Welcome to the South Staffordshire Water Plc privacy notice
Issue date 26 June 2018, version 2.0
Who we are
We provide our customers with clean water services. To our customers in the West Midlands, South Staffordshire and South Derbyshire we are known as South Staffs Water and to our customers in the Cambridge region we are known as Cambridge Water.We are part of the South Staffordshire Plc group of companies (“Group”). You can find details about the other companies in our Group here.
Any reference in this privacy notice to “we”, “us” or “our” is a reference to South Staffordshire Water Plc.
About this privacy notice
Please take some time to read this privacy notice which applies to the personal data we collect about you. It explains how we collect and process your personal data and tells you about the rights you have.
If we change our privacy notice we will post an up to date version on our website and let you know about any important changes.
Personal data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity of an individual has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together and have provided examples as follows:
- Identity Information: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, national insurance number, video images (including CCTV footage);
- Contact Information: includes billing address, home address, email address and mobile and landline telephone numbers, landlord contacts details (if applicable);
- Financial Information: includes bank account and payment card details (payment card details are not recorded once the payment has been completed);your credit history which we obtain from Credit Reference Agencies, fraud checks and CCJs;
- Account Information: includes details about your billing and payment history, other details of services we provide to you, the way you manage your account with us, income, and expenditure details, benefit information, complaints, job details, household details, property type, operational investigations, repairs, interruptions to supply, planned maintenance, meter details, claims, incident details, tariff details;
- Technical Information: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); and any phone number used to call our customer service number;
- Profile Information: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses and responses to competitions you may enter;
- Usage Information: includes information about how you use our website, products and services, information about your water consumption and usage which we collect from our meters, current and historical water data usage;
- Marketing and Communications Information: includes your preferences in receiving marketing from us and our third parties and your communication preferences; and
- Vulnerability Information: includes information about you or a member of your household’s physical or mental health conditions, or disabilities where you have applied for specific tariffs or schemes such as WaterSure and our Assure Tariff, or to register you as a vulnerable customer on our Priority Services Register.
Where we collect information about health or disabilities we will always obtain your explicit consent to collect, record and share your information with others, unless processing is necessary to protect your vital interest, someone else’s vital interest or for another lawful reason.If we need to process data about children (under 16 years of age) we will seek consent from a parent or a legal guardian.
How we collect your personal data We collect personal data in a number of different ways and from a variety of sources.
We will collect information directly from you when you:
- contact us through our website, by telephone, post or email or fill in forms we provide to you and when we visit your home or premises;
- register with us and set up an account to receive our services;
- use our services or communicate with us about our services;
- sign up to participate in our Watersmart programme or use our voice activated application Alexa Skill or mobile applications or our social media platforms such as Twitter and Facebook; and enter a competition, promotion or survey.
We may also receive or collect information about you from third parties such as:
- other members of your family or persons authorised to act on your behalf;
- landlords (including Landlord Tap) where you are a tenant;
- social services and medical professionals in relation to customers who are registered on our Priority Services Register or apply to receive our social tariffs;
- housing associations and local authorities who assist us in providing our social tariffs and provide us with information to help us to keep your account details accurate and up to date;
- other utilities such as Anglian Water Limited and Severn Trent Services Limited who provide sewerage and waste services to you;
- our business partners, subcontractors and suppliers for the delivery of services, provision of operational services such as fixing leaks;
- service partners who provide or help us to provide you with water efficient products and services, such as Homeserve Membership Limited and Watersmart Limited;
- if someone makes a complaint about a water leak or notifies us that a property is empty;
- from other members of our Group who assist us in managing your account and providing services to you;
- from benefits agencies to assist us in assessing applications for social tariffs, our Watersure scheme, debt management and recovery;
- the Consumer Council for Water, Ofwat and WATRS where we are dealing with complaints or queries raised with them;
- priority services information provided by other utility companies (consent required for this);
- photographs and images from our CCTV cameras on our sites or where our employees or supplier’s employees use body cameras or dash cams to record their work and for their safety and security and for the prevention and detection of crime;
- law enforcement agencies, Police, Department for Work and Pensions, HM Revenue & Customs, fraud prevention and credit reference agencies; and
- third party data and insight providers who provide us with relevant information about you, which we use to ensure that your personal data is accurate and up to date, to help us operate our business and deliver services to you.
- the electoral roll;
- Companies House;
- Register of county court judgements;
- Register of bankruptcies; and
- Land Registry.
