South East Water Limited ("We") takes care to protect and respect your privacy.
For the purpose of the Data Protection Requirements*, the data controller is South East Water Ltd of Rocfort Road, Snodland, Kent, ME6 5AH (company number 02679874).
* 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 notice or exercise any of your rights you can:
email us: Dataprotection@southeastwater.co.uk
write to us: Data Protection Officer, South East Water, Rocfort Road, Snodland, Kent, ME6 5AH
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.
South East Water strives for 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, such as by telephone or email. This includes information you provide when you register to use our website, establish an online billing account with us, 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 but may include:
- your name, address, email address and landline and mobile phone number,
- Date of birth to help us identify you
- National Insurance number if we need to pass this to the Department of work and pensions
- Bank account details if you pay by direct debit
- Credit card details (although this is never recorded or stored after the payment is made) if you pay by credit card
- Income, expenditure and other affordability information including benefits information if you apply for a particular scheme or tariff
- Medical or health information so that we can provide you with tailored services (for example if you ask to go on our Priority Services Register)
- Landlord name and contact information
- Details of your household such as number of children,
- Meter details such as water consumption and usage
- Details of your water usage by way of surveys
Where you provide any evidence of the above 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, Helping Hands and Water Direct both for ourselves and for your wastewater providers, Thames Water or Southern Water.
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.
Our lawful basis for processing your personal information
We will only process your information if we have a lawful basis to do so. There are 6 lawful basis of processing as set out in the Data Protection Requirements and the ones that most apply to South East Water are set out below.
Most of the activities we carry out are necessary to ensure compliance with a legal obligation or to carry out our statutory powers as a statutory water undertaker, for example, providing a supply of drinking water, managing our water network, promoting water efficiency, raising and collecting charges, reducing debt and protecting the health and safety of our staff.
Where the activities are not strictly necessary for compliance with a legal obligation we may process your information in accordance with our legitimate interests e.g. carrying out market research or customer satisfaction or feedback surveys, or telling you ways you can be more water efficient.
We always check that our legitimate interests are not overridden by your rights and that such processing is set out in this privacy notice.
In some cases we may need your consent to process the information e.g. where you provide us with sensitive personal data such as health data, in particular in relation to certain support such as our priority services register and discount schemes or tariffs or in relation to certain marketing activities. When we use consent we will make sure we collect your consent and record it and that we will tell you how you can withdraw your consent if you change your mind.
Sometimes we may need to protect your vital interests and process your information 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.
In some cases we may be acting in the best interests of the public when we use your data, for example when we operate our Priority Services Register to ensure that our communities are served in the ways appropriate to them and that support can be provided at times of need. In this case and to process your special category health data we also use the lawful basis of Substantial Public Interest
What to expect when you contact us
Contacting 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.
Contacting us by the website
If you fill in a form on our website or use the contact us page for sending a message the information you provide will be added to your account so that we can action your request and your contact details will be saved for future use by us in managing your account. All the forms you use on the website will have a link back to this privacy notice for more information, depending on the form.
Completing water use surveys or water efficiency tools on our website
The information you provide about your water usage will not be stored on your water account. It will be used by our water resources management team in relation to future planning for water resources in your area.
Contacting us by telephone
When you contact us by telephone your telephone number will be added to your account so that we can contact you in future with regard to our services to you, for example confirming that action on your account has been taken, such as a bill being paid or a meter read having been taken.
Where you have provided a mobile telephone number this will be added in the same way and you will receive occasional texts to confirm appointments made with you or to let you know not to worry about a letter that may already be in the post if your payment was received, or if we have been trying to get hold of you for example to make an appointment.
You may also be asked from time to time if you would like a text to confirm any action that you have requested on your account, for example a receipt of a telephone payment, confirmation of a meter read etc. These will only be sent to you if you want them sent.
We may also text you in the event that there is a water supply interruption, water quality concern or to provide you with urgent information about your water account. This will only be used in essential service cases.
