Severn Trent Privacy Notice
Severn Trent Water Limited ("STW") published an updated privacy notice ("Notice") to inform you how they process your personal data and the rights you have in relation to that processing.
Last updated: July 2024
Severn Trent Water Limited is a registered company in England and Wales with a registered office at Severn Trent Centre, 2 St John's Street, Coventry, CV1 2LZ with a registration number of 02366686 ("STW"). STW is a provider of water and wastewater (sewage) services and provides access to recreational visitor sites across the Midlands of the UK. Any reference to “we” or “us” in this Notice means STW.
We are publishing an updated Privacy Notice ("Notice") to make it easier for you to find out how we use and protect your personal data that we process. If we make any changes to this Notice, then we will update the effective date below. If we make any material changes to this Notice, then we will post information about it on our website and, where possible, we will endeavour to notify you via email.
If you have any questions about this Notice, please contact us as set out in Section 2 "How do you contact us" of this Notice.
The purpose of this Notice is to inform you about how your personal data is processed by STW and the rights that you have in relation to the processing of your personal data by STW. Please read this Notice carefully and ensure that you understand how STW will deal with your personal data.
This Notice makes it easier for you to find out how we use and protect your information within STW. This Notice provides you with you details such as those in the following non-exhaustive list:
You can also view our:
STW is a data controller for any of your personal data that you supply to STW or which we collect, which may be in the course of your use of the STW website, in connection with your application for an account or your receipt of products or services from us, or in your other dealings with STW. Please note that STW has other privacy notices in place to inform other categories of data subjects about how we process their personal data, for example, we have a dedicated privacy notice that is specific to STW employees.
Being a data controller means that we are responsible for deciding how we hold and use personal data about you. As a data controller, STW takes the security and use of your personal data very seriously and wants to do so in compliance with the Data Protection Act 2018 ("DPA 2018") and the UK General Data Protection Regulation ("UK GDPR") and any other applicable data protection and direct marketing laws. As a data controller, we also use several external third parties to process your personal data on our behalf, and some of these third parties are commonly referred to as ‘processors.’ We require that our processors process your personal data in line with this Notice. For further details, please see Section 7 "Who do we share your data with" of this Notice.
If you have any questions, concerns, or would like more details about how we use your personal data, please contact us via one of the contact methods set out below:
How to submit a Data Subject Access Request ("SAR")
To request copies of your personal data you can use either our Online Subject Access Request form or complete our Subject Access Application PDF form. Alternatively, you can also submit a SAR via any of the other contact methods listed in this Section 2 of this Notice or email us at customerSAR@severntrent.co.uk.
For further details about your rights in respect to accessing the personal data that we process about you, please see Section 11 "Your data protection rights" of this Notice.
We collect the following types of personal data from any contact that we have with you by telephone, letter, e-mail, WhatsApp, facsimile, when visiting your home, Web chat service, Mobile Application, our Contact Us forms and via social media like Twitter and Facebook or even face to face at one of our sites.
Please refer to table 1 in Appendix 1 of the Notice for further details and a list of the different categories of personal data that we process about you.
We will only request special categories of personal data from you where we believe it will help us to manage your account in the best way for you and to ensure that we can respond to your needs during an incident should one occur. Scenarios in which we may request your special category data are:
We will process this data in line with the UK GDPR under the lawful basis of ‘public task’ for personal data and necessary for reasons of either ‘employment, social security and social protection’ or ‘substantial public interest’:
You can find more details on special category data transfers in Section 8 "Sending data outside of the UK" of this Notice.
We collect your personal data in a number of ways, for example:
We may also access or request information about you that is available to us from organisations or third parties such as credit reference agencies, fraud prevention organisations, land registries, local councils or other Government departments to ensure we can charge you for our services, offer you access to our financial assistance schemes or priority support services during an incident.
