Last updated: November 2023
Please Note: Due to changes set out by Ofgem in relation to Mandatory Half Hourly Settlement (see www.ofgem.gov.uk/energy-policy-and-regulation/policy-and-regulatory-programmes/electricity-settlement-reform) this Policy now gives us the right to automatically collect half hourly readings from your smart meter when you join us, change tariff or get a smart meter. This change is required to enable Ofgem’s plans for market-wide half-hourly settlement. We don’t actually currently do this (the default is daily) and we will always let you know before we start to do so. You can change how often your smart meter takes readings. See clause 3.2 for more information.
Your data is in safe hands
Our customers are at the centre of everything we do. So, as well as giving you excellent value and the best service around, we’re committed to protecting your privacy.
The boring bit:
The responsible data controllers are: OVO Electricity Limited (No. 06858121); OVO Energy Ltd No (06890795); OVO (S) Gas Limited (No. 02716495); OVO (S) Home Services Limited (No. SC292102); OVO Gas Ltd (No. 06752915); OVO (S) Energy Solutions Limited (No. SC386054); Corgi Homeplan (No. SC358475).
If you have any questions, comments, or concerns about this policy, we’d love to hear them. Get in touch anytime: our contact details are in section 14.
Thanks for reading! We hope this policy helps.
1.0 The data we collect and how we do this
We (or third parties who act on our behalf) collect your personal data when you use our website, talk to us over the phone, by letter, by email, on social media, video, digital messaging (such as Whatsapp), or in person, receive our products and/or services, or ask to join schemes which you’re eligible for.
We might collect the following data:
|Types of data we might collect from you
|What this data covers
|Your contact details and the contact details of people associated with your account.
Remember: if you give us someone else’s personal data, make sure you always have their permission.
Any other relevant info we need in order to know that it’s you and be able to contact you directly.
Details of a secondary contact, such as nominees or attorneys (for example, their name and number)
|Your account data and the account data of other people associated with your account.
Remember: If you give us someone else’s personal data, make sure you always have their permission.
|Unique account number
Date of birth
National Insurance number
Whether you’re a homeowner or renting
Energy Performance Certificate (EPC) data
Photos of your meters
Information about any other accounts you hold for gas or electricity including the name of the supplier and payment methods
Conversations we have with you, including phone calls and emails, which may be monitored or recorded
Household details and property type
Complaints and/or incident details
Notes added to your account
|Bank account details
Your credit history
Details of state benefits you receive
Information that allows us to understand your creditworthiness and financial position
|Internet protocol (IP) address used to connect your computer to the internet
Login data (like your username and password)
Your browser type and which version on the browser you’ve got, plus which devices you use to access our websites
Your time zone setting
Operating system and platform
Your behaviours on our website or app (for example, the pages that you click on page response times, download errors, length of visits to pages and how you interact with pages)
Your rough location when you connect to our websites (this will be just the city or county you’re using your device in)
We track technical data by using cookies
If you have an electric car we may collect the following data to provide you with services: car make, model, battery capacity & efficiency, kWh used by the charger from the grid and from the home (local power generation) kWh and minutes boosted
If you have a heat pump we may collect data on the usage and efficiency
|For some of our products and services, such as OVO Greenlight we might ask you to give us some extra data about your home and lifestyle, to make sure you get the most out of whatever you are using. This includes data like:
Number of people and rooms in your home
What type of heating system you have
What and how much you recycle
What transport you use
|Marketing and communications data
|Your preferences in receiving marketing from us and third parties
Your communication preferences
|Energy supply data
|The date we start supplying your energy
Technical meter details
Meter Point Administration Number (MPAN) for electricity customers
Meter Point Reference Number (MPRN) for gas providers
Energy usage (like meter readings and units of gas and electricity used over a period of time)
| Sensitive categories of data
|Data about your needs and the needs of other people in your household. This helps us understand if you have any special requirements. For example, this data may cover age, disabilities, health and/or any financial vulnerability. And, if it applies to you we might add you to the Priority Services Register.
If we think that someone might have committed fraud or stolen energy from us (for example by tampering with a meter or diverting the energy supply) we’ll record this information (see section 4 for further details)
|If you’re applying for Help to Heat Group Benefits, we need a mortgage statement.
If you want to attend one of our sponsored events, we might need venue and dietary preferences, accessibility needs and an emergency point of contact
If you speak to us through social media, we take your name and store a link to your social media profile, which we keep with details of your previous correspondence with us.
If you register an account for services with us, we create and record customer ID numbers for you and record the date of your application.
If you are part of the Group Feed-in-Tariff (“FIT”) Scheme or Smart Export Guarantee (“SEG”) Scheme, we’ll gather the following: regular generation/export meter readings; generation/export meter details; data needed for identification and address checks; details of company affiliations; details of nominated persons; contract details; micro generation certification scheme information; and (where necessary) EPC information for the property.
If you consent to video recordings for virtual home assistance and/or repair, we may capture visuals of your home if you keep your camera on whilst moving through your household
|If you have applied for Select Car Leasing, we will collect your vehicle registration number to confirm your lease agreement.
It’s really important that the personal data we hold about you is up to date so please let us know if your personal data changes at any time.
If you do not provide us with any personal data which we may request from time to time, we may not be able to provide you with certain services.
2. How do we use your personal data?
Here’s some more information about how we use your data.
We might use your data for the following reasons (this can include our agents and third parties too)
|Our reason for using your data
|More details on what we need this for
|To serve your account
|To identify you
To give you relevant products and/or services, benefits and rewards
To give you information about the amount of each service you’ve used, and which charges apply. For example, how much electricity or gas you have used and what this will cost
For contacting you about your account, whether that’s via post, email, your online account, SMS, live chat or other forms of electronic communication (including, messages sent through a smart meter) or by visiting you (to take a meter reading for example)
To predict the amount of energy you’re likely to use in any period of time
For deciding which products and/or services and which terms and conditions we can offer you. For example, if you ask for a certain plan we’ll check to see if it works for you
We will use data collected from your smart meter to work out your bills, to identify you, and to prevent fraud or energy theft. If you have a smart meter, you’ll find more details about how we use your information in our terms and conditions, as well as in our Guide to Smart Meter Data and Data Collection
When you switch to us from your last energy supplier, or when you switch away from us to a new one
To spot and prevent crime, fraud or loss
So you can use interactive online features
As part of arranging and carrying our visits to your property (such as for reading meters)
To give you incentives or run a loyalty scheme
To answer your complaints or questions
|To help us improve
|For training our team and improving our products and services, which might mean we monitor and record conversations we have with you (like phone calls,emails,SMSs and live chats)
When using data analytics to understand and improve the way we do things as a business
To carry out market research and to get in touch with you about this (for example when doing customer satisfaction surveys and questionnaires)
To create internal reports or profiles while analysing information for forecasting and marketing purposes
When we are conducting trials of technology and infrastructure to help develop and improve products and services
|To keep in contact
|For us (or authorised third parties) to get in touch with you, about our services and/or products - such as to send you info when you sign up or change plans, service announcements and administrative messages
To contact you (by letter, phone call, SMS or email) with details of products and services that we or members of the OVO Group offer, which are similar to those that you have already, or to give you info about services or products you’ve opted in to getting from us
To see if you would like any help when you start but don’t finish our sign up journey, or when you have asked for a quote from us
To contact you about any outstanding matters after the account is closed or you have switched to a different supplier
|To support the business
|To ensure the health and safety of you, our team and contractors
When using Feed-in Tariff (FIT) data to register the installation on the FIT scheme through the Central FIT Register, when acting as administrators and facilitating payments through this scheme, and when acting as a mandatory licensed supplier for the SEG (Smart Export Guarantee) scheme
To comply with any procedures, laws and regulations which apply to us – including where we think it's in our best interests to comply (or in the interests of others)
To allow internal corporate reporting, business administration, adequate insurance coverage, the security of company facilities, research and development, and to find business efficiencies and put these into practise
When your letting agent has given us personal information about you, we might need to share this with your local council and water authority - so they can get in touch with you about any tax or charges
To help with system maintenance, testing and training
To run credit checks and check your credit score, which might affect the services we offer you
To carry out or help with fraud prevention, identity or money laundering verification and legal enforcement when needed
To take payments and go after any money owed to us, and manage our debt collection and recovery activities
To administer and protect our business and to manage and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To respond to media or parliamentary enquiries as part of our right to respond
We may send you marketing communications about other companies in the OVO group and about our partners. We do this where we are allowed to because of law. The communications could be by email, letter, phone call or SMS. We won't send you direct marketing where you have opted out of receiving direct marketing communications.
