our contract.
• In relation to a previous communication from you. This may include any comment or complaint concerning us, our services, properties or developments, or any previous contact we may have had with you.
• If you requested further information or signed up to a product, property or development, whether directly through us or via a third party such as an estate agent.
• If you have expressed an interest in a specific product, property or development.
• To provide you with additional information concerning a specific property or development, type of property or development, or similar to those in which you have expressed an interest.
• For marketing purposes if you have chosen to receive a service from us by completing an online form or using your preference centre and not opted out.
CCTV AND CALL MONITORING
Our company offices, developments and sales offices use CCTV to ensure we provide a safe and secure environment for all visitors to our premises and to make sure we protect our employees and property.
We also record calls for training, monitoring and quality purposes to and from our Customer Service helpline.
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering the general data protection regulations, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
When and how we share personal data and locations of processing:
• We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with the new data protection regulations, confidentiality and security standards.
• We do not transfer any data to countries outside the European Union (“EU”).
• Personal data held by us may be transferred to third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage some of our internal IT systems.
• For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating these services are located in secure data centres ONLY within the EU, and personal data may be stored in any one of them.
• Third party organisations that otherwise assist us in providing goods, services or information Professional advisers.
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
CHANGES TO THIS PRIVACY STATEMENT
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on 23 May 2018.
DATA CONTROLLER AND CONTACT INFORMATION
The data controller is Hill Holdings Limited (Company No. 04202304 whose registered office is at The Power House, Gunpowder Mill, Powdermill Lane, Waltham Abbey, Essex EN9 1BN). The data controller acts on behalf of all Hill companies and joint partnerships where we have a vested interest.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at:
Data Protection Officer
The Power House
Phone: 020 8527 1400
INDIVIDUALS’ RIGHTS AND HOW TO EXERCISE THEM
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
ACCESS TO PERSONAL DATA
You have a right of access to personal data and supplementary information held by us as a data controller. This right may be exercised by emailing us at GDPR@hill.co.uk. We will provide a copy of the information free of charge. However, we may charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive.
ACCESS TO PERSONAL DATA, cont
We may also charge a reasonable fee to comply with requests for further copies of the same information. The fee will be based only on the administrative cost of providing the information.
We will aim to respond to any requests for information without delay, and in any event within the legally required time limits (currently one month of receipt).
AMENDMENT OF PERSONAL DATA
To update personal data submitted to us, you may email us at GDPR@hill.co.uk or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
WITHDRAWAL OF CONSENT
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at GDPR@hill.co.uk or, to stop receiving an email from a Hill marketing list, please click on the unsubscribe link in the relevant email received from us.
OTHER DATA SUBJECT RIGHTS
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability. Some of these rights will only be available from 25 May 2018.
If you wish to exercise any of these rights, please send an email to GDPR@hill.co.uk
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to GDPR@hill.co.uk. We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website: