Data Protection Officer
D-ENERGi Business Complex Unit D,
Madison Place Central Park, Manchester
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
This privacy statement was last updated on Friday 8th January, 2021
The below policy explains how we may collect information about you and then use it to meet your needs. It also explains some of the security measures we take to protect your privacy, and tells you certain things we will not do.
D-ENERGi is the ‘Data Controller’ for your personal data. This means we have legal responsibility for how we collect and handle your data.
When we first obtain personal information from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information from us about other services or products. You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us at email@example.com or contacting the data officer at the above address.
1. Using your personal information & Your Privacy Rights
1.1 We and our agents may use your information to:
- Provide you with the services you have asked for (which may include loyalty,discount and rewards schemes we may run from time to time).
- Offer you accounts, services and products from time to time (we may do this using an automated scoring system, which also uses information from other agencies, including credit reference agencies).
- Help run, and contact you about improving the way we run, any accounts, services and products we have provided before, now or in the future (we may contact you by e-mail or text message, if you have given us these contact details).
- Create statistics, test computer systems, analyse customer information, create profiles and create marketing opportunities (including using information about what you buy from us and how you pay for it, for example, the amount of gas you use and any discounts we have offered you).
- Help prevent and detect debt, fraud and loss.
- Help train our staff.
- Contact you in any way (including by email, phone, text or multimedia message or other forms of electroniccommunications, such as a message through your smart meters) about products and services we and our partners offer.
We may also monitor and record any communications we have with you, including phone conversations and emails, to make sure we are providing a good service and meeting our regulatory and legal duties.
1.2 Your Rights:
To be informed: have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. We fulfilthis right by giving you this notice.
Access to your personal data: You can request access to a copy of your personal data that we process as a data controller, together with details of why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making.
Right to withdraw consent: If you have given us your consent, you can withdraw that consent at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will tell you.
Right to object: You may object to our processing of your personal data by us, where this processing is based on our legitimate interests or in the public interest. We will assess whether our interest in continuing to process your personal data overrides your rights and freedoms. If not, we will stop processing your personal data. Either way, we will inform you of the outcome.
Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
Erasure: This is also known as “the right to be forgotten” and this means that you can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent (where applicable), or where we have no lawful basis for keeping it or otherwise using it. There are limited exceptions, for example where we need to use the informationto bring or defend a legal claim.
Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred. This is limited to personal data you have provided with your consent or in relation to the products you have with us, and which we process by automated means, such as your account transaction data.
Restriction: You can ask us to restrict the personal data we use about you where:
- it is inaccurate;
- you have asked for it to be erased;
- you have objected to our use of it; or
- where you need this for the bringing or defending of legal claims.
When you have asked us to restrict the use of your personal data we may still store your information but will not use it further without your consent, unless we need to process it:
- to bring or defend legal claims;
- to protect the rights and freedoms of other individuals; or
- for other important public interest reasons.
2. Sources of Information
When we contact you, we may use any information we hold about you to do so. So we may contact you by email, phone, text message or other forms of electronic communications, such as using smart meters, or by visiting you. If we are contacting you to tell you about any offers, as far as possible, do so in line with how you have told us you would prefer to receive marketing information (your recorded marketing preferences). You can ask us not to send you any information on our offers at any time by contacting us and giving us your account details.
3. Disclosing & Sharing your information
3.1 We may allow other people and organisations to use information we hold about you
To provide services you have asked for, which may include providing information to anyone acting onyour behalf or other people who may be interested (such as landlords or letting agents).
- Regulatory reporting is a legal requirement we haveto do and will involve us processing your data for this purpose.
- Managing your complaint or dispute will require us to process your information and in certain circumstances require us to share it with bodies like the ‘Energy Ombudsman’.
- Our obligation to try and install a smart meter will require us to process your data for this purpose.
- Orders made by a Court, for example where we are ordered to disclose information to law enforcement agencies.
- To help to prevent and detect debt, fraud, or loss (if you do not pay your debts, we may transfer your debt to another organisation and give them details about you and that debt).
- If we have been asked (for example by Ofgem or a lawyer) to provide information for legal or regulatory reasons.
- Our team of energy brokers and consultants who act asour agents.
- As part of current or future legal proceedings.
- As part of government data-sharing initiatives, for example, those designed to help stop fuel poverty (where people cannot afford to pay for heating and electricity).
- To help manage any loyalty, discount or rewards schemes.
- As part of the process of selling one or more of our businesses.
If you hold an insurance policy with us, to pass information to an insurer to manage your insurance policy (including underwriting and claims, to help develop newservices and to assess financial and insurance risk).