We might also use your personal data to show you digital advertisements via your My OVO app, social media feed, on search engine results pages, or on other websites. You have the ability to opt out of this type of advertising on the relevant platform (e.g by blocking cookies or clicking no in the application).
If you want to change your marketing preferences, you can do this at any time. Our contact details are in section 14.
Finally, If you decide to leave us, we may contact you to allow us to market our products and services to you after you have left for up to one year, unless you opt out.
3. How we use smart meter data
3.1 Here’s how we use energy consumption data, given to us by your smart meter
We will use your energy consumption data we obtain remotely from your smart meter for the following purposes:
- To calculate your energy usage
- To produce bills based on real readings
- For industry reasons, and to predict the demand for energy
- To give you information and feedback about your energy use, as well as how you could manage your energy use better and save money
- To track trends in energy use, analyse your energy data, and to compare it over time with other customers’ energy use. This is so we can create tailored products and services for you
- To spot faults when they happen and fix these faster, as well as any other issues with your meter
- To give interactive tools to analyse your energy use through your online account, or through communications we may send you (like when we send you energy saving advice)
- To give you tailored advice on how to lower the amount of energy you use based on your energy use specifically
- To carry out internal reporting, modelling and analysis to understand our customers better
3.2 How often your smart meter sends us readings
You can choose how often your smart meter sends us readings. When you join us, change tariff or get a smart meter the default position is that your smart meter will send us half hourly readings. You can opt out of this and change to another frequency at any time by getting in touch with our customer service team (current options are half hourly, daily or monthly).
You don’t have to give us readings frequently, if you don’t want to. But, if that's the case we might not be able to give you some of our products and services. Or at the very least, your use of some products and services could be limited. The options are:
- half hourly – your smart meter will collect data every 30 minutes and send this to us once a day (this will be the default setting that you have consented to when you join us, get a new smart meter or switch tariff unless you opt out);
- Daily - your smart meter will send us a reading once a day
- Monthly – your smart meter will send us a reading once a month. Please note this is the lowest level of data we’re allowed to take for billing and regulatory reasons. If you choose this option, we’ll also take ad hoc daily meter reads, as and when we need to to make sure we’re serving you properly. For example, to keep billing you accurately, or if we need to use the data to answer a question, or if we think your smart meter isn’t working properly)
We might also get smart meter readings when:
- your prices change
- you move to another of our energy plans
- you move home
- you ask us to
- you switch to another supplier
You can always change how often we collect energy data from your smart meter. If you do, this will take up to 5 days to carry out from the date that you contact us.
4. How we use your sensitive personal data
We treat some of the data we collect about you as extra sensitive. This could be about your needs, or details of criminal offences (see section 1). We’ll only use this data in the following ways:
4.1 How we look after you and others in your home
We collect data about you and other people in your household, to make sure we’re aware of any needs you might have. This could be data on age, health, or disability, for example. With your permission, we could use this helpful data to:
- Look after you and others in your household. For example, to make sure we don’t turn off your power if you have a vulnerability. And so we can respond in the right way, if there’s an emergency situation.
- Give you products and/or services in a way that suits you, like if you need large print or braille
- Assist staff and third-party contractors
- Make sure you have the best experience when you come to an OVO event – let’s say, if we need to make sure the space is easily accessible for you
We might share this data with the following people or organisations:
- The electricity distributor (who will also give us this data) via the Priority Services Register
- The relevant gas transporter (who will also give us this data), engineers, or the network operator via the Priority Services Register
- When using an outsourced service company that manages a wide range of energy industry data, for us
- Social services, charities, health care services, and other support organisations
- And/or other relevant organisations – such as emergency responders or local authorities, which might be able to give you support
4.2 Criminal offences data
We use details of any criminal offences you’ve been accused of, together with information about whether the gas or electricity supply to your property has been tampered with or stolen in the past (or if we think it has), for the following reasons:
- To make decisions about which products and services we can offer you, as well as the relevant terms and conditions
- To make decisions about whether to disconnect your energy supply
- To spot and prevent fraud or crime, with the help of any third parties when needed
5. The data we get from third party sources
We also get your personal data from the following third-party sources:
|Type of data
|Other energy suppliers
|Meter readings Payments from your existing supplier, when you ask to switch from us We might also get details of suspected fraud or energy theft, so we can spot fraud or crime
|National databases(ECOES, Xoserve and PAF)
|We might get details like your MPAN and other information about your energy supply, to help if you’re going through the process of switching suppliers. And to access this info, we might use a third party.
