Privacy in more detail

We collect and use personal data about you for different purposes.

 

You may give us information by:

• filling in paper forms
• submitting forms on our website
• submitting forms on social media
• on the telephone
• by email,

 

or otherwise.

 

The information we collect about you will vary depending on your relationship with us.

 

We may also collect information about you from other sources. For example, if you rent your home, your landlord may give us your personal data in order to set up your account at their property.

The reason we need to collect your personal data will vary depending on what it is being used for.

 

The table below gives examples of the types of data we collect about you, the reason it is collected and how long we keep it for (the retention period).

 

Example information	We may use this for:	Retention period
Name, postal address, email, date of birth, marital status, financial and credit card information, household income	Billing purposes	7 years after the account is closed
Postal address, telephone number, e-mail addresses	To contact you	7 years after the account is closed
Date of birth, customer reference number	To identify you and protect your account	7 years after the account is closed
Health information, job status, number of children, age of children, receipt of benefits	Any special circumstances you want us to know about	7 years after the account is closed
Telephone discussions	For training purposes	3 years, unless the call has been tagged to be kept for longer
We may note other information on your account that is related to the services we provide to you	To provide you with the excellent customer service you expect	7 years after the account is closed

 

We may also use your personal data to administer, support, improve and develop our business generally and to enforce our legal rights.

 

We need to collect and use your personal data for a number of purposes and we must have a lawful basis for processing it. This lawful basis will vary depending on how and why we have your personal data, and how we collect it.

 

We have put together the table below to provide you with examples:

 

Lawful basis for processing	Example activities
Activities necessary for the performance of our public tasks as a water company	Arranging and maintaining your supply, billing you, maintaining our infrastructure
Activities necessary for compliance with a legal or regulatory obligation e.g. Water Industry Act 1991, Ofwat, Consumer Counsel for Water, DWI	Supplying Water and removing Waste Water, providing contact information to Ofwat
You have provided us with your explicit consent to process the information	Providing support or discount schemes, specific marketing activities
Activities are within our legitimate business interests	Carrying out market research, customer satisfaction surveys, or certain marketing activities
To protect your vital interests or someone else’s vital interests	If there is a risk to your household due to a water quality issue or where your water supply may be disrupted
Fulfilling contractual obligations	Fulfilling private contracts individuals may have with our laboratories

 

If we process special category information we must have an additional lawful basis for processing. Special category data we do routinely collect is:

• Health data

 

This data is processed to provide you with the support you need or inform you about discount schemes.

 

On rare occasions we may process other Special Category data which includes:

• information revealing racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetic or biometric data
• data concerning your sex life or sexual orientation

 

The lawful bases for processing special category data are detailed in the table below and we have provided an example of when this might apply:

 

Additional lawful basis for processing special category data	Example activities
You have provided your explicit consent	Providing support or discount schemes, specific marketing activities
The processing is necessary to protect your vital interests or someone else’s vital interests	If there is a risk to your household due to a water quality issue or where your water supply may be disrupted. We may also work with your energy company to ensure you are protected during any disruption to your power supply.
You have made the information public	You have provided the information publicly on social media
The processing is necessary for the establishment, exercise or defence of legal claims	Taking action for failure to pay bills
The processing is necessary for reasons of substantial public interest	If we suspect fraud on the part of a customer
The processing being necessary for reasons of public interests in the area of public health	Managing a water quality incident

We have security arrangements in place to guard against:

 

• unauthorised access,
• improper use,
• alteration,
• destruction, or
• accidental loss of your personal data.

 

We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that there is no unauthorised access to your personal data.

            

When we work with third party organisations, we require them to assure us of their compliance with our data protection and security requirements. This is further detailed in the contracts we have with them.

 

When you enter data onto secure areas of our websites, a Secure Socket Layer (SSL) is initiated. An SSL is a security device which ensures that any data which you enter is encrypted during transmission over the internet. Encryption means the data is encoded so that it is not legible until such time as we decode it.

 

No data transmission over the internet can ever be entirely secure. While we do our best to protect your personal data, we cannot guarantee its security and you must be aware of this when using our websites.

