Privacy

This Privacy Notice is designed to explain how we collect and use our customer’s personal data. Bristol Water plc (Bristol Water) is committed to protecting our customer’s data, uphold their data rights, and meet their expectations for handling personal data.

The Notice is designed to be easy to use and understand, if you have any concerns or would like more detail please follow the instructions under ‘Contact Us’.

What is Bristol Water?

Bristol Water is a water-only company and a statutory water undertaker supplying customers in the Bristol and South West area. We are part of the Bristol Water group, which the simplified diagram below explains:

Bristol Water Group Structure Diagram

We may share your personal data across these group companies. Bristol Wessex Billing Services (also known as BWBSL or Pelican Business Services) is a joint venture company with Wessex Water Services Ltd, and provides billing and certain customer services functions for us. For more details please see the ‘Who we share your data with’ section.

We are a registered data controller, registration number: Z5277208. This means it is our responsibility to maintain and protect all personal data that we collect and ensure that anyone we share personal data with will also adequately protect that data.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for monitoring our compliance with data protection legislation. To contact the DPO please see the ‘Contact Us’ section.

What personal data we collect

We will always endeavour to make clear why we are collecting your personal data at the time.

Information you give us
We will collect your personal data whenever you fill in a form, contact us (including by social media), pay us, request a service, provide feedback, or enter a competition or survey.
Information you provide us may include:

  • Account and card details – account number and sort code, account holders name, direct debit details
  • Contact details – postal address, email address, mobile or landline numbers
  • Personal details – name, date of birth

For certain customers we might ask for health information too. This is where a health condition could impact your usage, for example requiring an above average use, or needing a constant supply. We will use the health data to assess requirements and ensure we provide the services required. We will only ever do this with your explicit consent, which can be withdrawn at any time.

Information we collect
We record all phone calls, incoming and out-going, made by departments that deal directly with customers, including Operation Customer Service, Meter Options, and Wholesale Services.
While providing a service we may collect data about you. By reading your water meter we will collect water usage information.
Whenever you visit our website we use cookies that will contain personal information, for more detail please see the ‘Web cookies’ section.

Information provided by other sources
For non-household (business) customers, we may receive information from your retailer such as supply or contact details.
We occasionally use analytics providers in order to get a better understanding of our customers’ lifestyle and water consumption habits. This assists us in understanding our customers, tailoring our services, and providing relevant information such as water efficiency advice and products. Where possible, this will be aggregated, pseudonymised, or anonymised data.

In 2016 we purchased landline phone numbers for our customers from GB Group plc. This was to improve our ability to proactively contact our customers. Since 2016 we have only collected phone numbers from customers directly.
Some health information relating to our customers is collected by local NHS Trusts and then passed to us. We will only use this information with your explicit consent, which can be withdrawn at any time. The reason for obtaining this information is where a health condition may impact your water usage, for example requiring an above average use or needing a constant supply. We will then use the health data to assess requirements and ensure we provide the services required.

Purpose for collecting your personal data

We will only collect data where we have a clear and legal basis to do so. The table below explains each legal basis we use, with a more detailed description of the purpose alongside it:

Legal Basis Purpose
Legal Obligation To meet our obligations under:

  • Water Industry Act 1991
  • Water Resources Act 1991
  • Environment Act 1995
  • Water Industry Act 1999
  • Water Act 2014
  • Water Supply (Water Fittings) Regulations 1999
  • Water Supply (Water Quality) Regulations 2016
  • Instrument of Appointment as issued by the Secretary of State for the Environment
Legitimate Interests
  • Provide water supply services and products
  • Administer a customer’s account, including billing, requests, enquiries, and complaints
  • Contact our customers about service related issues, including interruption to supply, planned maintenance, roadworks, and water quality
  • Make goodwill, bond, and compensation payments
  • Communicate with you about products and services we provide, including water efficiency measures
  • Carry out and analyse customer surveys
  • Carry out staff training and quality assurance
  • Use aggregated data to understand customer trends in lifestyle and water consumption, and to assist in business planning
  • Comply with any regulatory obligations we may have
  • Ensure we operate to the expectations of a responsible water company
  • Handle responses to public consultations, such as our Drought Plan
  • Maintain our land holdings and sites
  • Keep our records accurate and up-to-date
  • Carry out credit checks (for more information see the ‘Credit checks’ section)
  • Prevent and detect crime, including fraud
Consent
  • Assess eligibility for a social tariff based on health or financial circumstances
  • Assess and provide operational and service requirements based on health circumstances