|Debt collection agencies
|Information about payments you’ve made or payment plans you have agreed to Information about your personal circumstances such as your ability to pay and any additional needs you have
|Credit reference or fraud prevention agencies
|You can find more info about this kind of data in sections 7 and 8
|Third party data providers
|We collect aggregated data about your geo-demographic lifestyle and property energy performance. We analyse this along with your account information so we can gather insights, plan marketing activities to tell you about relevant products and services; and to conduct market research and business development.
If you’ve entered our collections process, we collect contact details to help us get in contact with you
Debt consolidation providers give us information on your debt profile, to help us create payment plans if you’re struggling financially
If we’re doing something that may impact the service you receive, we may ask tracing agents or other third parties to collect your contact details to help us communicate with you
|Councils, local authorities or housing associations
|We might get your name, address and contact details from councils, local authorities, or housing associations. This could be when these organisations want to apply for carbon-cutting measures for your property as part of the government funded schemes.
|Letting agents, landlords, cohabitants, previous tenants or other third parties
|We might get your name, address, and contact details if you’ve recently moved into, or taken over a property or supplier. Or if a third party (Like your landlord) introduces you to the OVO Group, so we can set up your account.
|As a regulated company, we might get your personal information from our regulator, Ofgem, in order to meet our regulatory obligations
|Law enforcement agencies (such as the police)
|We might get data about meter tampering, the bypassing of meters, or the illegal use of energy so we can spot and prevent fraud or crime
|OVO Group companies
|We might get your account data, technical data, optimisation and energy supply data for administrative reasons – like to make sure our customers are getting a consistent service from us, and to make our business more efficient OVO Group includes any of the companies listed at the top of this document. Plus, our related businesses in the wider OVO Group such as CORGI, Kaluza, Field Force, Kantan, and The Renewable Exchange, as well as other subsidiaries of OVO Group Limited from time to time.
|Third parties who introduce you to us (such as price comparison websites)
|So we can set up an account for you and to give you the services you’ve asked for
|Department for Work and Pensions
|We might get the following details to check if you can get the Warm Home Discount Scheme: your contact details, account data, financial details, and details of your energy supply
|Department for Business, Energy and Industrial Strategy (BEIS)
|We might give them your contact details, account data, and energy supply data. This could be if they ask for information about Feed-in Tariff (FIT) installations, for example.
|Partnerships with third parties that provide offers
|If you redeem a voucher/offer from a third party via the OVO Beyond app that provides a reward to your OVO account (such as applying a credit to your bill) the third party will inform us that you have redeemed the voucher and we will apply the relevant information to your account. An example of this is if you book transport with Omio via the OVO Beyond app.
6. Legal Bases for data processing
We’ve checked the legal bases for us to use your personal data, and they’re as follows:
|For your contract
|We use your data mainly to give you the products and services that you’ve asked for (for example, energy products) and to provide you with information about these products and services
|Our legal obligations
|Our use of your personal data is necessary so we can comply with our legal obligations
|Our Legitimate Interests
|It might be in our interests to collect and use personal data, as we need this info to give you the services you want more effectively. When deciding whether it's in our interests to use your data, we will also consider your interests as a citizen and your rights under data protection laws.
