Privacy Policy

 

Introduction

HTA Design LLP (“HTA”) is committed to protecting the personal information of our clients - current and future, visitors to our studios and website, suppliers and contractors.

HTA is a data controller which is registered at the Information Commissioners Office with number Z3660300 and we are subject to the General Data Protection Regulation which applies across the European Union including the United Kingdom and any legislation enacted in the United Kingdom to give effect to it.

This privacy notice provides information about the personal information that HTA collects about all external and third parties such as visitors to our studio and website, clients –current and future, suppliers and contractors, and the ways in which our practice uses that personal information.

Any questions regarding this privacy notice and HTA’s data protection practices should be sent by email to our Commercial Director, Rajiv Ranjan via email to: Rajiv.Ranjan@hta.co.uk

 

How does HTA collect information from you data?

 Our website

You can visit our website without providing any personal information, however we may automatically collect IP addresses, information about your visit and how you use our website.

You may provide us with information by corresponding with us by phone, email, or otherwise as indicated on the website

 

Visiting our Studios

  • Meetings: When you visit our London studio, you will be asked to provide your name and the company you work for by the ground floor reception team, which is part of building management for the entire building. This information is held for safety reasons so we know who is in the building at any one time. Other HTA studios are smaller and their own manual processes may apply where a concierge service is not available. Visitor records are generally deleted at the end of each working day and never kept longer than a week. 
  • Events: If you are visiting for an event which is being held in our studios or hosted by us in an external location, you will be asked for your name and the company you work for.  You may also be provided with a name badge, if appropriate for the event.

There is a high chance that there will be photographers at the event and if that is the case you will have been informed beforehand and your consent sought for your photograph to be taken.

If this is the case, photography may be used on our social media sites and publications.  If you do not wish to have your photograph taken, please make this clear in advance of the event, in writing to Rachel Hardman, Practice & Marketing Manager via email at: Rachel.Hardman@hta.co.uk

 

Information from third parties

While we collect most of the information we hold directly from you we will sometimes obtain information from third parties such as references (with your consent) or publicly available information such as information contained on Companies House or websites such as LinkedIn. We may obtain credit reference checks if relevant.

 

What type of information is collected from you?

The personal information you provide may include your name, job title, company address, e-mail address, phone numbers, professional social media profile links (e.g. LinkedIn), company website and other information about yourself to enable us to provide you with our services.

 

How is your information used?

When we collect personal information from our clients and other members of the public, it will be used for the following purposes:

  • to maintain responsible commercial relations with you;
  • to understand your service and/or project needs;
  • to manage and develop our business and operations;
  • to meet legal and regulatory requirements;
  • to notify you of changes to our services;
  • to process a job application if appropriate;
  • to recommend your product or service to relevant contacts within the industry.

We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity.

When you voluntarily give us your personal information we will only use it for the above purposes. If we intend to use your personal information for a purpose other than those above, we will seek your express consent.

 

What is the legal basis on which we process your data?

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The below explains what we use (process) your personal information for and our reasons for doing so:




What we use your personal information for

Our reasons

  • To provide services to you.
  • For the performance of our contract with you or to take steps at your request before entering into a contract.
  • To prevent and detect fraud against you or us.
  • For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you.
  • Conducting checks to identify our customers and verify their identity.
  • Screening for financial and other sanctions or embargoes.
  • Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator.
  • To comply with our legal and regulatory obligations.
  • Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.
  • To comply with our legal and regulatory obligations.
  • Ensuring business policies are adhered to, e.g. policies covering security and internet use.
  • For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.
  • Operational reasons, such as improving efficiency, training and quality control.
  • For our legitimate interests or those of a third party, i.e. to be as efficient as we can.
  • Ensuring the confidentiality of commercially sensitive information.
  • For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information.
  • To comply with our legal and regulatory obligations.
  • Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.
  • For our legitimate interests or those of a third party, i.e. to be as efficient as we can.
  • Preventing unauthorised access and modifications to systems.
  • For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you.
  • To comply with our legal and regulatory obligations.