These purposes may be executed by us or one of our third party service providers.

Who we share personal data with

We are required to share personal data with multiple parties for legal, regulatory, and operational purposes. We have contracts in place with all third parties with whom we share data. 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 will not sell your data to be used for marketing purposes.

Service providers

Name / Category of Service Provider Processes
Bristol Wessex Billing Services Limited (t/a Pelican Business Services) Read meters, send out bills, handle billing enquiries, process payments, and account management
Wipro Limited Our IT services provider. They have access to all our systems and data.
Network Maintenance Contractors (including Kier Integrated Services Limited) Perform network maintenance, including street works and responding to water supply incidents, provide priority services to ‘vulnerable’ customers.
Self-Lay Providers Making new supply connections at development sites
Housing Associations and Landlords Water regulations inspections
Land Agents Managing our land and property, and obtaining land rights
Customer Services Support Handle large scale call volumes during water supply incidents, and provide software for live chat featured on our website
Social Media Platforms Responding to enquiries and complaints
Customer Survey and Feedback Services Carry out and analyse surveys and feedback results
Mgage Europe Limited SMS text alert system during water supply and water quality incidents
Credit reference agencies Carry out credit checks
Debt recovery companies (including Searchlight Collections Limited) Collection of unpaid charges
Insurance providers Managing litigation and compensation claims
Auditors Provide assurance for business processes and decision
External Legal and Professional Advisors Obtaining legal advice, managing disputes, and compensation claims
Other water companies

All of our domestic (household) water supply customers receive sewerage services from Wessex Water Services Limited. We share certain customer data with Wessex Water for billing purposes and to assist customer services. Water consumption information is shared so that Wessex can calculate waste water use. Contact details are shared to maintain accurate data. Details of any ‘vulnerable’ customers are shared to ensure both companies provide priority services. Information is usually shared between us and Wessex Water via our jointly owned billing company, Bristol Wessex Billing Services Limited.

Wessex Searches (trading name of Wessex Water Enterprises Limited) is a subsidiary of Wessex Water Limited. We provide customer information to Wessex Searches for the purpose of providing CON29DW searches to house buyers.

For non-household customers, we must share customer data with the non-household customers’ retailer as we do not have a direct relationship with these customers. This includes water supply information, details of any contact between us and a non-household customer, and information relating to water supply incidents. What information we share and how it is shared is governed by the Wholesale-Retail Code. Water 2 Business is a retailer and is part of the Bristol Water group (it is a joint venture with Wessex Water Services Limited). We share data with Water 2 Business in the same manner as with any other retailer.

Legal and regulatory authorities

To comply with our legal and regulatory obligations we may provide personal data to the following authorities:

  • Defra
  • Ofwat
  • Drinking Water Inspectorate
  • Environment Agency
  • Public Health England
  • Environmental Health Authorities
  • CCWater
  • WATRS
  • MOSL
  • Local Authorities
  • Police, Fire, Ambulance, and other emergency services

All customers who contact us may have their contact details passed to a third party working on behalf of Ofwat as part of the Service Incentive Mechanism (SIM) survey. The SIM survey is one of the tools Ofwat uses to regulate water companies, and Bristol Water is obliged to share this information as part of our Instrument of Appointment. Bristol Water also conducts a replica survey in order to improve responsiveness and efficiency.