We use your information in various ways, such as to:
To process your personal data, we must have a proper reason and a legal ground under UK GDPR to do so. The table 2 at Appendix 2 of this Notice sets out
Here we provide a general explanation of each 'legal basis' that STW relies on to process your personal data to assist you with understanding the information in table 2 at Appendix 2 of this Notice:
As part of normal operations, we engage third party contractors to provide us with services, for example, if you call us to inform us about a leak or a blocked sewer, we may use contractors to investigate the issue. Where we use third party contactors, we may need to give your personal data to them, for example, to investigate the issue and inform you of the outcome.
We may also share your personal data with other third parties because we are under a legal, statutory or other obligation to do so or because we believe that sharing your personal data will help us to manage your account in the best way possible for you.
We may share and collect your personal data with the following parties:
If you opt into using your social media credentials to access our web self-service, please review the appropriate privacy policy to understand how these companies will use your data and your rights.
Like many other utilities companies, we share your personal data with, and receive your personal data from, Credit Reference Agencies (CRAs). This helps us maintain up-to-date customer records, prevent fraud and identify customers at risk of falling into debt. This makes it easier for us to find and help customers who need financial assistance. This helps us manage debt levels and, in turn, keep prices lower for all customers. If you pay your bill on time, the fact that we share your data with the CRAs will also positively impact your credit rating.
We will share your personal data with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time.
The CRAs may give this information to other organisations that want to check credit status. If you tell us that you have a spouse or financial associate living at the same property, we will link your records together.
CRAs will also link your records together and these links will remain on your file and theirs until either you or your partner successfully applies for a disassociation with the CRAs to break that link.
You can find out more about the CRAs on their websites, in their Credit Reference Agency Information Notice. This includes details about:
Credit Reference Agency Information Notices ("CRAIN") for the two Credit Reference Agencies we use are listed below:
We will only send your personal data outside of the United Kingdom to:
If we do transfer personal data to our agents or advisers outside of the UK, we will make sure that it is protected in the same way as if it was being used in the UK. We will use appropriate safeguards such as those set out in the non-exhaustive following list:
Sometimes we will need to share your personal data with third party data processors in countries that are outside of the United Kingdom that do not have an adequacy decision, for example: we have a third party supplier that is based in India or South Africa.
In these instances, we will put adequate safeguards in place to ensure that your data receives the same level of protection as if it were being processed in the UK. Please see the following non-exhaustive list for some examples of these safeguards: 1) appropriate training; 2) regular auditing; 3) security checks; 4) contractual terms in place; 5) conduct transfer impact and transfer risk assessments; and 6) appropriate security measures.
We will take appropriate technical and organisational measures to prevent unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data:
We keep your personal data for only as long as necessary to provide you with the services and for the purposes described above. This means that we will keep different types of your personal data for different periods of time (so called 'retention periods'), depending on its sensitivity and the purpose for which we have collected the personal data in the first place. However, we do not expect to keep your data for longer than 7 years after we stopped processing it.
If you are our customer, we will keep your personal data for as long as are one. After you stop being a customer or if you have visited one of our sites, we may keep your data for up to 7 years for one or more of these reasons:
We will keep your data for longer than 7 years where required for legal and regulatory purposes. We will also keep it for research or statistical purposes e.g. your water consumption to help us manage our network efficiently. If we do, we will make sure that your privacy is protected and only use it for those purposes.
Below we have listed the retention periods that may apply to the personal data we process about you:
Once the purposes for which we collected and processed your personal data are no longer relevant and your data does not need to be retained, we delete or dispose your data safely and securely. The method of disposal varies and is dependent upon the nature of the personal data. For example, any documents that contain sensitive personal data must be disposed of as confidential waste and be subject to secure electronic deletion. If the data is held electronically, the original record and any backup/archives of the record must be removed from our systems from on premise storage or in the cloud. In the case of physical documents, they are disposed by using a high grade crosscut shredder. Electronics are disposed of through Information Security. In addition, we put in place appropriate controls that prevent to the extent possible the permanent loss of essential information as a result of malicious or unintentional destruction of information.
As part of our green recovery efforts to transform our business and the wider water industry, we want to give you the most up to date information about your water usage through the use of smart meters. It will also allow us to help you use water more efficiently through identifying leaks more quickly and trial new ways of managing peak demand.