We collect, use, store and transfer your personal data for a number of different purposes and the law requires us to have a lawful basis for processing your personal data. Primarily as a water business we have a legal obligation to supply water, maintain our networks, maintain water quality and charge for our services. We are required to keep reliable and accurate records of all of our communications with our customers. Our activities are also in the public interest and sometimes we process personal data where it is in our legitimate interest. The table below sets out the lawful basis that we use.
Lawful basis for processing
|Purpose of processing||Lawful basis|
|Providing water services to you and managing your account|
|Supplying you with water||Legal obligation and public interest|
|Managing your supply and the provision of water services and products to you||Legal obligation and public interest|
|Charging you, collecting monies and debt collection||Legal obligation and public interest|
|Dealing with service and billing enquiries||Legal obligation and public interest|
|To manage and administer your account||Legal obligation and public interest|
|To make Guaranteed Service Standards payments||Legal obligation and public interest|
|To deal with complaints||Legal obligation and public interest|
|Metering and billing||Legal obligation and public interest|
|To provide you with service communications (including by SMS) for example about leaks in your supply area, interruptions to water supplies||Legal obligation and public interest|
|Keeping our records accurate and up-to-date||Legal obligation and public interest|
|Carrying out fraud and fraud prevention||Legal obligation|
|Data for children under the age of 16 which we may be required to collect for the purpose of any special tariffs or services to vulnerable customers||Consent|
|To make arrangements on your behalf with approved third party contractors to provide quotations for repairs to leaks on your premises||Consent|
|Dealing with risks to your household due to water quality and supply issues||Vital interest|
|Legal and Regulatory Compliance|
|To meet our obligations under the Water Industry Act 1991, Water Industry Act 1999, Water Industry Act 2014, Water Supply (Water Quality) Regulations 2016, Water Resources Act 1991, Environment Act 1995 and our Statutory Instrument of Appointment and licence conditions.||Legal obligation|
|Complying with our general regulatory and statutory obligations (including our responsibilities under data protection laws)||Legal obligation|
|Providing personal data to Ofwat or their appointed suppliers for the purpose of carrying our customer surveys||Legal obligation|
|Managing our water supply network and resources||Legal obligation|
|Promoting water efficiency||Legal obligation|
|Service communications (water supply issues, road closures etc.) metering, to comply with the law||Legal obligation and public interest|
|Complying with instructions, orders and requests from law enforcement agencies, any court or otherwise as required by law||Legal obligation|
|For a non-household customer (businesses, charities or public sector) to provide information with your retailer and with Market Operator Services Limited ("MOSL") who operate the Central Marketing Systems for the non-household retail market as part of OpenWater||Legal obligation|
|Fraud and detection of criminal activity||Legal obligation and public interest|
|General Business Activities|
|To carry out staff training and quality assurance||Legitimate interest:
We have a legitimate interest in ensuring that our staff are trained and to check and improve the quality of our services.
|Managing litigation and compensation claims. Making and defending claims||Legitimate interest:
We have a legitimate interest in establishing and defending our legal rights.
|Administering and improving our website||Legitimate interest:
We have a legitimate interest in collecting information to allow us to administer and improve our website for the benefit of our customers.
|Managing our business||Legitimate interest:
We have a legitimate interest in effectively managing our organisation to the benefit of all of our stakeholders.
|Sharing information with organisations which promote or help us to promote water efficiency services and products, such as Homeserve Limited and Watersmart Limited||Legitimate interest:
We have a legitimate interest in promoting products and services which can improve customers water efficiency, reduce leakage and waste water and assist us in meeting our legal obligations.
|Improving and broadening our range of services and product||Legitimate interest:
We have a legitimate interest in improving and broadening our range of services and products that we offer.
|Carrying out surveys, market research, gathering feedback and promoting competition||Legitimate interest:
It is in our legitimate interest to obtain feedback from our customers about the services and products that we provide so that we can improve and expand the products and services that we offer and to offer our customers competitions to encourage them to provide feedback or use of our services and products.
|Analysing trends and profiling activities||Legitimate interest:
We have a legitimate interest to analyse trends in relation to water consumption and use profiling to tailor goods and services for our customers.
|Arrangements with developers and self-lay organisations to supply mains, pipework and meter||Legal obligation and contract|
|The provision of recreational facilities||Contract|
|To send you direct marketing for products and services where you have given consent (unless we rely on our legitimate interest)||Consent|
|Managing the proposed sale, restructuring, transfer or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation||Legal obligation and legitimate interest:
We have a legitimate interest in being able to sell any part of our business.
|Maintaining the security and integrity of our systems, platforms, premises and communications (and detecting and preventing actual or potential threats to the same)||Legitimate interest:
We have a legitimate interest to make sure that our business is secure and protected.
