Privacy policy

Privacy policy

We are committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1  About us

Electricity North West Limited is committed to protecting the privacy and security of your personal information and to being transparent about how we collect and use that data to meet our data protection obligations in compliance with the General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018.

This privacy notice describes how we collect and use personal information about you, in accordance with the GDPR and the DPA. This privacy notice covers the following processing activities of Electricity North West:

  • Customer operations and complaints
  • Connections
  • Land Rights and Consents
  • Innovations
  • Stakeholder engagement
  • Priority services
  • Smart Meters

Electricity North West Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your information.

2  Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. used lawfully, fairly and in a transparent way
  2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  3. relevant to the purposes we have told you about and limited only to those purposes
  4. accurate and kept up to date
  5. kept only as long as necessary for the purposes we have told you about
  6. kept securely

3  Information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.

We collect basic personal data from you. Specifically, name, address, telephone number and email address. We may also collect your bank details in certain circumstances. If you contact us, or we contact you, by telephone, we may also record the call for training and service improvement purposes and make notes in relation to your call.

We may also receive personal data about you from third parties, including your electricity supplier, such as up-to-date contact details, off supply notifications and application details for new connection requests. As a distribution network provider, Electricity North West Limited works closely with third parties, including your electricity supplier, sub-contractors, National Grid, Members of Parliament, local authorities, housing authorities, charities and the Office of Gas and Electricity Markets (“Ofgem”).

For more information on personal data collected for our Priority Services Register specifically, please refer to this section below.

4  Why do we need your personal information?

We need to know your basic personal data to be able to maintain and operate the electricity distribution network for which we are responsible. In particular, we need to know your basic personal data to direct your enquiries to the correct team, to contact you regarding your enquiry, to allow our engineers to visit you onsite where required and to provide assistance to you in the case of an emergency.

5  Legal basis for processing

In order to process and use your personal information lawfully, we rely on the following legal bases:

  • for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract
  • to comply with our legal obligations
  • for our legitimate interests in ensuring effective operational management and internal administration, document retention/storage, compliance with regulatory guidance, exercise or defence of legal claims, product/service improvement and communicating with you
  • with your consent, to maintain and develop our relationship with you, including marketing our products and services and market research. You may withdraw your consent at any time.

For more information on the legal grounds for processing for our Priority Services Register specifically, please refer to this section below.

6  Situations in which we will use your personal information

The personal data we process is processed by our staff to:

  • enable our customer contact centre to help you with any enquiries or complaints
  • communicate with you by telephone, mail, email or other electronic means
  • enable us to provide you with assistance in order to ensure the distribution of electricity to you and to contact you in an emergency
  • monitor our work and maintain our records
  • obtain feedback on how we can improve our services
  • allow us to process charges in the event of damage to our equipment
  • provide compensation to customers in certain circumstances
  • comply with legal or regulatory requirements.

For additional information on what we do with your personal data for our Priority Services Register, Connections, Innovations, Stakeholder Engagement, Smart Meters or Land Rights and Consents specifically, please refer to the relevant sections below.

For the purposes of Network Management, IT support, email support and maintenance, we, or a third party who we share personal information with, may store and handle that personal information outside of the United Kingdom.

We will only permit this to happen if adequate safeguards have been put in place to protect your personal information. This means that we will:

  1. ensure that the country in which your personal information will be handled has been deemed "adequate" by the European Commission or Information Commissioner’s Office; or
  2. include standard data protection clauses approved by the European Commission or Information Commissioner’s Office for transferring personal information outside the UK into our contracts with those third parties.

We may share your information with:

  • your electricity and water suppliers
  • your gas distribution network operator
  • Ofgem, the Energy Ombudsman and any other regulatory authority we may be subject to for the purposes of demonstrating compliance with applicable law and regulations
  • to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
  • our sub-contractors for the purposes of carrying out work on our electricity distribution networks
  • our service providers for the purposes of providing services to us (including third party survey providers in order to carry out surveys on our behalf).

