Privacy Notice

HomePrivacy Notice

Privacy Notice

About us 

How to contact us

Information we collect from you and what we do with it

Lawful basis for processing

What to expect when you contact us?

Visiting our website

Our customers

Moving out of our supply area

Visiting our offices

Interested parties

Use of our company drone

Information we collect or obtain from others about you

Information we share with others

Other third parties

Trusted partners we use who may have access to your data

Where we store your information and how we keep it safe

How long we will keep your information

Your data protection rights

Changes to this Privacy Notice

 

 

 

About us

SES Water ("We") are committed to protecting and respecting your privacy.

This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you or that you provide to us or that we obtain about you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Requirements* (the DPR), the data controller is Sutton and East Surrey Water plc of London Road, Redhill, Surrey, RH1 1LJ (company number 02447875). This is our legal name and SES Water is our trading name.

* Data Protection Requirements means the Data Protection Act 1998 (or The Data Protection Act 2018), the EU Data Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011, the General Data Protection Regulation (from 25 May 2018) and all other applicable laws and regulations relating to processing of personal data and privacy in any applicable jurisdiction as amended and replaced, including where applicable the guidance and codes of practice issued by the UK Information Commissioner or such other relevant data protection authority;

How to Contact us

If you want to request further information about our privacy policy or exercise any of your rights you can:

email us: Customerrelations@seswater.co.uk

write to us: Data Protection Officer, SES Water, London Road, Redhill, RH1 1LJ

You can also contact the Information Commissioner's Office via https://ico.org.uk/ or at Wycliffe House Water Lane, Wilmslow, Cheshire SK9 5AF or 0303 123 1113 for information, advice or to make a complaint.

SES Water tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

We are also happy to provide any additional information or explanations needed. Any requests should be sent to us using one of the methods above.

Information we collect from you and what we do with it

We may collect and process a variety of data about you from information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by telephone, e-mail or otherwise. This includes information you provide when you register to use our website, establish an online billing account with us, search for a product or services, enter a competition, promotion or survey and when you report a problem with our website or our services.

The information you give us will vary depending on your relationship with us but may include your name, address, e-mail address and phone number, financial and credit card information, household income, age, disability, age of children, number of children, receipt of benefits (value and which ones), medical prescriptions, as well as bank statements, driver’s licences and passports etc.  What we process in different circumstances is set out below. We will keep scanned copies of all of this for validation and audit, at which point this evidence will be deleted in line with our document retention rules. 

We also collect information for discount tariffs such as WaterSure, Water Support and WaterSure Plus on behalf of Thames Water, where they provide sewerage services so that these can be processed (Water Support applications are shared with Citizens Advice Mole Valley). Our priority customers may provide information to us about medical conditions to allow us to make suitable arrangements during supply interruptions; they will be asked to give consent for us to process this data.

We use your information for the specific purpose(s) for which it has been provided to or collected by us and also to administer, support, improve and develop our business generally and to enforce our legal rights.

More detailed information on what we collect in different circumstances and how it will be used is set out below.

Lawful basis for processing

We must have a lawful basis for processing your information; this will vary on the circumstances of how and why we have your information but typical examples include:

  • the activities are necessary for the performance of our public tasks as a water company supplying customers with water and administering our relationship with them e.g. arranging and maintaining your supply, billing you, maintaining our infrastructure
  • you have given consent for us to process the information e.g. in relation to certain support and discount schemes or in relation to certain marketing activities
  • the activities are within our legitimate interests e.g. carrying out market research or customer satisfaction surveys
  • the processing is necessary for compliance with a legal obligation to which we are subject  e.g. we have to provide certain contact information and other details about our services to Ofwat and the Consumer Council for Water
  • to protect your vital interests e.g. because there is a risk to you and your household due to water quality issues or where the water supply has been disrupted

If we process any special categories of information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, processing of genetic or biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. This may include:

  • you giving us your explicit consent to do so e.g. in relation to a discount or support scheme
  • the processing being necessary to protect your vital interests or someone else's vital interests
  • you making the information public
  • the processing being necessary for the establishment, exercise or defence of legal claims e.g. because you have failed to pay your bills
  • the processing being necessary for reasons of substantial public interest e.g. where we suspect fraud on the part of a customer
  • the processing being necessary for reasons of public interests in the area of public health e.g. managing a water quality incident

What to expect when you contact us?