You can also sign up to receive additional text services, such as ‘In Your Area’ or for general information and updates if it is easier for you to receive texts for example if you are hard of hearing. This way you will know that you are always kept up to date. If you opt out of receiving such additional messages later on you will still receive your essential service messages.
We may also use it to tell you about other services we offer that are similar to those that you have already purchased or enquired about. Where we have obtained your details in the course of setting you up a water account and providing such services to you, we may contact you by electronic means with information about services similar to those which were the subject of this previous transaction unless you tell us you do not want us to by opting out. If you opt out of receiving such messages you will still receive your essential service messages.
Contacting us by email
If you e-mail us, we will respond to you using the e-mail address you gave us. Please note that we will still need to identify you are the account holder before we can discuss your account over email so we may need to ask you to provide personal information about yourself. As email is not always the most secure method of communication please feel free to either contact us via a web form or telephone us if you do not want to put your personal data in an email. Your e-mail address will be added to your account and may be used for future communications.
We may use it to tell you about other services we offer that are similar to those that you have already purchased or enquired about. Where we have obtained your details in the course of setting you up a water account and providing such services to you, we may contact you by electronic means with information about services similar to those which were the subject of this previous transaction unless you tell us you do not want us to by opting out. If you opt out of receiving such messages you will still receive your essential service messages.
Any email sent to South East Water, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance. Emails are also backed up and thereafter 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.
Contacting us by post
All letters and their accompanying documents are scanned and then saved electronically. The hard copy letters are then destroyed and any accompanying original documents (for example evidence of identity) are not stored at South East Water and these will be posted back to you.
How we can identify you once you have contacted us
In order to ensure that we are manging your account in a secure way you will be asked to provide identifying information about yourself. We have improved this security recently and we will now be asking for your date of birth as this is deemed a more secure identity question to use. It is important that you keep your contact and identification details up to date with us. Where you have contacted us by direct email we may need to call or email you in response to or to confirm you are the account holder before we can discuss your account with you.
Please note that if our agents do not feel that they have been able to satisfactorily identify you they may not be able to provide you with information about your account. If you struggle to remember items of information, ask about our password scheme or think about appointing a third party to manage your account for you. Contact us to find out more about this.
Visiting our offices
When you sign in to our visitor system you will need to provide information such as your name and vehicle registration number (if you are parked at our site).
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.
We also have ANPR (automatic number plate registration) at our Head office and at some of our sites for security purposes so we can identify cars that have entered.
If you have an accident while you are on South East Water premises this must be reported and will be recorded for the purposes of health and safety and insurance requirements.
Visiting our website
To enable us to monitor and improve our websites, we may gather certain information about your use using cookies and similar technologies. These 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 the site’s 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
|Google Analytics||These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.|
|s7.add this.com||These cookies are used to collect information about how visitors share pages on our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the pages shared using the Add This tool, number of visitors to the site, where visitors have come to the site from and the pages they visited.|
|Cloud flare||This cookie is used to accelerate content delivery across the website. This cookie is strictly necessary for Cloudflare's security features|
|Incapsula||This Cookie improves performance and security on the website.|
|Various||These cookies are used across the site to help prevent CSRF attacks, ASP.NET MVC uses anti-forgery tokens, also called request verification tokens.|
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: https://www.aboutcookies.org.uk/managing-cookies
Our household customers
For all our household customers we will use your name and address, date of birth and other items depending on how you contact us (see above) for managing your water account and providing your water services. This means we can use it to help detect and quantify water leakage; manage the water network, help us to fulfil our duty to encourage water efficiency and for billing and payment purposes such as administering your account, verifying your identity, debt collection, responding to your queries, processing your applications and contacting you by telephone, email or post in relation to our services, obtain your views or comments about our services and generally carry out our functions as a water company. We may also provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about. We rely on our statutory entitlements as a water provider and our legitimate interests to do so.
For some customers we may need additional items depending on their requirements.
Priority Service Register
Our customers can choose to become a member of the Priority Service Register (PSR) if they need additional assistance in communicating with us or they have certain access or health needs or may need support in the event of a water disruption. Have a look at our Priority Services page for more detail.