We may also use aggregate information and statistics in order to help us develop our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

Marketing

If you have provided consent, or we otherwise have the right to do so, we may send to you direct marketing and promotional materials relating to our services, engagement activities or related products, for example sending you communications (including by email) for these purposes. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of our emails or by emailing electricitycustomerrelations@enwl.co.uk.

7  Data security

We take the security of your data seriously. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8  How long will we keep your information for?

We will keep your information only for as long as necessary depending on the purpose for which it was provided. When determining the relevant retention periods, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved
  • legal obligation(s) under applicable law to retain data for a certain period of time
  • regulatory requirements
  • (potential) disputes
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us using the details below in the Contacting Us section.

9  Your rights

You have the following rights regarding your information:

  1. Right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this privacy notice.

  1. Right of access

You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this privacy notice). This is so you are aware of the information we hold about you and can check that we are using your personal data in accordance with data protection law.

  1. Right to rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

  1. Right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not a general right to erasure; there are exceptions.

  1. Right to restrict processing

You have rights to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.

  1. Right to data portability

You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

  1. Right to object to processing

You have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests or on public interest grounds; the right to object to processing for direct marketing purposes (including profiling); the right to object to the use of your personal data for scientific or historical research purposes or statistical purposes in certain circumstances.

  1. Right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to the use of your personal data for direct marketing purposes.

For more information on your rights or if you would like to exercise any of your rights, you are welcome to contact us at the contact details set out below under “contacting us”.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10  Contacting us

If you would like to contact us in relation to your rights, or if you are unhappy with how we have handled your information, you may contact us as follows:

Address: Customer Relations Team, Electricity North West, 304 Bridgewater Place, Birchwood Park, Warrington, Cheshire, WA3 6XG

Email: electricitycustomerrelations@enwl.co.uk

If you would like to contact our Data Protection Officer, you may do so by contacting them at:

Address: Data Protection Officer, Electricity North West, 304 Bridgewater Place, Birchwood Park, Warrington, Cheshire, WA3 6XG

Email: dataprotection@enwl.co.uk

If you are not satisfied with our response to any concerns about your data or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or write to them at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

11  Supplemental information

11.1  Priority Services Register

Please read this section if you have registered with our Priority Services Register.

Special categories of personal data

In addition to collecting your basic personal data (name, address, telephone number and email address), if you have registered for our Priority Services Register, we process special category or “sensitive” data about you (e.g. personal data concerning health) where we have asked for your explicit consent or otherwise where this is necessary:

  • to protect your vital interests or the vital interests of another person, if you or they are incapable of providing consent
  • under the Civil Contingencies Act 2004, or
  • for the establishment, exercise or defence of legal claims.

Where your consent is required, we will ask you for it at the relevant time. You may withdraw your consent to this processing and remove your name from the Priority Services Register at any time by contacting us on 0800 195 4141 or emailing us at customerwelfareteam@enwl.co.uk.

What do we do with your personal information?

We use your information to:

  • add you to our Priority Services Register
  • ensure that you are provided with the ongoing support you need in an emergency, bad weather and for planned supply interruptions (including providing you with updates and alerts) both onsite and through our customer contact centre
  • with your consent, share that data with your water and electricity suppliers
  • liaise with your nominated contact (where provided)
  • periodically check with you that the information we hold is correct and up to date.

If the only contact detail we hold for you is your home address, we may periodically share these details to a third party to write to you and confirm that the details we hold for you are up to date.

We may also receive personal information about you from your electricity suppliers, gas suppliers, water company, welfare organisations and NHS organisations to include you on our Priority Services Register so that you will benefit from this service.

We may share your information with welfare organisations, local authorities, and emergency services for those organisations to provide support and assistance to you in special circumstances or emergencies; and our sub-contractors to provide onsite support during planned supply interruptions, bad weather or emergencies.

11.2  Connections

Please read this section if you have requested a new connection, disconnection, diversion or additional load.