We may also be required to share personal information if required to do so under court

Transfers outside of the European Economic Area

Currently, we only uses one data processor based outside of the EEA. Wipro Limited has personnel based in India and may process our held data in India. A strict data processing agreement is in place to ensure both we and Wipro follow all data protection law as applicable in the UK.

How long will we retain data for?

We have a data retention policy. Data will be retained as long as it serves a useful and legitimate purpose and taking into account all legal and regulatory obligations.

The following general principles have been applied, although there may be exceptions to these principles:

  • Customer data – 6 Years
  • Regulatory information – relevant business planning period (maximum 5 years), or 10 years for formal regulatory submissions
  • Financial information – 7 years
  • Any information that may be relevant to existing or future legal proceedings – 6 years
Direct marketing

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 will never sell your data to third party marketing companies.

Automated decision making and profiling

We do not currently conduct any automated decision making, including profiling, as defined by data protection legislation.

Web cookies

Our website uses cookies to store small amounts of data on visitor’s computers and devices. Cookies are typically used to improve functionality and relevancy of information.

The following cookies are used on our website:

Name Purpose
PHPSESSID Session cookie used to establish a user session. It is used on a temporary basis and disappears when the session is closed
catAccCookies Used to record whether use of cookies has been accepted
wp-settings-[number] WordPress Cookie. The number on the end is your individual user ID from the users database table. This is used to customise your view of the admin interface, and possibly also the main site interface
wp-settings-time-[number] WordPress Cookie. The number of the end is your individual user ID from the users database table. This is used to customise your view of the admin interface, and possibly also the main site interface

Browser settings can be used to block and remove cookies. For more information please contact your internet browser provider.

Credit checks

All customer billing, credit checking, and debt recovery is managed by Bristol Wessex Billing Services Ltd on our behalf, who in turn may use credit reference agencies. Credit reference agencies are used to verify the accuracy of our data, check debt risks and inform debt management decisions.

Data subject rights

We recognise customer rights under data protection legislation:

  • Right to be Informed – customers are entitled to know how their data is processed. This notice is designed to provide an overview of all processing activity. If more specific detail is required please contact us by the details provided below.
  • Right to Access – customers can access their data via a Subject Access Request, for more information please see our Customer Subject Access Request Policy here
  • Right to Rectification – if customer data is found to be inaccurate we are under an obligation to correct it. This may be done by contacting Customer Services by the details provided below.
  • Right to Erasure – customers have the right to be forgotten. Personal data shall be deleted where there is no longer a legitimate purpose to the data processing.
  • Right to Restriction on Processing – We have processes in place to restrict processing where there is a legitimate objection.
  • Right to Data Portability – Where applicable, we have processes in place to allow data portability to another data controller.
  • Right to Object – if a customer objects to the processing of their data under legitimate interests they have the right to raise an objection, which will be appropriately considered by us.
  • Right to not be subject to automated decision making – customers have the right to have automated decision making to be reviewed by our personnel. We do not use automated decision making at the moment and will inform customers if our policy changes here.
Contact Us

If you have any questions in relation to this notice please get in contact.

Operational Customer Services,
Bristol Water plc,
Bridgwater Road,
Bristol
BS13 7AT
customer.services@bristolwater.co.uk
0345 702 3797
or Data Protection Officer,
Bristol Water plc,
Bridgwater Road,
Bristol,
BS13 7AT
Colin.Caldwell@bristolwater.co.uk
0117 934 1108
Complaints

if you have any complaints in relation to this notice or our use of customer data you may contact us at the above address.
Customers are reminded that they have the right to object to the processing of their data that relies on the legal basis of legitimate interests, including (but not limited to) legitimate business interests, marketing, profiling, or research. All requests will be evaluated on a case-by-case basis.

Alternatively you can complain to the Information Commissioner’s Office at ico.org.uk or call their helpline on 0303 123 1113.

Updating this Policy

We may change this notice from time to time. We encourage all customers to periodically check this policy on our website to ensure they are aware of the most recent version.

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