Lawful basis for processing special categories of data
|Purpose of processing special categories of personal data||Lawful basis|
|Collecting medical, mental & physical health data to assess whether special tariffs can be provided or additional services are required and sharing this information with third parties as necessary (particularly in the case of an emergency).||Explicit consent and it is necessary to protect someone’s vital interest or they are incapable of giving consent vital interest|
|Obtaining legal advice, establishing, defending and enforcing our legal rights and obligations in connection with, any legal proceedings (including prospective legal proceedings)||It is necessary for the establishment, exercise or defence of a legal claim|
Information we share with othersWe may need to share your personal data with other third parties as follows:
|Category||Types of third parties|
|Our Group & Employees||We share your personal data with our employees and other companies within our Group, so that we can manage your account and provide you with services.|
We have legal and regulatory obligations to share personal data with our regulators, such as, Ofwat, Department for Environment, Food and Rural Affairs, Drinking Water Inspectorate, the Consumer Council for Water, Water Redress Scheme and the Environment Agency.All of our customers may have their contact information shared with Ofwat and third parties working on their behalf for the purpose of the following customer surveys: Service Incentive Mechanism (SIM), Customer Measure of Experience (C-Mex) and Developer Services measure of Experience – for developers only (D-Mex). You may be contacted by third parties on Ofwat’s behalf about the service you receive from us. This is not a direct marketing call and we have a statutory obligation to share your personal data.
|Law Enforcement Agencies||
Sometimes we are contacted by HM Revenue & Customs, the Department for Work and Pensions, the police, local authorities and fraud agencies. Under data protection laws we are permitted to share personal data with them without your consent and you will not be notified that this has been done. This is in support of the prevention and detection of crime.We may also share information where we are required to do so to under a legal obligation such as a court order or under statute.
|MOSL & Retailers||
If you are a non-household customer (businesses, charities or public sector) we will share information with your retailer and with Market Operator Services Limited (“MOSL”) who operate the Central Marketing Systems for the non-household retail market as part of OpenWater. We have a legal obligation to share this information.Pennon Water Services Limited (“PWSL”) is a joint venture between South Staffordshire Plc and Pennon Group Limited and operates as a retailer. We share information with PWSL in the same way as any other retailer.
|Water & sewerage companies||Customers in our supply area receive sewerage services from Severn Trent Water Limited or Anglian Water Limited. We share personal data with these companies for billing purposes and to manage sewerage services. We also provide both companies with billing services and act as data processors on their behalf.|
|Credit Reference Agencies||
We may share your personal data with and receive personal data from Credit Reference Agencies (“CRAs”).
We will share your Identity, Contact, Financial and Transactional Information with CRA’s and they will share this data with us. We will also share details of your settled accounts and any debts not fully repaid on time.
We will use this personal data to assess your account, decide what payment terms are appropriate, make sure the information we hold about you is up to date and accurate, verify your identity, manage your account with us, trace and recover debts and to help detect and prevent criminal activity and fraud.
When CRA’s receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. They provide us with public and shared credit and fraud information
If you owe us money and do not repay in accordance with our terms we will notify our credit reference agency. This could result in your credit rating being negatively impacted.Further information about the CRAs and the way in which they process and share personal data can be found in the Credit Reference Agency Information Notice here.
The main CRA’s that we use are listed below together with links to their privacy notices:https://www.callcredit.co.uk/legal-information/privacy-centre
We use carefully selected third parties to help us process your personal data and provide services to you. When we work with third parties we ask them to provide us with assurances that they comply with data protection laws. We work with the following categories of service partners:
Other third parties
We may also share your personal data with:
We have a legal duty to promote water efficiency and use a number of methods to do this, including direct marketing. This may include products and services that we provide or that are provided by a third party such as Homeserve Membership Limited and Watersmart Limited. We rely on our legitimate interests to do this.
From time to time we may also tell you about products, services or offers that we think may interest you which we provide or that are provided by carefully selected third parties. In some circumstances we may need to ask for your consent to share your personal data for the purpose of these offers.
If at any time you wish to stop receiving marketing from us please contact us using any of the methods described in our Contact Us section below.
Please note you may still receive non-personalised marketing material. You will also receive information which we are required to provide you with by our regulator Ofwat which will be included with your bill.
