(each referred to as the "Website" and together the "Websites").
In this Policy, references to "we", "us", and "our" (and other similar terms) means WPD and "you" and "your" (and other similar terms) mean our customers, contacts, suppliers and Website visitors.
For the purpose of the EU General Data Protection Regulation, each WPD company is a data controller and the registered office is at Avonbank, Feeder Road, Bristol BS2 0TB.
This Policy is an important document because it explains the way that we use the Personal Information we collect from you when you interact with us including but not limited to on our Websites, what our legal basis is for processing that Personal Information, and to set out what rights you have in relation to your Personal Information.
This Policy is comprised of the following Sections:
Section 1: Personal Information that we collect about you and the purposes for which we use it
Section 2: Legal basis for use of your Personal Information
Section 3: We share your Personal Information with third parties in certain circumstances
Section 4: Retention of Personal Information
Section 5: Security of your Personal Information
Section 6: Transfer of Personal Information outside the European Economic Area
Section 7: Cookies
Section 8: Your rights
Section 9: Changes to this Policy
Section 10: Contact us
1. Personal Information that we collect about you and the purposes for which we use it
We collect Personal Information about you whenever we are in contact with you and if we are working together. This includes collecting and processing the following information:
- Personal Information that you provide by filling in forms on our Websites or paper forms. This includes feedback and comments on our performance and complaints and information that you provide when completing the registration form.
- If you contact us by phone, email or post, we may keep a record of that correspondence.
- We may be required by the Energy Regulator Ofgem to pass your details to an independent survey company who may ask you to complete voluntary surveys. We may also contact you to request your contribution to our own surveys which we commission from time to time, for regulatory purposes.
More specifically we collect, store and use your Personal Information for the following purposes to maintain, improve and develop our network.
As a distribution network operator we have an obligation to develop and maintain an efficient, co-ordinated and economical system of electricity distribution. We use your Personal Information to provide our services in accordance with this obligation, in circumstances such as those described below.
(a) If you contact us because your power is out:
We will collect your contact details for the purpose of contacting and corresponding with you. We will also collect your address (including postcode) so that we can investigate and resolve the problem.
(b) If you contact us to make a new connection or change or disconnect an existing connection:
We will collect your (and/or, if you are an agent contacting us on behalf of another person, that person's) name, address, phone number, details about your property, your Meter Point Administration Number ("MPAN") (the reference number used in Great Britain to uniquely identify your electricity supply point), information relating to your electricity meter, access arrangements and other site specific details in relation to the connection. We will use this information for carrying out the works and for monitoring the progress of your connection. We may also allow you or relevant third parties (such as Independent Connections Provider appointed by you) the option of monitoring the progress of your connection directly, for example, via a data sharing portal or monitoring portal service provided by us or on our behalf.
(c) To manage an existing connection to our distribution network:
In order to administer the connection agreement between us and manage our network generally in accordance with our licence conditions, we will collect your name, address, phone number, details about the property that is subject to the connection, Personal Information relating to your MPAN, information relating to your electricity meter (including the type of meter you have, for example, whether it is a smart meter) and information relating to your electricity consumption or generation.
For example, we may need to use electricity consumption data from smart meters in a specific area to assess whether a particular transformer needs to be upgraded, or to provide us with the information we need to balance network demand. We do not use this data to build a profile of your day-to-day electricity consumption in order to sell or advertise products to you. Our use of electricity consumption data is regulated by Ofgem.
For more information about how WPD use data about your electricity consumption derived from smart meters click here.
(d) If you contact us in an emergency or with a general enquiry:
We will collect your name, email address, phone number, the best time to reach you, the urgency of your enquiry, your preferred way of being contacted and the nature of your query so we can respond to your query in the most efficient way.
If you contact us using the Webchat function on our Websites or via social media such as Facebook or Twitter, we will use the Personal Information you provide to us for the purposes of investigating and dealing with your query.
(e) If you are a landowner:
We will collect details of your property; your name; any easements or consents over your property; how long you have owned it; and details of next of kin, for the purposes of obtaining access to, or placing equipment on, your property.
(f) If you are included in our Priority Services Register:
We will collect your name, address and contact details, details about other utility service providers which provide services to you (for example, gas and water), and your reasons for being included in the Priority Services Register, including information about your health or medical conditions.
We may contact you via letter, phone, email text or post to make sure your details are accurate and up to date for the purposes of ensuring we can, at all times, give you the best support for your needs.
If anything about your situation changes you can tell us and we will update your details.
We will only include your name in our Priority Services Register if you have given us your consent. You can withdraw your consent at any time and ask to be removed by contacting us using the contact details below.
(g) If you are taking part in one of our network innovation projects:
As part of the network innovation project, we may collect and process your name, address, email address and contact telephone number.
We use the information held about you to contact you to administer the project in question and to respond to queries you may have, tell you about any changes to the project, or ask you for feedback on the process.
The information collected about you as part of project in question will only be accessible by WPD staff members, group companies, consultants, advisors or subcontractors who need it in order to carry out the project you have signed up to. WPD staff in other day-to-day roles will not have access to this information.
Information shared with partner organisations, such as universities and third parties who may be carrying out analysis on or an assessment of the project, will not identify any individual customer and will not contain customer names and addresses.
(h) If you are, or are employed or engaged by, a supplier (or prospective supplier) of goods or services to WPD or an Independent Connections Provider ("ICP") carrying out works on WPD's network:
We will collect, store and use your personal and/or professional contact details, as well as contact details for any organisation that you represent, for the purposes of corresponding with you and administering the contract in place between WPD and you (or the organisation you represent).