Customers can be added to the PSR with their consent. However we are now going to use the lawful basis of processing called public task as this will allow third parties to add people to the priority service list where they cannot add themselves and allows us to act in the best interests of the public when we use your data to ensure that our communities are served in the ways appropriate to them and that support can be provided at times of need. In this case and to process your special category health data we also use the lawful basis of Substantial Public Interest. Any customer can ask to be taken off the PSR at any time.
We ask for information about the type of need you have and you may be contacted by telephone, email, text or in person when you join and occasionally thereafter to ensure that we are providing you with the best support for your needs.
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 technicians and field agents 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.
We may also share your details with our trusted partners or your sewerage provider in the event of an emergency so that if you have a high priority water dependent need we can supply you with bottled water.
If anything changes about your situation just tell us and we will update your details. If you don’t want to be on the PSR anymore, just ask to be removed and we will do this for you.
We may also join a nationwide initiative between water and energy companies so that you only have to register in one place. If we do we will give you notice before your details are shared with your energy provider.
Customers with financial difficulty
We have several schemes to help support customers who have financial difficulty. These schemes are: WaterSure, Helping Hands, Water Direct and Social Tariff. We may recommend these schemes to you in accordance with our legitimate interests but you will only be placed on these if you are eligible and have provided your consent.
In support of the application for a scheme, we may ask you questions about your household including the occupants, ages and incomes and 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 set amount for the scheme and whether you are 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
- Date of birth for you and/or your children
My Account customers
For your convenience, you can choose to register to have an online account called “My Account”. 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. You will also receive email and text notifications when there has been a change to your payment plan or there is an important message to send you relating to your water account. You will also have an option to sign up for optional notifications as well via your My Account in the Notifications page.
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 and water efficiency advice.
For the information you provide to us when you register as a customer please see the section above relating to how we process information when you contact us with by telephone and by email.
People who fall into arrears or fail to pay their water bill
In respect to a customer’s responsibility for paying their bills, South East Water has a regulatory requirement to maintain a safe supply of fresh water to your property. In our Household Charges Scheme 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 South East Water. Our Household 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 lawyers, local authorities, the Department of Work and Pensions (DWP) and debt recovery or tracing agents, credit reference or fraud prevention agencies, in order to help us trace and collect money owed to us.
We rely on our statutory entitlements and legitimate interests to do so.
Reporting 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.
Reporting 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.
The water quality concern may need to be reported to the DWI and they may wish to contact you direct to investigate if you have made a complaint and we would be required by law to pass on your contact details to them for this purpose. The issue may also need to be reported to your local health authority or to Public Health England. We rely on our statutory entitlements and legitimate interests to do so.
Making a complaint
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 (CCWater) we will share information with them in order to resolve your complaint. This exchange of personal data with CCWater is a legal requirement under section 27B of the Water Industry Act (as amended by the Water Act 2003).
We will only use the personal information we collect to process the complaint in accordance with our complaints process. For more detail see www.southeastwater.co.uk/customerleaflets.
Making an insurance claim
If you make an insurance claim to us we will need to share the details of your claim with our insurance provider and loss adjustor. We will keep the details of the claim until it has been settled and thereafter for a period of 6 years. We rely on our statutory entitlements and legitimate interests to do so.
Developing Smarter Water Networks Trial customers
If you are a customer in our trial area for the smarter water network, the sensor on the meter will collect the meter read back at 15 minutes intervals but will only transmit this back to us on an hourly basis.
During the trial we will be using this data for the following reasons:
- Leakage detection – we should be able to locate whether the leak is in your property or on our network (and where on our network) which will help us fix it quicker. If the leak is in your property we can point you in the right direction to get it fixed. It could help us identify how to better prioritise which leak to fix first in some cases.
- Reducing the volume of water lost to leaks – if we find the leak quicker we can fix it quicker and save water.
- Stress testing the battery and telecommunications channels to make sure the devices will last as long as they say they should.
- We may talk to you as well to see if us telling you about this changes your behaviour at all. For example, does this improve customers water efficiency in any way?