We will never sell your personal data to marketing companies.
Automated Decision Making and Profiling
We do not carry out any automated decision making.
We carry out limited profiling activities in relation to for example: water consumption, demographic data and ability to pay. This helps us to provide you with information that may assist you for example: whether you would benefit from a water meter.
CCTV and mobile recording devices
Our sites (including car parks) may be monitored by CCTV and your image and car registration may be recorded for security purposes if you visit any of our sites. Images are retained for 30 days and then deleted.
Our employees and our service provider’s employees may be equipped with and operate “body cameras” and “dash cams” may be located in their vehicles, so that work can be recorded for the security and safety of those employees and for the prevention and detection of crime.
Use of our company drones
We operate drones fitted with cameras that can be switched on remotely to record images of our sites and assets for inspection, mapping, managing our network and infrastructure.
We retain the images for no longer than is required for the purpose for which the images are being recorded but may keep inspection images indefinitely.
The drones are operated by a licensed and qualified drone pilot. When a drone is used it is always kept within the pilot’s visual line of sight. Drones are operated land owned by us or our Group or where we have the express permission of the landowner or relevant local authority and not within 50 meters of a member of the public.If you have any concerns relating to privacy and the use of our drones please contact us using any of the methods described in the Contact Us section below.
We, our Group and the service provider managing our customer contact centre may monitor and record calls for quality, security and training purposes.
How we look after your personal information
When we collect information about you we ensure that we minimise what we collect, but we also try to collect enough accurate and up to date personal information to ensure that you can receive our products and services.
We take appropriate care to secure the information we hold about you. We have implemented appropriate organisational and technical security measures to protect your information, such as passwords and information encryption. We also have policies and procedures in place to ensure that there is no unauthorised access to your personal data.
We take seriously our obligations towards your privacy and the protection of information we may hold about you. Whenever we share your personal information we work to ensure it is protected from misuse or loss.
Our website contains links to other third party websites. If you follow a link to any of the websites provided by a third party, we will not be responsible for the content and privacy practices of that third party and we accept no liability for those third party websites. Please note that your use of a third party website will be subject to the terms and conditions and privacy notices of that third party.
Where your personal data may be processed
Sometimes we will need to share your personal data with third party data processors in countries that are outside of the European Economic Area, for example: one of our Group Company’s is based in India.We put adequate safeguards in place to ensure that your data receives the same level of protection as if it were being processed inside the EEA.
How long we keep your information for
We will retain your information for as long as we need it depending on the purpose for which your personal data has been processed.
Generally we will keep your information for as long as you are a customer and for a period of 6 years after your account has been closed. Your personal information will then either be deleted or anonymised.
In certain circumstances, we may be required to retain your personal information for longer where such retention is required by law or record keeping requirements, including managing our relationship with you, defending any claims, or for tax purposes.Your Rights
Depending on the circumstances, you may have the right to:
- access your personal data and to be provided with certain information in relation to it. This is known as a data subject access request (“SAR”) and we have a standard form which you can compete to make it easier for you to make a SAR request;
- require us to correct any inaccuracies in your personal data without undue delay;
- require us to erase your personal data;
- require us to restrict processing of your personal data;
- receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us and where the processing is automated; and
- object to a decision that we make which is based solely on automated processing of your personal data.
Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.
Where our processing of your personal data is based on legitimate interests you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.
In most cases we will respond to within 1 month of your request and you will not be required to pay a fee. However, there may be circumstances where we are unable to complete your request to exercise your rights within 1 month or at all or you may be required to pay a fee. If this is the case we will inform you of the reasons and provide details of how you can register a complaint with the Information Commissioners Officer.To exercise any of your rights or request a SAR form please contact us using any of the methods referred to in the in our Contact Us section below.
We have appointed a Data Protection Officer (“DPO”) who you can contact if you would like any information about our privacy notice or you would like to exercise any of your rights.
You can contact us by:
Emailing us at: GDPRenquiries@south-staffs-water.co.uk
Call us on: 0345 60 70 456 and ask for the Data Protection Officer.
You can also contact the Information Commissioners Office at www.ico.org.uk, or by writing to them at Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF or by phone on 0303 123 1113 to make a complaint or for further information or advice.We take our responsibilities in relation to personal data very seriously, so if you have any complaints or concerns about how we are processing your personal data we would appreciate the opportunity to address your concerns in the first instance.
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You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Cookie description||Purpose||Name||Expiry date|
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