People who contact us via social media

It is never a good idea to post your personal contact information on a public social media site. If you contact us using social media to report an issue and we need more information, we will ask you to private message us with suitable communication information which we will use to contact you in order to resolve your concern or gather additional information for our investigation.

People who contact us by telephone

When you contact us by telephone your telephone number may be added to your account so that we can contact you in future in service of your water account.

We may also use a telephone number listed on your account to text you in the event that there is a water supply interruption or water quality concern (you will be given the option to opt out of the text messages).

People who e-mail us

If you e-mail us, we will respond to you using the e-mail address you gave us. Please try to avoid sending personal data by e-mail as this is not considered to be a secure communication method. Your e-mail address will be added to your account and may be used for future communications. Any email sent to SES Water, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. E-mails are also backed up by our data processor Mimecast. E-mails are deleted in line with our retention rules.  Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

People who make a complaint to us

If you make a complaint to us, we will follow our complaints procedure. We may need to share details about your complaint internally in order to fully investigate. If you escalate your complaint to The Consumer Council for Water (CC Water) we will share information with them in order to resolve your complaint. This exchange of personal data with CC Water is a legal requirement under section 27B of the Water Industry Act (as amended by the Water Act 2003).

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies any individuals.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention rules. This means that information relating to a complaint will be retained for seven years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

People who report a water leak

If you are kind enough to report a water leak we may take contact details from you in order to contact you if we need more information about the location or nature of the leak. You do not have to leave your contact information but it would be helpful for us if you can so that we can quickly identify the leak and repair it, minimising the amount of water that is wasted.

People who visit our website

With regard to each of your visits to our website we will automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information gathered through cookies and similar technologies are used to measure and analyse information on visits to our websites, to tailor the websites to make them better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.

Our website may also, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Information about Cookies we use

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We only use cookies that are required for the operation of our website; these are shown in the table below.

Cookie Name

Cookie Description

Accept

This cookie is used to remember that you have accepted our cookie policy and prevents the policy pop-up from appearing in future visits.

ASPSESSIONID

Unique identifier for each computer generated by the server to keep track of the user’s current session state.

No personal information is kept in the session cookie and it is destroyed when the session ends.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. More information can be found here: http://www.allaboutcookies.org/manage-cookies/

 

People who are water supply customers

People who report a water quality concern

If you report a water quality concern, for example dissatisfaction with taste, odour or the aesthetic appearance of the water provided to you, we will need to investigate. This means that we may use your telephone number to call you and discuss your concern. It is likely that a water sampler will need to visit your home to take some samples. We will keep you informed of planned visits and of any results we find by letter or by telephone. If you have provided an e-mail address a copy of any letter may also be sent using this for your convenience.

People who are Priority Customers

Priority customers are customers who may need additional assistance either in communicating with SES Water or in the event of a water disruption. Priority customers include people with physical or mental impairments / medical conditions or who have children who are under 12 months old and may not be able to easily leave their home to collect bottled water or who have a significant need for water as a result of their medical condition. We add customers to this register with their consent and use needs codes to minimise the amount of personal data we collect. As a priority customer we may contact you by telephone, e-mail, text or a physical visit to your premises in the event that there is a water disruption and you may be without running water. If you have provided a password then this will be used. If you have informed us that it takes time to answer the door, our employees will wait longer for you to answer the door. They will always have identification and if you are not sure you can always call us and check your visitor is genuine. You do not need to share full details of your medical condition with us to be added to the register and you can be removed from the register at any time if your circumstances change or if you would like to withdraw your consent. We work with trusted partners to process your data.

People who need financial help to pay their water bill

We have several schemes to help support customers who have financial difficulty. These schemes are: WaterSure, WaterSure Plus, Water Support, and Water Direct.

