- About this notice
This notice applies to the activities of Sutton Decentralised Energy Network (“SDEN” (also referred to as “we”, “us” or “our” in this privacy notice)) in its capacity as data controller as defined by the General Data Protection Regulation (‘GDPR’).
SDEN is committed to ensuring that your personal data are kept safe and handled in compliance with relevant laws and regulations. This privacy notice sets out how SDEN collects and uses your data. We ask that you read it carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
- The personal data we collect and use
Information collected by us
In the course of our activities as an energy service provider, we may collect and process the following personal data:
- Your name
- Your property address
- Correspondence Address and Postcode (if different to property address)
- Contact telephone number(s)
- Email address(es)
- Your Signature
- Move in/completion/occupancy date
- Move out/termination date
- Security questions for security and identification purposes
- Additional customer information, such as additional information about your personal circumstances and individual needs, which ensure that we can deliver our service to you and assist you responsibly
- Customer representative information, including name, address, contact details and payment information
- Customer household information, including information about other individuals living at your home. This may include name, contact details and relationship to the account holder and any other information we may require on a case by case basis
- Preference when communicating with you
- Your landlord’s name and contact details (if you are a tenant)
- Account information including your unique account number, unique customer identification, contact details, household details, property type, premises details, meter numbers, meter details, tariff details, financial and payment records, payment status, online account status, security questions, notes added to your account and your account history
- Heating and hot water consumption information including use and consumption pattern
- Transaction and payment details, which include Direct Debit details, bank account details you provide to make payment for your heat supply and payment plan details. If you pay someone else’s bill, we will have a copy of your payment
- Records of your discussions and correspondence with our customer service team and our agents and contractors, including call recordings, emails and letters from you and your representatives. We keep a record of queries, comments, suggestions and complaints that you send to us and our responses
- Information about discounts and which discounts are applied to your account
- Vulnerable customer status and whether you require priority services. This may include special category data, such as health information (for example, if you have a disability).
- Records of when you have exercised your statutory rights under data protection law and our response
Information collected from other sources
We may collect personal data from the following third parties for the purposes of providing our services:
- Entities in the same group as us
- Credit and anti-fraud reference agencies
- Operations and maintenance engineers and their contractors
- Property site developers, their contractors and legal representatives
- Local authorities
- Housing associations
- Energy network operators and distributors and their contractors
- Authorised representatives associated with your account
- Public registers such as the Land Registry
The purposes for which we use your information
This data allows SDEN to:
- Deliver our service in accordance with the terms and conditions of our contractual agreement with our customers
- Contact our customers and their representatives regarding their account and important service information and updates
- Respond to and resolve customer queries, issues and complaints
- Review, monitor and investigate energy consumption
- Issue monthly statements to our customers, collect payments and manage payment plans
- Conduct debt collection exercises
- Provide updates to customers about billing and important information relating to the service
- Provide performance reports to management and shareholders of SDEN
- To work with agents, suppliers and contractors to ensure service delivery of your heat and hot water
- Ensure staff and contractors safety is maintained at all times
- Undertake credit and anti-fraud checks and understand your creditworthiness and financial position
- Send electronic marketing communications to customers with their consent.
What if I don’t want to share my personal data?
You are not obligated or required to share any personal data listed above. However, if you do not provide us with the data described above, we may not be able to deliver our service to you.
- Lawful basis for processing your data
Where we process your personal data because of our contractual agreement with you, for example:
|Reason or purpose
|Personal data processed
|Delivering our service to our customers and holding details of your account
|Take payment for our service and debt collection
|Perform credit and anti-fraud checks
|Communicating with you regarding our services (including billing)
|Responding to your queries and complaints
|Investigating your energy consumption on your request
|Providing you with important service information (e.g. site-wide issues affecting your property)
Where we process your personal data because we have a legal obligation to do so, for example:
|Reason or purpose
|Personal data processed
|Responding to emergency situations (e.g. severe water leak)
|Investigating crime and fraud associated with your account
- Who else do we share your personal data with?
