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:
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 We will only ever do this with your explicit consent, which can be withdrawn at any time.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.
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 Obligation||To meet our obligations under:
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.
|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:
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
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.
The following cookies are used on our website:
|PHPSESSID||Session cookie used to establish a user session. It is used on a temporary basis and disappears when the session is closed|
|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.
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.
If you have any questions in relation to this notice please get in contact.
|Operational Customer Services,
Bristol Water plc,
0345 702 3797
|or||Data Protection Officer,
Bristol Water plc,
0117 934 1108
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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