We are currently rolling out smart meters across the Severn Trent catchment area. If you apply for a free meter installation or are due to have a meter replaced in one of these areas, a smart meter will be fitted at your home. Your installer will inform you that a smart meter is being installed.
What is a ‘smart’ meter?
We use Advanced Metering Infrastructure (AMI) meters, which gives us the ability to collect granular data about your usage without the need to send out a meter reader to your property. Meter reads will be taken either on an hourly basis, but some meters provide us the ability to record your usage every 15 minutes between 2-5am – this is to help us understand leakage in more detail. Customers then have the option to view their hourly consumption online by signing into a Web Self-Serve account.
What smart meter information do we collect?
We collect:
How often do we take smart meter reads?
Our smart meters will show the data back to customers on an hourly basis through the My Smart Tracker web page, which is part of our online ‘My Account’ service.
For what do we use the smart meter readings?
Meter readings are used to detect potential leakage and to encourage lower water consumption. We will only use the meter readings to bill you for the water you’ve used if this is how you pay. Your bill type will not change unless you request this.
We will use hourly readings for a number of different activities:
What is our legal basis for processing your smart meter data
Please see further details at table 3 at Appendix 3 of this Notice.
Do you share my smart meter data with anyone?
We will use your consumption data to identify a potential problem with your supply such as a leak. As a result, we may ask a third party contractor to visit your property to investigate. Please see Section 6 "How we use your data and what is our Legal Basis for processing" of this Notice for further detail on who we may share your personal data with.
Who can I contact if I have an issue or want to object to processing?
If you did not wish to receive your monthly consumption report, then please contact us using details noted in Section 2 "How do you contact us?" of this Notice.
You have a choice about how smart meter data is used apart from where we require it to bill you for our services or for any other legal or regulatory purpose. We can access your daily data unless you object to the processing of this personal data (to learn more about your rights, see Section 11 "Your data protection rights" of this Notice).
Under the UK GDPR you have rights. Please see below for more details. For business customers, please see also Section 12 "Non-household/business customer data processing" of this Notice.
For each you can follow the steps in Section 2 "How do you contact us?" of this Notice. These rights are in some circumstances subject to exceptions. Your rights include:
Your right to be informed - You can ask for details of how we process your personal data, as covered by this Notice.
Your right of access - You have the right to ask us for copies of your personal data. You can request a copy of the data we hold about you or ask us about how STW processes your personal data. You can do this by following the steps in Section 2 "How do you contact us?" of this Notice.
When submitting a SAR, please follow the instructions provided. Note that our process of compiling a SAR does not include a review of any ongoing issues and does not form part of the STW complaints process.
Also, you can make a SAR on someone else's behalf. However, when you make such a request, you will need to provide us with confirmation of your authority to do so.
We can refuse to provide the requested information only if an exemption or restriction stated in applicable data protection law applies or if the request is manifestly unfounded or excessive.
STW Water is not covered by the Freedom of Information Act 2000, however, you can request certain types of information under Environmental Information Regulations ("EIR") 2004. For further details in respect to EIR, please see our dedicated EIR page.
Your right to withdraw consent - Where we rely on consent to collect and process your personal data for a specific purpose, you have a right to withdraw your consent for that specific processing at any time. However, withdrawal of the consent does not affect the lawfulness of prior processing. To withdraw your consent, please contact us at the details in Section 2 "How do you contact us?" of this Notice.
Your right to rectification - You have the right to ask us to rectify any personal data we have about you that you think is inaccurate and to complete data you think is incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
Your right to erasure - You can request the deletion or removal of personal data where there is no reason for us to keep it or process it (for example, when you effectively objected to the processing of your data, where we may have processed your data unlawfully, where you withdrew your consent for processing of your data or where we are required to erase your personal data to comply with applicable law). This right is also known as the “Right to be Forgotten.” However, when personal data is processed based on a legal obligation or where we have an overriding legitimate interest, we might need to keep or use your data. In such a case, we will notify you about as soon as possible.
