PHS Home Solutions Limited (PHS) is committed to protecting the privacy of your personal information. PHS is Registered with the Information Commissioners Office (ICO) and complies with the Data Protection Act 2018 and with the data protection principles set out in the Act and the UK General Data Protection Regulations (UK GDPR) effective from May 2018.
Good information handling makes good business sense. By doing this we believe we will enhance our business’s reputation, increase customer and employee confidence, and by making sure personal information is accurate, relevant and safe, save both time and money.
Our organisation act as a Data Controller as we keep or process information about living people and must comply with certain important rules about how we collect and use personal information.
Lawful Basis for Processing
Our firm must have a valid lawful basis in order to process a person’s data and be able to demonstrate the processing of data is “necessary” in order to provide our products and services. There are six lawful bases.
Our organisation process on the basis of the following:
CONTRACT – We may have to process information to fulfil our contractual obligations for an installation, or provide a quotation, or enter into a finance agreement, or enter into an insurance policy through a provider, or provide a warranty or service arrangement. In this instance the processing is necessary for the performance of the contract.
LEGAL OBLIGATION – We may have to check data against the HMT Sanctions List which is a legal obligation or process information for health and safety reasons. In this instance Health and Safety is legislation.
LEGITIMATE INTERESTS – In many instances the processing is necessary, for example to create a Green Deal Advice Report, Energy Performance Certificate, Green Deal Finance Plan, act as a credit intermediary in order to arrange a Finance Plan, access or check eligibility, carry out a Customer Survey Report, arrange an insurance policy with a provider.
CONSENT – We ask person’s to positively opt in if they want to receive further information on a product or service that we market separately.
We process special category data where this is necessary.
Collection of Information – your consent
We may collect personal information from you if you provide it voluntarily. If you provide personal information to use, we will assume that you have read this Privacy Notice Policy and have consented to us using your personal information in the ways described in this Policy and at the point where you give us your personal information. If, after providing us with personal information, you later decide that you do not want us to use it for particular purposes, then please write to us at the address shown.
Collection of your Information. What information do we collect and when?
We may collect and process the following data:
- Information you provide when buying our products or services
- Information you provide to us by filling in forms on our websites
- Information collected through correspondence with our Sales and/or Customer Relations teams
- Information you provide to us through the recruitment process
- Information you provide to us in order to register for alerts
- Social Media interaction
- Information you provide to us by entering competitions
- Statistical data about your browsing actions and patterns for the administration of your application for employment
We may monitor or record any communications between you and us including telephone calls. We will use these recordings to check your instructions to us, to analyse, assess and improve our services to customers, complaints handling, and for training and quality purposes.
We may require you to submit personally identifiable information in order for you to make use of our services. You confirm that any information you enter will be true. We will only request and collect information which is necessary or reasonable in order to provide you with your requested services and to improve the services that we provide. It will not be a requirement to provide any additional information which is not needed to provide the services
Credit or debit card information when making purchases via this method
Profile information and insight from organisations that already hold information on you, such as credit reference agencies and “customer insight companies”. They give us their views on your household, your status, as well as your possible preferences and behaviours
Reasons for Collection of your Information and how we use your information
In the course of our dealing with you we may collect and process certain information about you, including your name, date of birth, address, contact details (including your email address and contact telephone number), payment details (where applicable), any benefits you receive or are entitled to (including disability benefits) (where applicable), and other information about you and your property in respect of which services and products may be provided. Your personal information may be used by us, our employees, contractors or agents to:
- identify you during any communication between you and us;
- assess eligibility for services and products (whether provided by us or on our behalf);
- manage your credit agreement where applicable;
- carry out regulatory checks and meet our obligations to our regulators;
- cross reference and screen your data against the HMT Sanctions List;
- carry out DBS Checks and processing data about criminal convictions, criminal offences or related security measures as required, where persons acting in a sales position or senior position for or on behalf of our firm. No register of criminal convictions would be kept;
- communicate with you to arrange the provision of such services and products;
- administer and provide such services and products;
- detect and prevent loss, fraud and other criminal activity;
- carry out credit reference checks;
- carry out market research and to help us review, develop and improve the services and products we offer;
- contact you (in accordance with your preferences), by post, telephone, SMS, email and other electronic means with information about products, services, promotions, and offers that may be of interest to you
identify you during any communication between you and us;
- keep legal certificates and work records relating to the services we have provided to you to include any details relating to
- Warranty and guarantee information to record entitlement to manufacturer warranties
- Workmanship guarantees on work done by us or our contracted partners
- Government required guarantees such as 25-Year term CIGA / SWIGA Insurance Backed Guarantees
- Installation Certificates to include installing, commissioning and Servicing for example
- Renewable Technology (Solar PV, Air & Ground Source Pumps)
- Records of any Legal and or statutory notices we may have issued or supplied to include Gas Safe Certificates, Warning Notices, At Risk, Not to Current Standard labelling
- Any information which we consider the may be required by the Health and Safety Executive to support any investigation or records of work at a property
- Installation records of equipment which could be the subject of a Health and Safety notice, product recall or modification for example to a Gas Boiler or associated heating equipment
- Industry Body Documentation and installation records to include Gas Safe and OFTEC
- Audit Bodies such as Accreditation bodies for PAS:2030
- Government Bodies such as those government bodies or appointed agencies such as Gem Serv where Green Deal is involved in our capacity as to any Provider, Assessor or Installer Organisation
- Records of Advice given to include Energy Performance Certificates (EPC’s) which remain legally valid for 10 years after generation and may influence decisions to install or buy certain equipment
- Occupancy Assessments and Green Deal Advice Reports
- Any data we consider may be required by any Government Body such as OFGEM who retain the right of Audit on schemes they administer on behalf of the government for at least six years after installation
- Utilities such as those we provide services to in order to enable them to discharge their Energy Company Obligation
- Domestic customers and their heirs and successors in title who may ask for copy of records of Gas work done at a property to enable property sales
- Waste and Environmental records and evidences which may be required by the Environmental Agency relating to our Waste Carrier Licence and Disposal records
In the event that we sell or buy any business or assets, we may disclose personal information held by us to the prospective seller or buyer of such business or assets. If we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets.