In support of the application for a scheme, we may request evidence of one or more of the following

  • A medical condition resulting in increased water use
  • A family, with three or more children living at the property under the age of 19.
  • The household income is less than the published amount and responsible for a child under the age of 5 (living at the property) or someone in the household is over 62 years of age
  • Received Disability Living Allowance (DLA) or Personal Independence Payments (PIP)
  • Income Support
  • Income-based Job Seekers Allowance (JSA)
  • Housing Benefit
  • Council tax Benefit
  • Pension Credit
  • Working Tax Credit
  • Child Tax Credit (other than just the family element)
  • Income-related Employment and support Allowance (ESA)
  • Universal Credit

People who are e-billing customers

In the interests of reducing paper and protecting the environment, and for your convenience, you may be an e-billing customer. This means that you can sign in online to see your bills and any outstanding payments and you will receive e-mail notifications when you have a new bill. We do take your e-mail address, water account number, name and postal address when you sign up for e-billing – for more details please see our terms of use.

There may also be links within the e-billing portal to leaflets which are normally sent out with paper bills, offering additional information about the water services we are providing to you, encouraging you to be water efficient or if you are an unmetered customer asking you to consider having a water meter.

Your e-mail address or telephone number may be used to contact you about the water services that we provide. If we want to use your e-mail address to send you direct marketing communications including those of our group companies, we will ask you to consent to this when you log onto e-billing. It is your choice whether you consent and consent can be withdrawn at any time by contacting us using the details above or using the "unsubscribe" function in any communication itself. 

People who fall into arrears or fail to pay their water bill

In respect to a customer’s responsibility for paying their bills, SES Water has a regulatory requirement to provide a safe, maintained supply of fresh water to your property. In section 5 of our Water Charges Scheme, which is approved by our industry regulator, Ofwat, we explain that water charges are payable by the occupier of the premises, or the person who uses the supply, except where the owner of the premises is liable by enactment or by agreement with SES Water. Our Water Charges Scheme is further supported by the Water Industry Act 1991, which gives Water Companies the powers to charge and recover charges. This is referred to in Section 142 of the Water Industry Act 1991.

The information that we hold about customers may be used to recover arrears in line with our regulatory obligations and in doing so we may use third party debt collection / management companies and credit reference agencies to assist us.

Profiling and automated decision making

All customers are given a High, medium or low rating which is based on previous payment history. Customers always begin with us on low and will remain in this category as long as they pay their bills on time, customer who fall into arrears or fail to pay their water bill may receive a higher rating which will directly influence how our customer liaison officers approach debt recovery with individuals. This ensures that first time late payments are dealt with proportionally. You can ask any customer services advisor to tell you your current rating. Some automated processing is used to send reminder letters and schedule visits but your account will always be reviewed by a person before legal action is taken to recover your debt.

We also profile our customers by whether or not the have a water meter so that we can target unmeasured customers to encourage them to have a meter fitted in the legitimate interests of water efficiency.

We receive some information about area affluence so that we can target particular customers who may benefit from financial support with paying their water bill. We will in the future receive and share additional information about individuals with the specific purpose of offering financial support in line with the Digital Economy Act.

Moving out of our supply area

If you move out of our supply area, your account will be closed once any outstanding balance has been paid but your data in relation to water consumption and charges will be kept on record for seven years. If you wish to object to any of the information we keep you can make an application to have further information deleted.

Visiting our offices

When you sign in to our visitor system your name will be entered and there will be a photograph taken. All visitor information is deleted from the system every 6 months. Our premises are monitored by CCTV so your image may be captured whenever you enter our site boundary. There are signs to show you when you are entering an area monitored by CCTV. CCTV Images are held for 30 days and then deleted.

If you have an accident while you are on SES Water premises this must be reported and will be recorded for the purposes of health and safety and insurance requirements.

Interested parties

If you are an interested party or stakeholder to SES Water, e.g. parish council, wildlife trust, local politician, neighbour to one of our sites, we will ask you to sign up to our new portal where you can stay up to date with SES Water activities. There is a separate privacy notice for the portal.

