This Policy is an important document because it explains the way that we use the Personal Information we collect from you, what our legal basis is for processing that Personal Information, how we may share that data with third parties and 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 how 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: How long do we keep your Personal Information for?
Section 5: Security of your Personal Information
Section 6: Transfer of Personal Information outside the European Economic Area
Section 7: Your rights
Section 8: Changes to this Policy
Section 9: Contact us
WPD is a group of companies who look after your electricity supply in different parts of the UK, including Western Power Distribution (East Midlands) Plc (company number 2366923); Western Power Distribution (West Midlands) Plc (company number 3600574); Western Power Distribution (South West) Plc (company number 2366894) and Western Power Distribution (South Wales) Plc (company number 2366985) (collectively, “WPD”).
In this Policy, references to "we", "us", and "our" (and other similar terms) means WPD and "you" and "your" (and other similar terms) mean you, being a PSR customer.
For the purpose of the data protection laws each WPD company is a data controller and the registered office is at Avonbank, Feeder Road, Bristol BS2 0TB.
1. Personal Information that we collect about you and how we use it
We collect information about you when you ask to be included on the PSR register over the phone or fill in the form to register for the PSR. Where we include you on the PSR register, we will collect Personal Information that we need to know in order to communicate with you and ensure that your needs are met in the event of a power cut. The Personal Information we will collect includes your name, address and contact details and your reasons for being included in the Priority Services Register (including information about your health or medical conditions).
We may also receive this Personal Information where you have asked another service provider, for example your energy or water supplier, or care provider, to share this information with us in order to register you on our PSR.
If there is a power cut we may contact you (for example by text message or telephone) to ensure that you are aware of the outage, and so that you can contact us if you need further assistance.
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.
If you contact us or we contact you by phone, email or post, we may keep a record of that correspondence too.
2. Legal basis for use of your Personal Information
We are a licensed electricity distributor, and where we use your Personal Information to provide our PSR services to you, we do so to comply with our license conditions. We'll only use your Personal Information as described on the registration form and the PSR pages on our website. You can of course ask to remove yourself from the register at any time.
Where you have indicated on the registration form that you would like us to share your Personal Information with other energy and utility companies (to be added to their priority services registers) this is on the basis of your consent.
We also have a great network of third parties who can help PSR customers with additional services, for example to provide support with fuel poverty support and government grants for home improvements to reduce energy bills. This is explained further below. We will only share your data with these third parties where you give us your consent to do so.
We conduct customer satisfaction surveys to ensure your needs are being met and to understand if we could improve our service. Some of these surveys are required under our licence conditions, and our legal basis in these instances is that we are complying with a legal obligation. Other surveys may be undertaken on a legitimate interests basis, but you are not obliged to take part and if you are contacted we will only continue with a survey if you are happy for us to do so.
Below we also explain how, in certain circumstances, it may be necessary for us to share your Personal Information with third parties who can provide essential support to you in the event of a power cut or emergency. We only share minimum amounts of Personal Information with such third parties, and only where it's necessary for your welfare and safeguarding. For this our legal basis for processing your Personal Information, and sharing it with third parties, is complying with a legal obligation. This is because we have a duty to ensure the safety of our PSR customers.
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) Where there is a power cut and as a result there is a concern for your welfare. We will only ever share the minimum Personal Information required for that third party to provide support, and only where there are reasons to be concerned about your safety. These third parties will contact you to provide support and advice in the event of a power cut. Third parties with whom we may share this information include the emergency services, the Red Cross and other support agencies, networks and charities and Local Authorities.
(b) As part of our support package for PSR customers we have a range of third parties who can provide energy savings advice, access to government grants and schemes (for example for home insulation) and other services that may help your reduce your energy bill. This includes the Citizen's Advice and the Energy Savings Trust. We will only share your Personal Information with these third parties where you have asked us to do so and given consent to pass on your details.
(c) Where you have consented on the registration form, we will share your details with other energy and utility companies so you can join their priority services registers. This will allow them to support you too, for example in a water supply outage your water supply company could use this information to provide bottled water and keep you informed.
(d) WPD aims to provide the best customer service possible, and in order to evaluate customer satisfaction and continuously improve our service we sometimes engage third parties to carry out customer surveys on our behalf.
(e) if you have suffered a power cut we may share your Personal Information with an external support provider so they can contact you on our behalf (usually by phone) to ensure you are safe, and to see if further improvements can be made to meet your needs.
(f) We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. 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. 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. How long do we keep your Personal Information for?
We keep your Personal Information for no longer than necessary for the purposes for which the Personal Information is processed. Typically this means the duration that you are registered on the PSR unless you ask us to remove your personal information earlier. We may retain your Personal Information for slightly longer in order to comply with applicable laws or 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 will never pass any Personal Information collected to third parties for marketing purposes.
Unfortunately, the transmission of information via the internet is not completely secure. If you provide Personal Information to us, we will do our very 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 including encryption, password protection and security features to try to prevent unauthorised access.
6. Transfer of Personal Information outside the United Kingdom
Your Personal Information will be stored in the United Kingdom. It's possible that we may need to transfer your Personal Information to staff or suppliers operating outside of the UK for support services, but if so we will always ensure that your Personal Information is treated securely, in compliance with applicable laws and according to this Policy.
7. 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.
If, with your consent, we have shared your Personal Information with third parties then you will have to contact those third parties to request access to Personal Information they hold about you, or to enforce the other rights mentioned above.
You will not have to pay a fee to access your Personal Information from WPD (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.
8. 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.
9. 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: March 2021