Your personal information may also be used by us, our employees or agents if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce any agreement we have with or otherwise concerning you, or to protect our rights, property or safety or those of our customers, employees or other third parties.
With whom do we share your personal information?
We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share information in accordance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
We share the information we collect with third parties such as:
- The Financial Conduct Authority (FCA);
- Green Deal Oversight and Registration Body;
- A finance lender (where applying for a finance option where we act as a credit broker);
- Green Deal Finance Company (GDFC) (where we act as a lender for a green deal finance plan);
- An insurance provider where we act as an insurance intermediary;
- Green Deal Assessors;
- Green Deal Installers;
- Other Green Deal Providers;
- Appointed Representatives and Introducer Appointed Representatives where we act as their Principal;
- Credit reference agencies (who may check the information against other databases, public or private to which they have access), or fraud prevention agencies. This information may come from your interactions with us or them through applying for a Green Deal Plan or other consumer finance product; or ascertain from the way in which the loan is administered and managed, for example, information relating to the payments which are made to your account with your energy supplier.
- Debt Collection Agencies;
- Fraud Prevention Agencies;
- Other people and businesses who help us provide our websites, mobile apps, Wi FI networks and related services to you, for example, information technology companies who design and host our website, payment services companies who enable you to use credit or payment cards with us, and data insight specialists;
- any new business partners we may have over time, for example if we enter into a joint venture, re-organisation, business merger or sale of part of our business, the other party may receive some or all of your information;
- our professional advisors for example our lawyers, compliance officers, insurers and insurance brokers when they need it to provide advice or help us obtain insurance;
- other people who make a subject access request to us, where we are allowed to do so by law.
- Third parties involved in the handling of a complaint.
In connection with the above purposes, your personal information may be transferred to, or otherwise processed by third party service providers acting on our behalf, our agents and law enforcement authorities (including the police).
Access to Information
The UK GDPR gives you the right to access information held about you. You have the right to ask for a copy of the personal information held about you. You also have the right to ask for inaccuracies in information to be corrected. Any access request is not subject to a fee unless the requests are unreasonable in which case a fee may be charged and will be disclosed at the time of request. A copy of the information held about you by us can be requested by writing to us at the address shown.
Transfer of Information Abroad
Because of the uncertainties surrounding UK membership of the EU, we may transfer your personal information outside the EU. However, we will not transfer your personal information to any countries that are not current or former members of the European Union (EU), the European Economic Area (EEA) or the European Free Trade Association (EFTA) without first obtaining your consent.
Change of Policy
Dealing with Data Protection Complaints
We aim to comply fully with our obligations under the Data Protection Act (DPA) 2018 and the UK GDPR. If a customer has any questions or concerns regarding our company’s management of personal data including their right to access data about themselves, then they should contact the director who is responsible for ensuring our company is compliant with data protection.
If our company holds inaccurate information, then the customer should write to our firm at the address shown providing the director with any evidence to show what the information should say keeping copies of the correspondence. If after a reasonable amount of time (28 days is recommended) the information has not been corrected, then the customer can make a complaint.
There are two courses of action:
- Contact the Director to process the complaint by writing to us at our Registered Office address:
Data Protection Director, PHS Home Solutions Limited, Venter Building, 3 Mandarin Road, Rainton Bridge Business Park, Houghton Le Spring. County Durham. DH4 5RA
- If, following investigation and reply, any customer is still dissatisfied, they can go directly to the Information Commissioner, the independent body that oversees data protection and the UK GDPR. They can be contacted on 0303 123 1113 or their website is www.ico.org.uk.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.