Your right to object to processing – When we process your personal data on a legitimate interest's basis, you can request that your personal data is not processed for specific purposes. Sometimes, we may demonstrate that we have compelling legitimate grounds to process your personal data that override your right to object. However, you always have the right to object at any time to the processing of your personal data for direct marketing. Please note that, in some cases, when the processing is essential for us to provide you with our services, if you object to us processing your personal data then we may not be able to continue to provide you with those services. In addition, where your explicit consent is required for us to process special category data and you decide to withdraw your consent, then we may also not be able to continue to provide you with our contractual services.
As a statutory undertaker we have a duty to promote efficient use of water and encourage customers to dispose of waste appropriately. We may send you information leaflets or emails or make you aware of products that help with this.
To help us to do this, we may share your information with carefully selected partners (described further in Section 7 "Who do we share your data with" of this Notice) who offer services or products that we think you may be interested in.
If you do not want to receive such offers at all, please let us know – you can contact us using the contact details in Section 2 "How do you contact us?" of this Notice.
Your right to restriction of processing – in certain circumstances you can request that no further processing of the personal data we have previously collected occurs. When we restrict the processing, we can store your personal data, but we will not use it. You can ask us to suspend the processing of your personal data when: (i) you want us to establish the personal data's accuracy, (ii) where our use of your data is unlawful but you do not want us to erase it, (iii) where you need us to keep your data even if it is no longer required to establish, exercise or defend legal claims, or (iv) where you objected to our use of your personal data but we need to check whether we have overriding legitimate grounds to use it.
Your right to data portability - In certain circumstances, you can request that we transfer personal data that you have provided to us to another organisation or directly to you We will provide your personal data in a structured, commonly used, machine-readable format. However, please note that this right applies only to automatically-processed personal data for the processing of which you have consented to or where the processing is necessary to perform a contract with you.
Automated decision-making and profiling – please note we do not currently conduct any automated decision-making, including profiling, as defined by applicable data protection laws.
About your rights
Please note that the rights described above are not absolute and the DPA 2018 and the UK GDPR set out exemptions from some of the rights and obligations in some circumstances. When we rely on them, we justify and document our reasons for doing so. If you wish to learn more about the exemptions, please check the guide to the data protection exemptions on the ICO's website.
You are not required to pay any charge for exercising your rights, although we reserve the right to charge where the UK GDPR allows us to do so. In most cases we will not charge you with a fee to comply with your requests, however, we can impose a reasonable fee for the administrative costs of complying with the request if it is manifestly unfounded or excessive or when you request further copies of your data following your request.
If you make a request, we will respond to you no later than one calendar month. However, we can extend the deadline to an additional two months under certain circumstances (e.g., when your request is complex or when you make more than one request). We will communicate to you if we decide to extend the deadline.
Please be aware that there may be circumstances when we are unable to complete your request, most likely because we could not provide you with water, waste water or billing services. If this is ever the case, we will inform you of the reason and provide details of how you can register a complaint with the Information Commissioner's Office (please see Section 13 "Contacts, queries and complaints" of this Notice) if you believe we have got this wrong.
For business customers, the market opened on 1 April 2017 for water supplies to business users, enabling businesses to switch providers and is run by Market Operator Services Limited ('"MOSL"). To facilitate this, we may share details of contacts at our business customers with MOSL and third party service providers where required.
Find out more information on MOSL.
Data protection laws are applied to non-household/business customers only to the extent that we process personal data of individuals (e.g., personal data of sole traders or company representatives). For further details, please refer to Section 11 Your data protection rights of this Notice.
Please note that if you are a non-household/business customer, you may exercise your right to request your data through either your wholesaler or retailer. If you wish to make a request to us as your wholesaler then please email us at WMUDSRR@severntrent.co.uk.
If you have any further questions about the way we manage your personal data or if you are unhappy with how we have used your personal data, you can always contact us. Our contact details are in Section 2 "How do you contact us?" of this Notice.