It's in our interests to:
• Run, grow, and develop our business
• Spot and prevent fraud and Identify, exercise or defend ourselves against legal claims, complaints and investigations (including media, parliamentary and regulator investigations)
• Make sure our own processes, procedures, and systems are as good as they can be
• Recover debts that are owed to us
• Get a better understanding of how people use our website and other channels where people engage with us
• Analyse and enhance the information that we collect
• Work out how effective our promotional campaigns and advertising campaigns are
• To send marketing communications to you by Mail and phone, you can opt-out of these at anytime, please take a look at section 14
• Enhance, modify, personalise, or otherwise improve our services and communications for the benefit of our customers. If you have concerns about the processing activities based on our interests, please take a look at section 14.
• Improve the security of our network and information systems
• Raise awareness of Smart Meters
|Sometimes, we need your consent if we do want to use your personal data. For example to send you marketing communications about OVO group products in certain circumstances. If you give us consent, but you later change your mind, you may withdraw it, by letting us know. Just get in touch, using the details in section 14 and we’ll stop using your data for that purpose.
|On very rare occasions we may use or share data about you to protect you or someone else.
|Substantial public interest
|We might use data in order to pursue something that’s of key interest to what’s called the ‘substantial public interest’. This would always be in accordance with the Data Protection Act 2018. These interests cover things like the safeguarding of people at risk, and safeguarding the economic wellbeing of certain people.
7. Automated decision-making
Your personal data helps us to make decisions that are automated (which means they’re carried out by my computer systems automatically). And we use your data to do this in the following ways:
7.1 To decide your OVO Home Services cover renewal price
We use an automated calculation to enable us to make a fair and responsible decision on what pricing we can offer you based on the cost of maintaining your boiler. We’ll consider:
- your boiler make and model;
- the length of time you have had cover;
- your geographical location;
- your claims history; and
- whether non-standard system parts are required (including thermal stores and unvented cylinders).
If we think your boiler is non-standard and/or you have made a claim against your product, and/or you live in a place where it costs more for us to serve you, your individual renewal price might go up.
7.2 To make credit decisions
We use automated credit-scoring assessments to check how suitable it is for you to take any product or service on a credit basis, and to manage any debt related to your account. To do this, we might look at:
- Data that’s included when you apply for a new product or service
- Data we already have about you, your account, or your property – such as payment history for existing products and services. This includes data from accounts where you’re named jointly, with one or more other account holders.
- Information from one or more credit reference agency
- And/or, where it’s appropriate, data from fraud prevention agencies
If we decide that offering unsecured credit is not appropriate, we might need energy customers to pay a security deposit – or to pay using a prepayment meter, or a smart meter in prepayment mode. We might ask you for payment security at any time, if we decide that unsecured credit is no longer right for you.
7.3 For the Warm Home Discount
For both online applications and paper applications, we use an automated process to check people are eligible for Warm Home Discount rebates. This means our computer system will check the benefits you’ve ticked on your application, to see whether you meet the criteria needed to get the rebate. The criteria are described in the online journey and on the paper application form.
7.4 How to appeal
You can appeal against any automated decision, get an explanation of the decision or ask for a person to review it, just get in touch with us. You’ll find our contact details in section 14.
8. Who we share your personal data with
We will share your personal data with the following types of third parties:
|Our third-party suppliers, partners and subcontractors
|They offer, review and/or receive services in relation to our website, services and/or products. They include:
• Payment processors
• Suppliers of technical, support and installation services
• Logistics providers
• Call centre service providers
• Security providers
• Cloud services providers
• Research agencies
• Market research agencies
• Green Deal providers
And (If you can claim government funding for energy efficiency measures) installers, energy performance assessors and sales advisor
|Any company that;’s a member of OVO group
|OVO Group includes any of the companies listed at the top of this document. Plus, our businesses in the wider OVO Group such as CORGI, Kaluza, Field Force, Kantan, and The Renewable Exchange, OVO Home Plan as well as other subsidiaries of OVO Group Limited from time to time.
|Family members or cohabitants, previous tenants, landlords, letting agents or other third parties
|Where appropriate, people who could need data about you or your property - or who introduced you to us
|Government or law enforcement officials
|If we have good reason to think we’ve got a duty to do it, we’ll give out your data to meet any legal obligation – where your data might be needed to meet national security or law enforcement needs, or to stop illegal activity.