We collect your Personal Information through materials you may provide to us in relation to the supplies you make to us, as well as your bank account and/or other payment details for the purpose of paying your fees.
We may also collect information in relation to any licence or professional qualifications you hold or register upon which you are named, to be satisfied that you or the organisation who employs you are suitably qualified to provide the goods or services to us or to carry out works on our network.
(i) If you agree to take part in a focus group:
We may contact you to ask if you would like to take part in focus groups. If you agree we will use the information you provide to gather views on a specific issue. If you agree we will also contact you with updates that relate to the focus group issue.
We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications. You can specify your contact preferences using the contact details provided below.
(j) If you use our consortium facility:
As part of providing the consortium facility we collect, store and process your listed contact name, telephone number, address, email address, as well as other details which are not Personal Information such as company name, connection site reference and connection site name. We will also collect any other information you provide on the consortium facility registration form.
(k) If you damage our property:
If you damage our property, including our cables, we will collect your name, address, MPAN, and your bank account details from you to invoice you for the damage to our property and to recover any money that you owe us for the repair of such property. We also collect details about maintenance or repair work and record of how the cable was damaged from either you or a third party.
(l) If you are a landlord or tenant:
If you are a landlord of a property we lease or a tenant in a property we own, we will collect your Personal Information such as your name, address, telephone number, email and bank account details as part of our landlord and tenant agreement with you (or in connection with other types of agreement we may have with you in relation to your property) in order to meet our obligations and to exercise our rights under that agreement.
(m) We use your Personal Information to send you important service communications:
We will collect and use your Personal Information to communicate important service messages to you, for example, we may contact you by phone, email or text when there are power outages. We will also use your postcode in order to send you important information about our services, for example, our PowerForLife newsletter which contains details of any planned interruptions.
We also collect Personal Information from vehicle dashcams and CCTV monitoring for the security of our company facilities and protection of company property and vehicles.
2. Legal basis for use of your Personal Information
a) our use of your Personal Information is pursuant to your granting to us consent to do so (for example, in relation to your registration on our Priority Service Register);
c) our use of your Personal Information is necessary for complying with our legal obligations (for example, providing information to Ofgem);
d) our use of your Personal Information is necessary for carrying out a task in the public interest;
e) where (a) - (d) do not apply, our use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others. For example, our legitimate interests include the following:
i) running, growing and developing our business;
ii) operating and ensuring the security of our Websites;
iii) ensuring a safe working environment for our staff and visitors;
iv) marketing, market research and business development;
v) providing services to our customers;
vi) placing, tracking and ensuring fulfilment of orders with our suppliers; and
vii) for internal group administrative purposes.
3. We share your Personal Information with third parties in certain circumstances
We share your Personal Information with third parties in the following circumstances:
(a) We use consultants, suppliers and contractors to help us provide services and we give them Personal Information but only to the extent they need it to carry out their specific tasks. We have contracts in place with them containing obligations regarding the use and security of Personal Information to ensure that it is protected as much as possible.
(b) If you are on our Priority Services Register, we may share your Personal Information, such as your name, address and details of your situation. We will only share your Personal Information with third parties where it is necessary for your welfare, including your safety in an emergency, and to to ensure you receive the relevant support and advice in the maintenance of your electricity supply. Third parties with whom we may share this information are:
Citizens Advice Bureau;
The Red Cross and other support agencies, networks and charities;
Local authorities; and
the Energy Savings Trust.
(c) We are regulated by Ofgem. In order to comply with regulatory obligations we may pass your Personal Information to third parties such as market research companies commissioned by us to carry out research that will assist us in monitoring our own regulatory compliance. Occasionally Ofgem may request information that includes Personal Information. We take steps to ensure that any data provided to market research companies or Ofgem is provided securely.
(d) We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
(e) In the event that we sell or buy any business or assets, we may disclose your Personal Information to the prospective seller or buyer of such business or assets.
(f) If all or substantially all of our assets are acquired by a third party, your Personal Information may be one of the transferred assets.
4. Retention of Personal Information
We keep your Personal Information for no longer than necessary for the purposes for which the Personal Information is processed. The length of time we retain Personal Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
5. Security of your Personal Information
We use appropriate technical and organisational measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers. We will not pass any Personal Information collected to third parties for marketing purposes unless you have specifically agreed to this.
Unfortunately, the transmission of information via the internet is not completely secure. If you provide Personal Information to us via our Websites, we will do our best to protect it, but we cannot guarantee its security and any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access.
6. Transfer of Personal Information outside the European Economic Area
Your Personal Information may be used, stored, transferred and/or accessed by other members of our group in the United States, or staff operating outside the European Economic Area ("EEA") working for us or our suppliers. Such staff maybe engaged in, among other things, the provision of support services. If we provide any Personal Information about you to any such non-EEA members of our group or suppliers we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy.
8. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. For example , depending on the basis upon which we use your Personal Information, you may:
• Request access to your Personal Information;
• Request correction of your Personal Information;
• Request erasure of your Personal Information;
• Object to processing of your Personal Information;
• Request restriction of processing your Personal Information;
• Request transfer of your Personal Information;
• Withdraw your consent to the processing of your Personal Information if our processing is based on your consent.
If you wish to exercise any of the rights set out above, please contact us via our contact details set out below.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you of this and keep you updated.
9. Changes to the Policy
Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or post.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
10. Contact us
If you have any questions, complaints or requests relating to your Personal Information, then please contact us using the following details:
E-mail us at: firstname.lastname@example.org;
Call us on: 0800 096 3080.
We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your Personal Information.
You have the right to make a complaint at any time to the Information Commissioner Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Version date: May 2019.