 

Our websites may contain links to other websites that are outside of our control. Other websites are not subject to our Terms & Conditions or Privacy Policies and so we cannot accept responsibility for their content. We recommend that you take the time to read the Privacy Policies on any other websites which you visit.

 

We also ensure that where information is required to be transferred out of the EU, we will comply with the law in doing so.

When visiting our websites, you may also be providing us with information via our use of website ‘cookies’.

 You can find out more about this by reading our Cookie Statement.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies can contain information that is transferred to your computer’s hard drive.

 

Our website uses cookies to distinguish you from other users. This helps us to provide you with the excellent customer service you expect when you browse our website and also allows us to improve our site.

 

We only use cookies which are required for the operation of our website.

Agreements we have with other organisations for sharing information.

 

We have legal requirements for sharing data with Thames Water, Anglian Water and Hartlepool Water who operate in our supply area.

 

We fully support customers under The Debt Respite Scheme (Breathing Space Moratorium and Mental Health Crisis Moratorium) (England and Wales) Regulations 2020 by acting upon notification from the Insolvency Service and liaising where appropriate with customers FCA regulated debt support agency. We are permitted to share data in this instance as we have a legal obligation to do so. We ensure we protect your data if sharing is required under these regulations, and we only share data which is necessary to meet these purposes.

 

In order to proactively support customers and eradicate water poverty, we share your personal data with the Department of Work and Pensions (DWMP) and select councils to determine if you are eligible for our WaterSure or Pension Credit tariffs. The DWP and councils are permitted to do so under the Digital Economy Act 2017 and NWL are permitted to do so under the Water Industries Act 1991 and under section 44 of the Flood and Water Management Act 2010 (social tariffs).

 

Like many other utilities, we share your personal data with Credit Reference Agencies (CRAs) and in return they provide us with information such as your financial circumstances and financial history.

 

The data we exchange can include:

• Name, address and date of birth
• Payment performance
• Details of any shared credit with your spouse or partner
• Financial situation and history
• Public information, from sources such as other utility companies, the electoral register, County Court Judgments, bankruptcies and Companies House.

 

We share information about you with CRAs on an ongoing basis; this includes information about your settled/paid accounts and any debts not paid on time. Ongoing sharing of your data is important to ensure we make the right credit decisions about you, ensure we offer you the right support, and to detect and prevent fraud.

 

We share information with CRAs to:

• Assess creditworthiness
• Verify your identity
• Manage your account
• Provide you with appropriate financial support
• Locate you if we are unable to trace you to collect a debt owed to us
• Prevent criminal activity
• Undertake statistical analysis, system testing and profiling

 

If like most of our customers you pay your bill on time, sharing your data will also positively impact your credit rating.

 

If you owe us money and do not repay in accordance with our payment terms, we will notify our CRA. This could result in your credit rating being negatively impacted and a default being registered against you. We will notify you of our intention to issue a default 28 days before doing so.

 

We will share your personal information with CRAs for as long as you are a customer with us.  Our legal basis for sharing your data is that it is either in our ‘legitimate interests’ or we have a ‘legal obligation’ as opposed to consent, therefore our customers are not able to opt out of this. 

 

CRAs will share your information with other organisations. Your data may also be linked to the data of your spouse, any joint applicants or other financial associates.

 

If you feel that your credit score has been incorrectly affected by any company, you can contact the CRA’s directly to investigate.

 

The CRAs we use have their own CRA Information Notice (CRAIN). These notices describe how the three main CRAs use and share personal data they receive about you or your business that is part of, derived from, or used in credit activity. All credit reference agencies have reference to this document on their websites which you can view here:

 

• TransUnion (opens new window)
• Equifax (opens new window)
• Experian (opens new window)

 

Vacant Properties

 

We will use credit reference agencies to determine who is responsible for charges at a property if it is listed as empty and unoccupied on our systems for longer than three months. This is a search against the property itself to determine occupancy as opposed to a search against an individual’s credit file, therefore has no impact to personal credit files.

 

Northumbrian Water are permitted to do this as we have statutory obligations they must fulfil under the Water Industry Act 1991 (WIA). This allows statutory water undertakers the power to demand and recover charges for the services which they provide.