- We may analyse the data to see if we can offer new services such as tariffs or usage plans to customers in the future. These would all be new opt in services that you could sign up to if you wanted.
During the trial we will also use the meter reads we collect to carry on with managing your account and providing your water services in the normal way. See our section on household customers for more information.
As this is a trial we are using the legitimate interest basis of processing as this is a key way for us to show that we can reduce the water used per person and to manage and reduce leakage in more efficient and time sensitive ways.
For more information see the Developing Smarter Water Networks Trial here.
Other types of customers
Non Household Customers
South East Water took over the management and collection of any debt incurred by non-household customers of both South East Water Choice and then Invicta Water trading as Water Choice for all debt incurred up to and including the 30th June 2018. For such processing of this debt, we will need to process your name, supply point ID (SPID), supply and billing address, and payment details or income and expenditure for payment plans. We will also be acting as a data processor for Castle Water for a transitional period to help them with any queries they may have in relation to the customers’ bills and will process customer information as so required, for example if a customer has moved away and their bill needs adjusting.
Where customers contact us for a new connection the personal information provided will be contact information and will be stored for 12 months after completion of the connection services. We will process this information for regulatory requirements in connection with providing a connection to the water supply. Developers may also be contacted for survey purposes. See 'Information we share with others'.
Bond or debenture holders
We will hold details about you until the bond or debenture has been released. We may need to use tracing companies to locate you if you have moved. Please do keep us up-to-date with your details. Any processing carried out is done so in accordance with the conditions of the bond or debenture.
Where we own property that we rent out we will process information required to manage the tenancy. This will be in accordance with the relevant tenancy agreement, therefore by way of a contract.
Farmers or land owners working with our catchment management team
Your information will only be processed with your agreement and as set out in any terms and conditions that you are provided, therefore by way of a contract.
If you are an interested party or stakeholder to South East Water, e.g. parish council, wildlife trust, local politician, neighbour to one of our sites, you will be asked to provide consent if you want to sign up to receive newsletters about our activities. We will contact you annually to check you still want to receive such updates. Please contact us if this changes and you no longer wish to receive updates.
If you have provided your details in connection with a specific scheme or project then your details will only be held in relation to that matter.
We may contact you separately in order to carry out any of our legal requirements, for example to inform you of planning permission we are seeking, advising of work to be carried out in your area, or in an emergency such as a loss of water supply.
Potential candidates for jobs at South East Water
We will process the personal information you provide to us as part of your job application and there is a separate privacy notice for this on the careers web page.
Customers of Waterlink
Where you have had plumbing or water supply pipe services provided to you by our commercial division of South East Water, called Waterlink, your personal information may be processed in accordance with the privacy notice at http://www.waterlink.co.uk/about/disclaimer.asp
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, charges and supply pipe works or leak allowances will be kept on record longer in order to feed into our water resource management plan. We will use this information at an aggregated level for business planning purposes.
Information we collect or obtain from others about you
We may receive or collect information about you from others when we are confirming whether properties are empty or are in actual fact using our water. To save us having to do this please ensure you notify us as soon as you move into or take responsibility for a property.
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.
Landlords and Housing Associations
In many cases we are supplied your details from your landlord or housing association which will include the date that you moved into the property. In cases of social or council run housing schemes this may also include information you have provided to them about income for example if they are recommending to us that you may need help paying your water bills.
Many landlords use ‘Landlord TAP’ which is a website that allows Landlords and Managing Agents, of residential properties in England & Wales, to provide water companies with details of those responsible for the payment of water and/or sewerage charges for their tenanted properties.
Information we share with others
We manage all arrangements for sharing your data with the strictest of care and would never sell your data to be used for marketing purposes.
The obligations that we have to our regulators
To comply with our legal and regulatory obligations we may provide personal data to the following authorities:
- Drinking Water Inspectorate
- Environment Agency
- Natural England
- Public Health England
- Environmental Health Authorities
- Local Authorities
- Police, Fire, Ambulance, and other emergency services
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 the Health and Safety Executive or the Environment Agency if it is part of the reporting requirements.