If you have any concerns about how we use your personal data, you can contact us directly using the details above. You can also complain to the ICO if you are unhappy with how we have used your data (please see the contact details below). We are always willing to help you with any issue, so we would appreciate the chance to resolve your complaint before you complain to the ICO and encourage you to contact us first before you choose to contact the ICO.
The ICO’s contact details are listed below:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk
You may from time to time receive information about special offers and promotions in respect to water related services or products in which we believe that you may be interested. Furthermore, we may also contact you to follow up on an enquiry that you have made to us about our products or services or to contact you about specific projects or campaigns that you have consented to receive information about. We may send these direct marketing communications by either letter, telephone, e-mail or via any other contact details that you have provided to us.
If you do not wish to receive such information, you may unsubscribe at any time. Depending on the mode of communication, you may unsubscribe by either clicking the “unsubscribe” link at the bottom of our emails or you can update your communication preferences in your account settings. In addition, you can also object to our direct marketing or withdraw your consent to receive such communication by contacting us via the contact details set out in Section 2 "How do you contact us?" of this Notice.
For further information about your rights in relation to any direct marketing sent by us, please refer to Section 11 "Your data protection rights" of this Notice.
| Category of personal data | Description of personal data |
|---|---|
| Personal data that we collect about you when you are our customer or visitor to our sites | |
| Contact information |
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| Transaction information |
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| Identification information |
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| Legal information |
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| Demographic information |
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| Special category data |
For further details about how we process special category data, please refer to Section 4 "Special categories of personal data" of this Notice. |
| Criminal offence information |
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| Observed and security information |
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| Communications |
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| Voluntary information |
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| Personal data that we collect about you when you are using our website | |
| Preference information |
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| Communications |
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| Website and device information |
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| Geolocation information |
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| Cookies and third-party technologies | For more information about cookies and third party technologies, please see our Cookie Policy. Please note that you can update your cookie preferences whenever you visit our site by accessing our cookie preference page. |
| Personal data we collect about you from other sources | |
| Third party payment providers, third party payment companies and other third party contractors |
|
| Our regulators (including Ofwat), authorities and third parties (including Department for Food, the Environment and Rural Affairs (Defra), and the Drinking Water Inspectorate (DWI) |
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| Relevant authorities and law enforcement |
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| Social services, charities and other third parties |
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| Credit reference agencies |
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| Selected partners |
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| HomeServe Membership Limited (our affinity insurance partner) |
|
| Purpose of processing | Legal basis | What personal data do we use? |
|---|---|---|
To provide you with services under contract We collect your personal data to provide you with our contractual services, e.g. car park permits and mobility scooters at our visitors' sites or any work you ask STW to undertake on a private asset such as a new connection into our network or a lead pipe replacement. |
Non-special category data
Special category data
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To confirm your identity We collect data to verify who you say you are. To comply with law, to provide information to relevant authorities, to report information to our regulators We collect data to keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws, to provide information to law enforcement agencies, other authorities or members of the public where we are required to do so by law, to report key performance information and other data to our regulators (Ofwat, DWI and the EA) in line with our statutory licence conditions and/or the legislation noted above and to help us manage our network to meet customer demand in line with our statutory licence conditions. For our Critical National Infrastructure (CNI) sites, which are vital for the country and daily life, the Centre for the Protection of National Infrastructure (CPNI) and DEFRA stipulate the use of Visual Security Systems. To detect leaks and monitor water usage We collect data to detect leaks on both our assets and homeowners. Where the leak is on your asset, we will notify you as required by section 75 of the Water Industry Act 1991. We also collect data to monitor your water usage through the use of smart meters (for further information concerning this purpose, see Section 10 "Smart meters" of this Notice). |
Non-special category data
It is in our interest to verify your identity, in order to protect our business and to comply with the laws that apply to us. Special category data
