Introduction
Welcome to the Great British Water Company Privacy Policy. In this Privacy Policy, when we refer to:
- ‘we’, ‘us’, ‘our’, ‘Great British Water Company, we are referring to:
- Great British Water Company Limited
- ‘you’ and ‘your’, we mean any individual who:
- uses our Website;
- visits any of our premises
- directly receives our services (for example, as a sole trader);
- works for one of our Customers;
- works for one of our Suppliers; or
- otherwise communicates with us.
- ‘Customers’, we mean any company or organisation that we provide our products and/or services to;
- ‘Suppliers’, we mean energy and utilities companies that we work with, including in order to collate energy and other utility proposals for our Customers, and who we may place customer energy and other utilities contracts with;
- ‘personal information’, we mean any information that can be used to identify you as an individual (whether alone, or if combined with other information);
- ‘services’, we mean our energy and utilities brokerage and management services;
- ‘products’, we mean our GB Water Insights Platform; and
- ‘Website’, we mean Business Water | The Great British Water Company (gbwater.co.uk)
We respect your privacy, and are committed to protecting your personal information. In this Privacy Policy, we explain how and why we collect, process, use and disclose your personal information, and what rights you have in relation to our use of it.
In certain circumstances, you may have a right to object to our use of your personal information. For further information regarding this, please refer to the Your Rights section below.
Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding your personal information. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
From time to time, we may change this Privacy Policy. As a result, please refer to this Privacy Policy regularly to review any amendments.
Who are we?
This Privacy Policy covers the processing of personal information carried out by the Great British Water Company.
When this Privacy Policy references ‘we’, ‘us’ and ‘our’, it is specifically referring to the Great British Water Company responsible for processing your personal information. That entity will be the controller of your personal information (meaning it will be the entity that determines how your personal information is processed and for what purposes).
What personal information do we collect and how do we use it?
We may collect and process personal information about you in connection with a service or product provided to you (or to the Company you work for) by us, through your use of our Website, via our social media pages, when you visit one of our premises, where we liaise with you in your role as employee of a Supplier, or where we otherwise communicate with you.
This can include a range of personal information, including:
- Identity Data: name, username, title;
- Work Details: job title and information about your organisation such as company name and business sector;
- Contact Details: postal address, email address, telephone number;
- Financial and Transaction Details: we may process your bank account and payment card details, and details of the payments made and products and services received, where you are directly purchasing our products or receiving our services;
- Technical Data: includes internet protocol (IP) address, your login data, passwords, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website;
- Photographs and Video Recordings: when you visit one of our premises, we may record CCTV footage of you; we may also record Teams calls
- Call recordings: when you speak to us on the phone, we may record our call;
- Marketing Preferences: details of your preferences to receiving marketing from us and your communication preferences;
- Complaints and Enquiries: details of any complaints or enquiries that you may make to us; and
- General Information: including other personal information you may provide during communications with us (for example, if you provide us with personal information when we are discussing our services to you over the phone).
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How we collect your personal information
We use different methods to collect personal information from and about you, including:
- From you directly. For example, you may provide us with your contact details and marketing preference information when signing up to receive our newsletters, or we may collect your financial information from you when you personally purchase one of our products.
- Through third parties or publicly available sources. For example, we may receive your personal information from credit reference agencies, or we may identify your contact details through publicly available sources such as through using Google search.
- Through automated technologies. Where you interact with our Website, we may automatically collect certain Technical Data about your equipment, browsing actions and patterns. We collect this information by setting cookies and other tacking technologies on our Website. Please see the Cookies section below for further information.
Personal information about third parties
In the course of using our Website, or through other interactions you may have with us, you may provide us with the personal information of third parties. For example, you may provide us with the information of a colleague when entering into a transaction on behalf of a Customer that you work for. In such cases, we will process such third party personal information in accordance with this Privacy Policy.
Where providing us with third party personal information, you confirm that the third party is happy for you to share their personal information with us, and that you have made them aware of this Privacy Policy.
Use of your personal information
We collect and process your personal information for a number of different reasons. Under data protection laws, we require a legal basis in order to process your personal information for each of our processing purposes. These legal bases can be:
- where we have your consent;
- where the processing is necessary for us to pursue a legitimate interest, and our legitimate interests are not overridden by your interests or rights;
- where the processing is necessary in order to enter into a contract with you or to perform a contract that we have in place with you;
- where the processing is necessary in order to comply with a legal obligation; or
- where the processing is necessary in order to protect your vital interests.
Please refer to the table below for the main purposes for which we process your personal information, along with the legal bases we rely upon for such processing.