|Other energy suppliers
|If you choose to leave us, we’ll share your data with your new supplier to help make the switching process smoother. This includes your energy use and any debts on your account. We might also share your personal data with another energy supplier when they carry out services for us – like if they do meter readings at your property on our behalf.
|Regulators or other legally appointed bodies
|This includes but is not limited to Ofgem, The Information Commissioner's Office or Financial Conduct Authority. We share your data for legal or regulatory reasons - for example, we might send your data to Ofgem to prove that you qualify for a government funded scheme if we are asked to do so.
|Price comparison sites
|These sites might take your details when you ask for a quote, or when you switch to us via a price comparison site.
|Third parties that help us with advertising and marketing
|Here’s one example of how this works. We share some personal data with these third parties, who advertise on their platforms for us: Amazon, Viant, Facebook, and Google AdWords.
|Relevant gas transporters, engineers, or network operators;
|We’ll share data with other utility service providers who might be supplying your property – like your distribution network operator.
|Where it will help you, we’ll share data with your local authority, water company, social services, charities, healthcare services, and other support organisations. We might also share it with housing associations that are relevant to your property and/or your use of our services.
|Debt collection and tracing agents
|This might happen if you don’t pay us for the services we give you. We might also sell the right to recover any debts you owe us to a third party, which is part of our general terms and conditions for supplying electricity and/or gas. As well as this, we could pass personal data to possible buyers of this debt, so they can evaluate it before the sale’s complete. If we’re doing something that could impact the service you receive, we may share your personal data with a tracing agent to locate your contact details so we can communicate with you.
|Authorised third parties or named account holders
|This can be on any account you hold with us
|Anyone who buys our business, any other business we buy or merge with, and/or a new data controller
|If we sell or merge any of our businesses or assets, or if we do any internal reorganisations, your personal data might be one of the assets that goes to the buyer and/or new data controller. This includes transferring data to a potential purchaser for due diligence purposes before the purchase takes place.
|Insurance underwriter /alternative dispute resolution provider
|If you’re a Home Services customer, we might share your data with an insurance underwriter, who underwrites our insurance products. We could also share your data with a dispute resolution provider, if you’ve got a complaint about your non-insurance product that we can’t settle.
|A third party, such as police or legal representative
|We would need to share your data with these third parties as part of enforcing our terms and conditions, or any other agreement. This might also happen when we’re replying to any claims, or protecting the following: our rights, or the rights of a third party, or the safety of any person. We might also do this to stop any illegal activity.
|Credit reference agencies
|When you enter into a contract with us for your energy supply, we’ll give information about you to credit reference agencies, and gather this from them too. When credit reference agencies get a request from us, they’ll place a search footprint on your credit file. This might be seen by other lenders. They give us public data (including info from the electoral register), as well as data on shared credit, your financial situation, information on your financial history, and on fraud prevention. We might also make checks, like assessing your application for credit and verifying identities – so we can spot and prevent crime. We’ll also keep sharing information about you with credit reference agencies on an ongoing basis. This includes things like your settled accounts and any debts you haven’t fully repaid on time. Occasionally, we might also do searches via credit reference agencies and fraud prevention agencies to manage your account with us. Who these credit reference agencies are, and the ways in which they use and share personal information, is all explained in more detail at experian.co.uk
|These advisers could be lawyers, bankers, auditors, and insurers who offer consultancy, banking, legal, insurance and accounting services.
|Letting Agents (where applicable)
|To carry out any ancillary services that you’ve asked for – an example would be for help with council tax and getting water set up at a new address.
|Fraud prevention agencies
|(i) To help us spot fraud and energy theft, we’ll give details of your account to fraud prevention agencies, who’ll use the information to check public databases and other ones they hold. They might also give us information to help tackle fraud and energy theft. Checks will be carried out on a regular basis, while you hold an account with us. (ii) If we think or are certain that energy has been stolen, a record will be kept by fraud prevention agencies. This might include sensitive data about alleged criminal offences. The fraud prevention agencies might give the information to other energy companies to help uncover fraud and energy theft, but only in occasional circumstances where you have accounts with them. Where theft has been found, your account terms could change, but we’ll let you know if this is the case.
|Owners and/or operators of smart (or similar) meters, smart meter contractors and the Data and Communications Company (DCC)
|This is for your smart meter, so that we can connect to it and get readings from it.
|Department for Business, Energy and Industrial Strategy (BEIS) / Central FIT Register
|For FIT and SEG customers, we’ll share information with the Department for Business, Energy and Industrial Strategy (BEIS) and the Central FIT Register where requested.
|Media and parliamentary enquiries
|If you have requested and/or agreed that a Journalist or Parliamentary Representative can investigate an issue on your behalf we may provide them with information regarding your case - as part of our Right to Respond.