To enable us to deliver our service to you, we may share your personal data with the following third parties:
- Our legal representatives
- Other people authorised to represent and access your account
- Any person or legal entity approved by you
- Your housing association
- Your property developer or landlord
- Your bank
- Debt collection agencies
- Credit and anti-fraud reference agencies
- Priority services register and vulnerable customers
To help and support our customers we keep a Priority Services Register (PSR) which records who our vulnerable customers are and the specific needs of each of these and how we can help. For further information please visit out vulnerable persons policy below.
This ensures we can meet vulnerable customers needs by enabling us to:
- Ensure that all our staff and contractors are aware of your situation and understand your needs. This will allow us to provide the necessary aid upon request.
- Upon request we can arrange a password for entry into your home from staff and contractors. This can help protect you from bogus callers.
- In the case of an interruption to your hot water and heating supply, we will provide a fast response to resolve this.
- In the case of a prolonged disruption, supply alternative heating arrangements.
- Provide your bill in an alternative format or phone you to talk through your bill.
- Send your bill, or provide a copy of your bill, to an alternative contact.
- If you are having difficulties in paying, we can arrange a payment plan to help manage the costs over the year.
- Provide advice to help you use energy efficiently to reduce costs, as well as details of sources which can give you additional and impartial information or assistance.
- Offer support to help you understand where the different charges on your bill come from, and what they mean.
You can view our vulnerable customers policy here.
- Contacting SDEN
Via our designated phone line for customers
If you contact SDEN via telephone we will ask for security information including your name, address, account number, email address and telephone number to verify that we are speaking to you. If you are unable to confirm your account’s security information over the phone, we may ask you to contact us with the details of your query via the email address registered to your account.
During the duration of a call with you, we will record your contact details, account details and nature of your query for our records. We may also add notes to your account to ensure that we maintain a record of your issues raised. Where appropriate this information may be shared with partner organisations set out in section 5.
Via our @sden.org.uk email accounts
If you contact SDEN via email you must do so from the registered email address held on your account to ensure that we can verify that we are speaking to you or your authorised representative. If you email us from an account that is not registered with us, we will request confirmation from the registered email address, before we can progress your query or complaint. During email exchanges between SDEN and you, details are recorded for our records and added to your account to ensure that we maintain a record of your issues raised. Where appropriate this information may be shared with partner organisations set out in section 5.
- Your personal data rights
You may have the following rights in relation to your personal data:
- the right to be informed about the personal data we collect, how your personal data are being used and from whom we collect your personal data when we obtain it from other sources;
- the right to access the personal data we hold about you;
- the right to request the correction of inaccurate personal data we hold about you;
- the right to request the restriction or deletion of your personal data in some circumstances;
- the right to request that we share elements of your data either to you or another service provider;
- the right to object to us processing your personal data in some circumstances; and
- the right to withdraw your consent at any time to those processing activities which we carry out on the basis of consent, listed in section 4. You can withdraw your consent at any time by contacting us using the contact details provided below.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us using the details below. We may require evidence of your identity before we are able to complete your request.
For details on how to submit a subject access request with SDEN please visit the following link.
- What can I do if I have concerns about my personal data?
We hope we can help clarify and resolve any issues we have with you directly, however you also have a legal right to raise a complaint with the ICO (Information Commissioner’s Office). If you wish to find out more about how you can go about doing this you can visit https://ico.org.uk/.
- International data transfers
When we share your information with third parties, your personal data may be transferred to countries outside of the UK and the European Economic Area that do not have equivalent data protection laws. For example, we store our data on cloud services that are located in the United States. Where this is the case, we have in place appropriate contracts with these third parties to ensure that your data is protected, including standard contractual clauses approved by the European Commission. If you would like to see a copy of these agreements, please contact us using our details below.
- Keeping your personal data secure
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and/or for as long as we are legally require to hold data in order to fulfil our statutory obligations.
We have put in appropriate procedures and policies in place to ensure your data are not accidentally lost, stolen or used without the permission of SDEN. We limit the number of employees and contractors who have access to your data to ensure there is a reduction in the points your data are transferred. This means that they are not permitted to process data for their own purposes or gain and are only using your data to undertake specific functions as set out in this arrangement with SDEN.
- How to contact us