- Network operators, so they can keep you informed about reconnecting your energy if there’s a loss of supply or an emergency
- Agents appointed by us to facilitate our contract with you, such as Meter Operators and Data Collectors
- Organisations that supervise or distribute data between smart meters, energy suppliers and other organisations that enable suppliers to bill customers for energy used and customers to switch between suppliers
- Other energy suppliers, landlords or housing associations if we or another organisation suspects the property is connected with fraud
- Another supplier you want to switch to
- Other people where you have authorised us to, or where they are named on your account
- Debt collection agencies and other organisations involved with debt collection (for example, bailiffs, law courts, private investigators)
- Social services, distribution services or other agencies if we think you need extra help
- Organisations giving you a service (for instance Green Deal), helping you compare your energy use with similar households or offer you rewards
- Organisations doing research for us
- Market regulators such as OFGEM and consumer protection organisations such as the Energy Ombudsman
- Organisations for the detection, investigation and prevention of crime
- Commissioning and installation contractors for installations such as Solar Panels and insulation
- Financial organisations for purposes such as payment processing, finance plans and refunds
- Energy market administrators i.e. Xoserve for gas and the Meter Point Administration Service
- If you apply for Affordable Warmth funder measures, the Energy Saving Trust and Department for Work and Pensions to confirm whether you’re entitled to the assistance
- Other FiT licensees if you want to transfer your generation unit(s) under the FiT scheme
3.2 If we suspect someone has committed fraud or stolen energy by tampering or with the meter or diverting the energy supply, we will record these details on your account record and may share this information with Ofgem and other people who are interested (such as other energy suppliers, landlords and housing associations). We may use this information to make decisions about you, your character, how likely we think you are to pay for your gas or electricity (or both) and future energy services. This may include recording sensitive personal information such as criminal offences you have been accused of. Also if the gas or electricity supply to your property has previously been tampered with or if gas or electricity has been stolen, or we suspect it has been stolen, we may take this into account when we decide what products or services we can offer you and the terms and conditions we give you.
3.4 You agree that we can ask your previous supplier for information that will allow us to take over your supply, such as information about meter readings and equipment or charges you owe yourprevious supplier. You agree that we can provide information we hold about you (such as information about meter readings, equipment or money you owe us) to your new supplier so they can begin supplying your gas and electricity.
3.5 If we believe that you (or a member of your household) need extra care (for example, because of your age, health, disability or financial circumstances), we may record this in the information we hold about you. We will use this information so that we do not stop your supply. We may share your information with:
- Social services, charities and other support organisations, if we believe at any time that you cannot look after yourself or other people using or visiting the site by making sure there is an energy supply to the site.
- Other energy suppliers if we believe you are thinking of changing supplier.
- The relevant gas transporter or network operator.
3.6 This clause applies to individuals, sole traders and partnerships and to directors of corporate organisations as well as limited companies and other corporate organisations. We will check your details with one or more credit-reference and fraud-prevention agencies to help us make decisions about your ability to make payments and the goods and services we can offer you. If you would like more information phone us on 0161 237 3333 and we will be happy to help.
a. We will search at credit-reference and fraud-prevention agencies for information about you and all the people you are applying with –if you are providing information about other people on a joint application, you must make sure they agree that we can use their information to do this. If you provide us false or inaccurate information and we suspect fraud, we will pass your details to credit-reference and fraud-prevention agencies. Law-enforcement agencies (such as the police and HM Revenue & Customs) may receive and use this information.
b. We and will use the information credit-reference and fraud-prevention agencies give us to:
- Help make decisions about credit and credit-related services for you and anyone applying with you.
- Check your identity.
- Prevent and detect fraud and money laundering.
- Manage your account.
c. When we ask credit-reference agencies to carry out a search, they will record this on your credit file whether yourapplication is successful or not.
d. We and other organisations may also use information to prevent fraud and money laundering, for example when:
- Checking details on applications for credit and credit-related services.
- Managing credit and credit-related accounts and services.
- Recovering debt. Checking details on applications and claims for insurance.
- Checking details of employees and people applying for jobs.
e. Organisations from other countries may use the information recorded by fraud-prevention agencies.
f. If you want to see what information credit-reference and fraud-prevention agencies hold about you, you can contact the following agencies currently working in the UK. The information they hold may not be the same, so it is worth contacting them all. They will charge you a small fee.
|Dunn and Bradstreet
|Consumer Services Team
|Credit File Advice Centre
|Consumer Help Service
|PO Box 491
|PO Box 1140
|PO Box 8000
|Phone: 0870 060 1414
|Phone: 0845 603 3000
|Phone: 0844 481 8000
|Phone: 0870 243 2344
3.7 If you give us information on behalf of someone else, you confirm you have given them the information set out in this document, and that they have given permission for us to use their personal information in the way we have described in this policy. If you give us sensitive information about yourself or other people (such as health details or details of any criminal convictions of members of your household), you agree (and confirm that the person the information is about has agreed) that we can use this information in theway set out in this document.
3.8 You are entitled to have a copy of the information we hold on you. And to have any inaccurate information corrected. You can also request data we hold to be erased.
Please note If the company receives a request from you to provide information we hold our systems we will provide this information for free. If we receive subsequent requests for the same information or if the information request is deemed to be unfounded, excessive or repetitive. The company reserves the rightto charge an administrative cost for providing this information.
4. Protecting information
We have strict security measures to protect personal information. This includes following certain procedures (for example, checking your identity when you phone us)and encrypting (encoding) data on our websites. Using encryption of our database systems, excel work sheets and more importantly regular staff training. We will not sell your information to any third party.
5. The internet
If you communicate with us usingthe internet, we may occasionally e-mail you about our services and products. When you first give us personal information through our website, we will normally give you the opportunity to say whether you would prefer us not to contact you by e-mail. However, you can always send us an e-mail at firstname.lastname@example.org for the attention of the Data Officer. Please remember that communications over the internet, such as e-mails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered –this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
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