Use of our Company drone

We have a company drone which we use on our land above our sites to monitor for the purposes of maintenance and to track progress with large projects. The drone is flown by our CAA qualified pilots, is only flown above company land and not within 50 meters of a person. If you have any privacy related concerns about the use of our drone please contact us.

Information we collect or obtain from others about you

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this website.

We may also receive information about you in some of the circumstances set out above e.g. if someone else reports a possible water leak, makes a complaint or confirms information needed in order to provide you with a discount or support scheme.

We also work closely with trusted partners (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, local authorities and credit reference agencies) and may receive information about you from them.

In future, we may also receive information about you from public authorities and other utility companies in order to improve public service delivery and ensure that priority customers can access available support and discount schemes.

Information we share with others

In many circumstances we will not disclose personal data without your consent. However, there are circumstances where we need to share some of your data in order to meet our compliance obligations or where we are permitted to under the DPR.

The obligations that we have to our Regulators

We have legal obligations to share data with our regulators. For example, we are required to share contact information with our water regulator Ofwat (and third parties working on their behalf) for the purposes of the water industry's Service Incentive Mechanism. We also have to share any personal data related to a water quality incident with the Drinking Water Inspectorate (DWI). Occasionally if you are part of an incident investigation there is a chance that data may be shared with Health and Safety Executive or the Environment Agency if it is part of the reporting requirements.

Agreements we have with other organisations for sharing information

We have in place some data sharing agreement for mutual benefits. For example, we have data sharing agreements with some local authorities including Reigate & Banstead Borough Council, Sutton Council, Tandridge District Council, SES Home Services and Orbit Collections to help keep our customer data accurate. This may involve names and addresses of customers.

We also have legal requirements for sharing data with sewerage companies Thames Water and Southern Water who operate in our supply area.

If customers fall behind with their payments and we are unable to locate them to chase their debt, we may share their data with credit reference agencies that will help us to track people’s locations for the purpose of collecting debt. 

Circumstances where we can pass on personal data without consent

Sometime we are contacted by HMRC, the Department for Work and Pensions DWP, the police, fraud agencies or Immigration asking for information about individual customers. Under the DPR, we are permitted to share this data with them without your consent and you will not be notified that this has been done. This is in the support of the prevention and detection of crime.

Ofwat Service Incentive Mechanism

All customers who contact us may have their contact information passed to a third party processor acting on behalf of our water regulator Ofwat for the purposes of the Service Incentive Mechanism ("SIM"). The SIM helps to regulate customer service in the water industry in England and Wales. You may be contacted by this third party about the service you received from SES Water and asked to score our performance. This is not a marketing call. As this is a Water Supply Licence Obligation we have to share your data and are not permitted to remove any contact details. We are also participating at the request of our regulator in a trial for a new scheme to measure our performance for both customer services and developer services. To do this we respond to formal requests for customer data from our regulator and this is shared with their new partner Allto.

Other third parties

In future, we may also be permitted or required to share information about you and your account with public authorities and other utility companies in order to improve public service delivery and ensure that priority customers can access available support and discount schemes.

If we merge with another business entity or divests a part of our business or carry out internal corporate restructuring, your information may be disclosed to SES Water's new business partners or owners or the new corporate entities.

Trusted partners we use who may have access to your data

We use trusted partners to help us process your data and provide services to you. All of our data processors have a binding contract with us that restricts their access to and handling of your personal data to only what is necessary in performance of their contract.

We use software providers for different systems, like our billing system, job management system, and meter reading system, to support us with the large amounts of data that we need to manage. We use Computershare to assist us with printing bills and customer communications. We used Citizens Advice Bureau in Mole Valley to process Water Support applications. We use companies to help us process payments including card payments, payment cards and to process cheques.

We work closely with our primary contractor Clancy Docwra for mains replacement and pipe repairs and they will have access to some customer information relevant to their work.

We use Orbit debt collection to assist us with customer communications, adding priority services customers to our register, housing association customer repatriation and recovering debt from customers. They have access to relevant customer information on our billing system and may use your data to contact you or visit your home in fulfilment of their contract with us.