The above does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by contacting Rachel Hardman, Practice & Marketing Manager at: Rachel.Hardman@hta.co.uk

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

Who will your data be shared with

We may share personal information with:

  • third parties we use to help deliver our services to you, e.g. consultants, solicitors, payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • our insurers and brokers;
  • our banks.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

 

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this privacy notice. Different retention periods apply for different types of personal information. Further details on this are available from our Data Protection Lead.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

 

Your rights

You have the following rights, which you can exercise free of charge:

Access -  The right to be provided with a copy of your personal information (the right of access).
Rectification -  The right to require us to correct any mistakes in your personal information.
To be forgotten -  The right to require us to delete your personal information—in certain situations.
Restriction of processing -  The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability -  The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object - The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making -  The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
 
 
For further information on each of the above rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

You can exercise any of your rights by contacting our Data Protection Lead via email at: Charles.Carmichael@hta.co.uk

Our website may at times contain links to other websites that may offer useful information to our clients and visitors. Please note, that if you follow the link to any of these websites this privacy statement does not apply and we do not accept responsibility or liability for their policies.

You also have the right to see and correct data that we hold about you. If your details change or any other information we hold is inaccurate or out of date, please let your direct contact at HTA know or email our Data Protection Lead via email at: Charles.Carmichael@hta.co.uk

 

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • with your and our service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission or otherwise to rely on an approved certification mechanism under GDPR.

If you would like further information please contact us.

 

Security

HTA will take reasonable technical and organisational precautions to ensure that your personal information it’s treated securely.  We will store all personal information you provide on our secure servers.

We restrict access to only those who need access to your data so they can discharge their duties.

In addition, we have deployed a number of systems to ensure your data remains safe, these include:

  • An incident detection, response and user behaviour analytic system running looking for unusual data access or user behaviour.
  • Carry out vulnerability testing on all desktops to ensure that no known issues exist that would allow applications to be hijacked.
  • A program of regular patch management, this ensures desktops and servers stay up to date with latest security patches.
  • Carrying out regular phishing testing, to ensure users are aware of the dangers of phishing emails, part of this testing includes training.
  • We use firewalls to protect our networks, to stop our data being breached.
  • All desktops run antivirus and anti-ransomware software.
  • We conduct regular backups.

Wifi

We provide access to the internet while you are in the studio, it is securely configured to separate our corporate data from internet browsing. As a guest you will be asked to logon to a secure portal that will grant you access to browse the internet only. We do not store any information about your connection or the sites you visit.


16 or under

We do not collect any personally identifiable information from children aged 16 or under without prior verifiable consent from his parent/guardian.

 

Data breaches and reporting

If it becomes apparent that a potential data breach has occurred, the Company will endeavour to report this to the ICO within 72 hours of becoming aware of the data breach.  This will be the case if the data breach is likely to result in damage to a person’s reputation, financial loss, loss of confidentiality, or major financial or social disadvantage.  If the breach is likely to result in a high risk to the rights and freedoms of the data subject the Company will also contact the data subject without undue delay.

Data breaches will be reported to the Information Commissioner Office (ICO) by calling the dedicated personal data breach helpline on 0303 123 1113.


How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.


Changes to this privacy policy

This privacy notice was published and last updated on 23rd May 2018.

We may change this privacy notice from time to time - when we do we will inform you via our website or other means of contact such as email.

How to contact us

Please contact us or our Data Protection Lead by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

 

HTA Design LLP

78 Chamber Street

London, E1 8BL

info@hta.co.uk

020 7485 8555 

 

Our Data Protection Lead's contact details:

Rajiv Ranjan, Commercial Director

Rajiv.Ranjan@hta.co.uk

 

Charles Carmichael, Data Systems Coordinator

Charles.Carmichael@hta.co.uk