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To manage customer accounts and our network assets We collect data to keep customer records, customer care, debt related activity and other interactions including compensation, for our internal business administration, and to protect customers and our business from fraud to minimise the risk of false details being used, and abuse by fraudsters. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions. |
Non-special category data
It is in our interest to protect both STW and you from fraudulent activities and operate our business administration efficiently. |
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To provide you with operational and service requirements We collect data to provide you with operational and service requirements based on health circumstances or financial circumstances, where applicable. |
Non-special category data
It is in our interest to fulfil effectively our legal and contractual duties. Special category data
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To contact you and send you direct marketing We collect data to manage any customer service surveys, to contact you regarding service related information about products, services and offers we think you may be interested in and to send you direct marketing for water related products and services. |
Non-special category data
It is in our interest to market and advertise our services and provide customer care. |
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To provide you with the highest quality of service We collect data to provide you with the highest quality of service through the use of call recordings etc. for training purposes, to ensure compliance with our policies and procedures, for security purposes and for any lawful purpose. |
Non-special category data
It is in our interest to improve the quality of service and products we provide and fulfil effectively our legal and contractual duties. |
|
To monitor your water usage and promote efficient use of water We collect data to promote efficient use of water, encourage customers to dispose of waste appropriately and prevent damage to our network, we may send you information leaflets or emails or make you aware of products that help with this on behalf of our partners, HomeServe, who have been carefully selected to provide access to affinity insurance products for our customers, which can help in the event of water related problems. We also collect data to monitor your water usage through the use of smart meters (for further information concerning this purpose, see Section 10 "Smart meters" of this Notice). |
Non-special category data
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To perform our public functions and provide you services related information We collect data to perform public functions in the Public Interest for personal data, and necessary for reasons of Substantial Public Interest (SPI) for special categories of data (health data) and to provide you with operational and service requirements based on health circumstances or financial circumstances, where applicable. We also collect data to provide you services related information for example: water efficiency information or waste ‘fats, oils and greases’ campaign information in line with our duties as a statutory water and waste undertaker and to help us manage our network efficiently. |
Non-special category data
Special category data
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To contact you and send you our direct marketing communications We collect data to contact you about specific projects or campaigns that you have consented to e.g. our river pledges campaign, to use your social media credentials to log into your Web Self Serve account. If you opt into using your social media credentials (Facebook, Google or Apple) to use with our web self service and to send you direct marketing communications (including competitions and promotions). As part of promotional material for our visitor sites we may ask to use your image. Please remember that you can withdraw your consent at any time, as described in Section 11 "Your data protection rights" of this Notice. |
Non-special category data
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| Purpose of processing | Legal basis | What personal data do we use? |
|---|---|---|
To charge you for water consumption, manage our network, detect leaks, report obligatory information to regulators and keep records required by law We collect data to charge you for your water consumption. We also collect data to manage our network to meet customer water supply demand in line with our statutory licence conditions, to detect leaks on both our assets and homeowners. Where the leak is detected on your asset, we will notify you as required by section 75 of the Water Industry Act 1991. In addition, we collect data to keep records required by law or to evidence our compliance with laws, including applicable tax laws, consumer protection laws and data protection laws and to report key performance information or other data to our regulators (Ofwat, DWI and the EA) in line with our statutory licence conditions and/or other water industry legislation. |
Non-special category data
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To manage customer service We collect data to manage customer accounts, including keeping customer records, customer care, for our internal business administration and to improve the service we provide to you. |
Non-special category data
It is in our interest to improve the quality of service and products we provide and fulfil effectively our legal and contractual duties. |
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To promote water efficiency, provide operational and service requirements based on water usage, compare and monitor water consumption We collect data to perform public functions in the Public Interest i.e. promoting water efficiency in line with our duties as a statutory water and waste undertaker. We also collect data to provide you with operational and service requirements based on water usage, health circumstances or financial circumstances, where applicable and to give you access to ‘My Smart Tracker’ web page, which allows you to monitor your hourly water consumption and to proactively send you monthly reports of your usage. In addition, we collect data for research and analytics purposes for example using aggregated consumption data to compare your water usage and monitor our network. |
Non-special category data
Special category data
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