We use a company called ‘We answer’ to provide additional support to our customer services teams in busy times and to proactively conduct market research so that we can understand and improve our quality of service. You may receive a call from them following contact with us to ask about your experience and how you would score us. This is not a marketing call and your response is very important to us. If you would prefer not to participate you can register yourself as ‘no contact’ with our customer services team at any time. Please note this will not stop communications for the purpose of water supply or from our regulator. We still have to share your contact information with third parties who are working on behalf of our water regulator Ofwat for the purpose of the Service Incentive Mechanism which measures customer services performance by water companies. We are also participating at the request of our regulator in a trial for a new scheme to measure our performance for both customer services and developer services. To do this we respond to formal requests for customer data from our regulator and this is shared with their new partner Allto.

We use one of our group companies, SES Home Services, to make leak repairs at customer properties. If you contact us about a leak in your home and are eligible for a visit, your data will be shared with SES Home Services in order to provide this function on our behalf.

From time to time we require legal advice and may need to share your personal data with our legal advisers or our insurance company or other professional advisors in order to obtain advice or make a claim.

SES Water also uses a trusted partner service to help maintain the security and performance of the SES Water website. To deliver this service the trusted partner processes the IP addresses of visitors to the website.

Where we store your information and how we keep it safe

All customer personal data is held in our billing system in the UK, which has controlled access and is externally audited. We use anti-virus software and fire walls to protect against cyber-attack. All access to our systems is strictly controlled by our IT department. We also operate strict physical security at all our sites and employees all receive security and data protection awareness training.

Where we transfer information to third parties to enable them to process it on our behalf (see the information about Trusted Partners above), we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.

We also ensure that where information is transferred to a country or international organisation outside of the UK / EEA, we will comply with the relevant legal rules governing such transfers.

How long we will keep your information

We keep customer billing and correspondence for 7 years. We hold voice recordings for 6 months.

Your data protection rights

Y

You have certain rights in relation to your personal information, although those rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights. Alternatively, the rights may not be enforceable until the General Data Protection Regulation comes into force on 25 May 2018. We will tell you if this is the case when you contact us.

You have the right to be informed and we will try to be as transparent as possible in our interactions with you. Any time you give us personal information you have a right to be informed about why we need it and how we will use it. You can find most of the information you need right here in this Privacy Notice.

You have right of access to any personal data we hold about you. You can contact us at any time to gain information about what data we hold, why we hold it, where we got it from and how we will use and share it. You may choose to write to us to exercise your Subject Access right. If you make a formal written request we will respond to acknowledge your request and check your identity, we might also ask you for information about what you are looking for to help us make sure we meet your request fully. You will receive a full response at the earliest opportunity but in any event within 30 calendar days or your request. There is no charge made for this by SES Water.

To make a request to SES Water for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer, or writing to the address provided below. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

You have the right to have any personal data we hold corrected at any time if you believe it to be inaccurate e.g. the spelling of your name or your contact information.

You also have the right to ask for our processing of your personal data to be restricted for example if you are contesting the accuracy of data we are using to bill you. We will restrict our processing while we verify the accuracy of the data that we hold.

You can also ask for certain information about you to be deleted for example if you are moving out of our supply area and you are not behind with your water bill payments or if you are no longer part of a discount or support scheme. We will not be able to delete any data relating to outstanding debts until the debt has been repaid as we have a legal obligation to collect debt. We will also not be able to delete your information if there has been a water quality concern related to the water supply for your property, as this data must be kept for seven years, or any information that we need to retain in connection with our Water Supply Licence.

You have the right to data portability where our lawful basis for processing is consent and where processing is automated, although we don't currently carry out any such processing. If we do in future, you can make a request and this data can be exported from our systems for you. 

You have the right to ask us not to process your personal data for marketing or profiling purposes. We will ask for your consent (before collecting your data) if we intend to use your data for such purposes, not already detailed above or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at CustomerRelations@seswater.co.uk

Changes to this Privacy Notice

This privacy notice will be kept up to date as our business and internal practices and/or the DPR change and so may be subject to change at any time to reflect any changing activities. The most up to date version will always be available on our website.

We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by the DPR.

We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 21 May 2018.


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