You may also provide us with certain special category personal information (such as information in relation to your health, ethnicity, religious or philosophical beliefs, trade union membership or data concerning your sex life or sexual orientation). We will rely upon your explicit consent as our legal basis for processing this information.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer on the contact details referred to below.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
How we might share your personal information
When processing your personal information for the purposes set out above, we may share your personal information with third parties, including:
- our professional advisors, including our solicitors and accountants;
- our Suppliers, to help them arrange proposals and connect with you (where you are working for a Customer or are receiving our services or products as an individual);
- our third-party service providers who process information on our behalf (including our IT service providers);
- other companies within our ‘Wider Corporate Group’
- other third parties who may assist us in order to enforce our rights, or to protect our property and rights; and
- law enforcement bodies, including in order to comply with any legal obligation or court order.
We may also share with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
Where will we transfer your personal information to?
We need to transfer personal information across our Wider Corporate Group to help operate our business efficiently, and this may involve transfers outside of the UK. We also may need to transfer your personal information outside of the UK where we share personal information with third parties.
We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect your personal information, by ensuring that at least one of the following safeguards is in place:
- your personal information is being transferred to a country that has been deemed by the UK government to provide an adequate level of protection for personal information; or
- we ensure that we have a data transfer agreement in place with the overseas recipient of your personal information, which incorporates specific clauses that have been approved by the UK government.
For further information, please contact our Data Protection Officer using the contact details below.
Retention of your personal information
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you (or the Supplier or Company that you work for).
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For further information on how long we hold your personal information, please contact our Data Protection Officer using the contact details below.
Marketing
From time to time, we may send you information regarding products or services that we perceive may be of interest to you or the business you work for. You may receive this information by letter, telephone or email. If, at any time, you prefer not to receive further marketing communications from us in any or all forms, you will have the ability to unsubscribe from such communications.
Cookies
Our Website uses cookies and other tracking technologies (which we will generally refer to as “cookies”) to distinguish you from other users and help provide you with a tailored experience when you visit our Website. You can find further information about the cookies we set by visiting our Website, where you will also find details of how you can change your settings to block or delete cookies (although please note that this may impact your viewing and use of our Website).
Other Websites
Our Website may include links to third party websites. We cannot control the content or the security of any third-party websites. Linking to such websites is done at your own risk and we make no representations as to those third-party websites’ content. We cannot be held responsible for any loss or damage incurred by you as a result of using third party websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website. Third party websites are not governed by our Privacy Policy, and we encourage you to read the privacy policy of every website that you visit.
Security
We place great importance on the security of all personal information that we process. We invest appropriate resources to protect your personal information from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure, and we cannot guarantee the security of your personal information sent over the internet or by email. We therefore do not accept responsibility for unauthorised or unintended access that is beyond our control.
Your rights
Under data protection laws, you have certain rights with respect to your personal information. These include:
- Right of access. You have the right to receive a copy of the personal information we hold about you (subject to certain exemptions).
- Right to rectification. You have the right to ask us to correct your personal information where this is incomplete or inaccurate.
- Right to erasure. You have the right to ask for your personal information to be deleted (in certain circumstances).
- Right to restriction. You have the right to ask us to suspend our use of your personal information (in certain circumstances).
- Right to portability. In certain circumstances, you have the right to receive your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where technically feasible.
- Right to object. You have a right to object to our processing of your personal information (in certain circumstances, and subject to certain exemptions).
- Right to withdraw consent. Where we rely on consent as our legal basis for processing your personal information, you have the right to withdraw your consent at any time.
A number of these rights are subject to exemptions, and some are applicable only in certain situations. For further information on your rights, and when they apply, please visit https://ico.org.uk/for-the-public/. If you wish to exercise any of your rights, or discuss your rights with us, please contact our Data Protection Officer using the contact details provided below.
How can you access your personal data?
If you wish to make a data subject access request, please do so in writing, sent to the postal address shown below, clearly marking your correspondence as a subject access request.
We do not normally charge for subject access requests unless they are ‘manifestly unfounded or excessive’ (e.g. repetitive). We will respond to your subject access request within one month of receiving it. In the unlikely event that your request is particularly complex, a further two months may be required but we will keep you informed if this is the case.
Complaints process
If you have a complaint about how we have handled your personal information, you may contact our Data Protection Officer using the details below and we will investigate your complaint. In addition to the rights listed above, you also have a right to complain to the relevant data protection authority. Under data protection law, you have a right to complain about our handling of your personal information to the data protection authority, which in the UK is the Information Commissioner’s Office (ICO).
Contact Us
If you have any questions about this Privacy Policy, please contact our Data Protection Officer, Jacki Fullerton, using the following contact details:
- emails to partners@gbwater.co.uk
- letters to The Great British Water Company, 3rd Floor Dept Lmc Hathaway House, Popes Drive, Finchley, London, United Kingdom, N3 1QF
Version Information
V2 – Privacy Policy published on 13.05.2024