9. How your personal data is sent outside of the UK and European Economic Area
We (or a third party who we share personal data with) might host, store, and handle that personal data outside of the European Economic Area (EEA). Some of our customer service work is done outside the EEA, to make sure we operate as easily as possible. This means that we’ll send your personal data to suppliers based outside the EEA.
9.1 The ways we protect data when we send it
When we send data outside of the EEA, we make sure that all the right safeguards have been put in place to protect your personal data.
This means that we’ll:
- Make sure the country where your personal data will be handled has been deemed “adequate” by the Information Commissioner’s Office (“ICO”) in accordance with the UK GDPR.
- Include standard data protection clauses (approved by the ICO for transferring personal data outside the UK and EEA) in our contracts with those third parties – these are the clauses approved under Article 46.2 of the UK GDPR.
10. How long we keep your personal data
We keep your personal data for no longer than is necessary. This means that when we don’t need it any more we delete it. The length of time we keep it all depends on why we’re using it and/or what we need to do to comply with applicable laws and to establish, exercise, or defend our legal rights.
In some circumstances, we might anonymise your personal data (so that it can no longer be associated with you) and use this indefinitely, without further notice.
11. Protecting your personal data
We follow strict security procedures to protect your personal data. This includes following certain guidelines (for example, checking your identity when you phone us).
Whilst we take appropriate technical and organisational measures and have in place physical and electronic procedures necessary to safeguard the personal data that you provide to us, no transmission to or from us by post, email, phone, SMS or over the internet can ever be guaranteed as entirely secure. Communications over the web are not secure and as such, we cannot accept any liability or responsibility for any unauthorised access or loss of personal data.
We also have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach where we’re legally required to do so.
13. The choices and rights you have, when it comes to your personal data
Our contact details are in section 14, and you can always get in touch to ask that we:
- Let you know if your personal data is being processed
- Give you further details about how we process your personal data
- Give you a copy of any personal data we hold about you
- Withdraw your consent for a way that we’re using your data (where we need your consent legally to use your personal information)
- Consider any valid objection you have to us processing your personal data (including the right to object to processing where we’re relying on our interests as a legal basis for processing)
- Update or delete personal data that we have about you
- Restrict the way that we process your personal data
- Consider any valid request to transfer your personal data (that relates to an energy account) to a third-party provider of services (this is called data portability)
- Where we carry out automated decision making that has legal or significant effects on you, make sure we get a person to review that decision, give you an explanation of the decision, and/or consider your appeal of the decision
However, certain personal data may be exempt from the requests above, in certain circumstances. We could need to keep processing your personal data because of our interests, or to meet a legal obligation.
If an exemption applies, we’ll tell you when we reply to your request. We might ask you to give us some data to confirm your identity before we reply.
14 Getting in touch with us
14.1 Our contact details
Two tips to help us get back to you more quickly:
- When you send us your message, let us know if it's a "rights request" as part of your message. This will help us make sure it gets to the right people.
- Include your name, account number, address, and if there's any data you're especially interested in, if you can. This will make it easier for us to respond to you properly.
How to contact us:
- If you’ve got any questions about data protection, or you’re not happy with how we’ve handled your data, email us at [email protected].
- For access to your data, use our online form.
- To delete your data, use our online form.
- For all other requests, email us at [email protected].
14.2 Data Protection Officer (DPO)
You can email our Data Protection Officer (DPO) at [email protected]. You can also write to them:
14.3 Information Commissioner’s Office (ICO)
If you’re not happy with our reply to any complaint or you think our processing of your data doesn’t comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO). Just use these details:
- Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
- Telephone number: 0303 123 1113
- Website: ico.org.uk