In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 13, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
We are Icosa Water Services Limited, a limited company registered in England and Wales under company number 10479916. We are licensed by the Water Services Regulation Authority (Ofwat) to supply water and sewerage services to customers within our licensed areas. We are a wholly owned subsidiary of Icosa Water Limited, company registered in England and Wales under company number 09155925. Our registered address is: Sophia House, 28 Cathedral Road, Cardiff, CF11 9LJ.
You may contact our Data Protection Officer here:
Data Protection Officer, Legal Services
Icosa Water Services Limited
28 Cathedral Road
Or you may email address: email@example.com.
Telephone number: 0330 111 0780.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 12 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right, under certain circumstances, to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data in some cases.
- The right to object to us using your personal data for a particular purpose or purposes, such as direct marketing which you can object to and stop at any time. You can object to processing carried out on legitimate interest grounds, including profiling, and we will provide you with our reasons for that processing.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- Contact information, such as your name, address, phone numbers, e-mail addresses and other contact information;
- Personal identifiers such as your date of birth and National Insurance Number; we can get this information from you as well as from Credit Reference Agencies,
- Employer details, role and work location;
- Copies of personally identifiable documents such as passports and driving licenses (to enable us to confirm your identity where required);
- Information relating to payments, including bank accounts, debit and credit card details;
- Details of your interaction with the company, whether by telephone, email, online, post or social media channels; for example recordings of telephone conversation we have with you, notes that we take from our conversations with you, your responses to any surveys carried out by the Company.
- Details of any queries or complaints raised through external consumer bodies, such as CCWater;
- Your billing and payment history, including your financial history and circumstances, credit rating and credit scores;
- Public information such as County Court Judgements and bankruptcies, electoral register information and fraud prevention information;
- Details of other people receiving our services with you, such as co-owners, co-occupants and family members’ details;
- Land registry information;
- Health and medical information;
- Passwords and user names to access your account;
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, because we have a statutory right to use your personal data or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
- Complying with all our statutory obligations, such as those imposed by the Water Industry Act 1991;
- Complying with all our regulatory obligations imposed by our regulatory bodies, such as Ofwat, the Environment Agency and the Drinking Water Inspectorate;
- Providing such information as is necessary to enable non-household customers to switch between retailers;
- Providing and managing your access to Our Site;
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience;
- Providing and managing your account, undertaking billing and collections;
- Contacting you about operational matters and service communications;
- Communicating with you, including responding to emails or calls from you, educating customers on their responsibilities in connection with water and sewerage services, promoting water efficiency measures and obtaining meter readings;
- Meeting service level obligations and making guaranteed standards payments;
- Manage water quality and resources and investigate water quality events;
- Manage our business and ensuring that we can maintain high standards of quality and service;
- Debt recovery; and
- Fraud and crime prevention.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third Parties whose content appears on Our Site may use third-party Cookies. Please refer to Part 13 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We may use the certain automated systems for carrying out certain kinds of decision-making and/or profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
We will keep your personal data only for so long as is necessary for the purposes for which it was collected.
We anticipate storing or transferring your personal data in the UK. This means that it will be fully protected under the GDPR.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
The security of your personal data is essential to us and we take important measures to protect your data.
We may share your personal data with other companies in our group. This includes our holding company and its subsidiaries. We may sometimes share personal data with our contractors or selected third parties. If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes. You are entitled to object to direct marketing (even though we may not need your consent to contact you with promotional material in the first place). See Part 14 below for details of how to withdraw consent.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 20 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to out Cookies Policy. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
We do not use direct marketing to sell our core services. However, we may want to contact you in relation to additional services such as water efficiency services. We may also want to provide you with marketing information from carefully selected third parties.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must and will always comply with your request. If you want to stop direct marketing communications from us, you can contact us using any of the options given in Part 15 below.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following contact details:
You may email us at: firstname.lastname@example.org
You may call us on: 0330 111 0780
You may write to us at:
Icosa Water Services Limited
28 Cathedral Road
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.