Obligations to share with your Waste Water providers
We have legal requirements for sharing data with your waste water companies Thames Water and Southern Water who operate in our supply area.
We also undertake additional data processing on their behalf by billing for them at the same time that we bill your water charges. We have data processing agreements in place with both Thames Water and Southern Water for this.
We also share information such as whether a property is connected to mains water supply for the purposes of land and drainage searches undertaken with waste water providers in connection with sales and purchases of properties for example CON29 Land and Drainage searches.
Agreements we have with other organisations for sharing information
We have in place some data sharing agreements for mutual benefits. For example, we have data sharing agreements with some housing associations to help keep our customer data accurate. This may involve names and addresses of customers.
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
Sometimes 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 Data Protection Requirements, we are permitted to share this data with them in the support of the prevention and detection of crime without your consent and you will not be notified that this has been done.
Ofwat surveys (customer service - “SIM”; C-Mex and D-Mex”)
All household customers and developers 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 regulating customer service in the water industry in England and Wales. You may be contacted by this third party about the service you received from South East Water and asked to score our performance. This is not a marketing call and your response is very important to us and Ofwat. As our water regulator we are permitted to share certain details with them, however, if you would rather we did not do this then please let us know. The results of these surveys may be stored with your water account.
We may use third parties, or our own employees, to help contact our various types of customers to undertake water consumption surveys to inform our water resource management plan or for customer satisfaction or customer engagement processes. These are not marketing calls 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 general communications in relation to your account. The results of these surveys are not stored on your water account but are instead used by our customer engagement and water resources team to look at improving engagement or planning resources in the area.
We may also contact you to undertake a survey after you have been in touch with us so that we can find out how satisfied you were with the service you received. The results of this survey will be stored on your water account. We may contact you after this to see if we can improve our service to you.
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 divest a part of our business or carry out internal corporate restructuring, your information may be disclosed to South East Water's new business partners or owners or the new corporate entities.
In the event that we sell or buy any business or assets we may disclose your personal data to the prospective seller or buyer of such business or assets.
If South East Water Limited, or substantially all of its assets, are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.
We may be required to share your personal information with others as required by law, for example for fraud prevention.
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. Our contracts detail how personal data should be handled and protected while being processed by any third party. We conduct due diligence checks on third party processors to ensure they comply with their obligations to us.
We use software providers for different systems, like our billing system, works order system, and meter reading system, to support us with the large amounts of data that we need to manage. We use companies to assist us with printing bills and customer communications and 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 companies to assist us with 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 our commercial arm, Waterlink (which is still South East Water) 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 Waterlink 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.
South East Water also uses a trusted partner service to help maintain the security and performance of the South East 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 subject to strong cyber security measures. All access to our systems is strictly controlled. 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 seven years after the account has been closed. We hold call recordings for six months, unless it is required for a legal case in which case it will be kept for the length of the legal case.
It is our responsibility and legal duty to promote water efficiency. We use a number of methods, including direct marketing on occasion. This may include promoting products and services we provide. We may engage with a third party to provide this service on our behalf.
We work with:
- Save Water Save Money who helps us promote water efficiency products to our customers.
- Advizzo in relation to a pilot for reducing water usage in the home where customers can receive a detailed water usage report and recommendations as to how to reduce their usage.
- Homeserve who promote supply pipe insurance to help us ensure customers are equipped to manage leaks in their properties to help us reduce leakage
We also on occasion promote WaterAid, a charity that was set up by the water industry to promote clean drinking water for all.
Such activities will be in accordance with our legitimate interests. However if you wish to exercise your right to object to such marketing please contact us.
Automated decision making and profiling
We do not currently conduct any automated decision making, including profiling, as defined by the Data Protection Requirements.
Your data protection rights
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 of your request. There is no charge made for this by South East Water.
To make a request to South East Water for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer, contact us using the email 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 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.
To exercise any of your rights please contact us at firstname.lastname@example.org
Changes to this privacy notice
This privacy notice will be kept up to date as our business and internal practices and/or the Data Protection Requirements 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 Data Protection Requirements
We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018.