What do we do with your personal information?

We use your information to:

  • process your application and provide you with designs and quotations for a new connection to our electricity network
  • enable you to make payment for your connection service online, via the payment gateway Lloyds Bank Cardnet
  • provide feasibility and budget estimates
  • move or divert your existing supply of electricity to a new location as requested by you
  • manage applications for disconnection from our electricity network
  • manage generation applications, which is reportable to our regulator Ofgem
  • provide our operational teams and sub-contractors with the necessary information to carry out the connection works onsite
  • share your contact details where you are the primary generator with a flexible connection to assist other applicants who are interested in shared capacity connections
  • contact you to invite you to take part in connections engagement activities, provide comment/feedback on changes in policy and improvements to systems
  • comply with legislation associated with the provision of electrical connections; carry out inspections to comply with our legal and regulatory obligations; and investigate reports of potential cases of electricity theft.

We may share your information with our data processors Lloyds Bank Cardnet, Mailchimp and subsidiary Mandrill, Mando Group Ltd and Episerver AB for processing your estimates, quotations and payments and for keeping in touch with you. We may also share your information with Explain Market Research Ltd for the purpose of service evaluation.

11.3  Innovations

This section applies to you if you have registered an interest in being kept up to date with new projects.

What do we do with your personal information?

If you register an interest in being kept up to date with any new innovations projects undertaken by us, a particular project or sign-up to be part of a particular project, we use your information to:

  • send you newsletter communications with updates about our ongoing or new innovations projects; this may also include information on wider industry events such as those organised by other DNOs or the Energy Networks Association
  • design projects to trial innovative technologies to help manage our network
  • effectively deliver innovations projects
  • verify any analysis carried out on those projects (which could include monitoring devices installed in customer homes and businesses)
  • conduct surveys during or after participation in such projects.

We may receive your information from third parties working in association or partnership with a particular project e.g. local housing associations.

In many cases, we deliver innovation projects with external partners such as local housing associations, and we may need to share your information with them to ensure that we can deliver the project successfully.

We may share your information with our third-party service providers, such as Impact Research Limited, who carry out engagement activities, surveys and/or research on our behalf.

11.4  Land Rights and Consents

Read this section if you are a landowner who has equipment belonging to Electricity North West situated on your land.

What do we do with your personal information?

We use your information to:

  • agree rights in land
  • manage existing land rights
  • carry out administrative duties relating to rights agreed inclusive of payments
  • carry out other land liaison duties such as notification of project work, operations and maintenance
  • process wayleaves payments and operational property rental
  • facilitate access to install, repair, monitor, maintain and remove apparatus lawfully situated on your land.

We may also share your information with our legal and professional representatives and any legal professional representatives you have appointed to liaise with us on your behalf and with contractors undertaking development projects and maintenance.

11.5  Stakeholder engagement

What do we do with your personal information?

We use your information to:

  • fulfil and evidence regulatory stakeholder engagement targets and obligations
  • record your consent and marketing preferences
  • invite you to future stakeholder activities and events that may be of interest to you
  • record your attendance at events and any feedback you have provided
  • provide you with updates and relevant information on our activities, including progress of initiatives, forthcoming developments and opportunities to engage and consult.

We may share your information with our third-party service providers who carry out engagement activities, surveys and/or research on our behalf. These service providers include Impact Research Limited, Explain Market Research Ltd and Feedback Market Research.

11.6  Smart Meters

Read this section if you have a Smart Meter.

What do we do with your personal information?

We collect data relating to the electricity consumption of the property which we have chosen to treat as personal data. We do not associate this data with any personal information about your household or occupants.

We use your information to:

  • Decide if our distribution network is overloaded or has spare capacity;
  • Help us restore supplies or reconfigure the distribution network if there is a fault; and
  • Optimise the configuration of the distribution network.
  • We may also share this information with other parties who have a legitimate reason to require it relating to design and management of the electricity distribution network.

 

Updated March 2021