 

If you are a home owner and your property is empty, unfurnished and you do not require a water supply, please make us aware of the circumstances and we will stop any credit searches against your property. You can do this in the “contact us” section of our website.

 

Other types of sharing

 

If you are a “household customer”, we may share your information with a third party company to assess whether you are eligible for our schemes to help you pay your water bill. We will only share your information in these circumstances with your agreement.

 

We work with debt collection specialists in instances where we need to take action for failure to pay bills.  Such action may include:

• Summoning your employer to a hearing
• Visiting your place of employment to issue court paperwork
• Asking the Court to take the money you owe us out of the wages your employer pays you. This is called an attachment of earnings.
• Asking a High Court Enforcement Officer to take your goods and sell them to cover what you owe us.
• If you own a property, we may arrange for the money you owe us to be held against the value of your property. This is called a charging order and would stop the sale or re-mortgage of your property.
• Asking a County Court bailiff to visit you at home to take your goods, which would be sold to cover the cost of what you owe us. This is called a warrant.
• Asking for an order for you to attend a Court hearing, where you’ll be asked to provide proof of your financial situation under oath, before making a payment offer in Court.

 

In some instances, if we are unable to recover the debt owed, we may sell your debt to another third party. If we do this, you will be notified of this and of the details of this third party. We will disclose to that third party the minimum personal data about you that is necessary for them to take on that debt.

 

The third party will be the data controller for that personal data, although we will retain copies in accordance with the procedures described earlier.

 

If you are a “non-household customer” (businesses, charities or public sector), as part of OpenWater we will share your information with Market Operator Services Ltd ("MOSL"). You may find out more about OpenWater (opens new window). You may find out more about how MOSL processes your information (opens new window).

 

If you are a “household customer” (a private customer) and a home owner, we may share your contact details with HomeServe. Find out more about HomeServe (opens new window) . You may find out more about how HomeServe processes your information (opens new window).

 

Sharing data for the prevention and detection of crime

 

We may be contacted by Her Majesty’s Revenue and Customs (HMRC), the Department for Work and Pensions (DWP), the police, fraud prevention agencies or immigration control. Under data protection legislation we are permitted to share your personal data and are sometimes required to share it without your consent and you will not be notified that this has been done.

 

Sharing data with Ofwat

 

All of our customers may have their contact information passed to a third party processor acting on behalf of our water regulator Ofwat.  Ofwat regulate and measure customer experience through a mechanism called C-MeX and developer services through D-MeX. C-MeX and D-MeX are financial and reputational incentive mechanisms designed to provide customers in the water sector with excellent levels of service.  You may be contacted by Ofwat’s chosen third party about the service you received from Northumbrian Water and asked to score our performance. This is not direct marketing and we have a Water Supply Licence Obligation to share your personal data for this purpose. We are restricted as to the removal of any customer from this contact.  Find out more about Ofwat (opens new window). 

 

Carefully selected and trusted partners

 

We may use carefully selected third parties to help us process your data and provide you with excellent customer service. When we work with third party organisations we require them to assure us of their compliance with our data protection and security requirements. This is further detailed in the contracts we have with them.

 

The following are some examples of our third party processors:

• software providers for systems like our billing systems, job management system and meter reading system in order to support our data and system management
• bill printing services who assist us with our customer bill printing
• operational partners who assist us with operational work like helping us to fix leaking pipes
• research partners who assist us with market research in order to improve our business and provide you with excellent customer service
• external auditors to ensure our business is running as it should
• we may also share your information with your energy supplier to ensure that your needs are supported in the event of a water or power disruption

 

Sharing data in an emergency or major incident

 

The Civil Contingencies Act 2004 provides legal authorisation (and in some cases a duty) to share data before, during and after an emergency or major incident where appropriate and proportionate.

 

In these circumstances we ensure we only share data which is necessary and we adhere to the Response and Recovery Information Sharing Protocol set up to ensure data shared is in compliance with the law.

 

Profiling

 

We may use profiling to:

• show us how likely it is that our customers will pay us for our services
• choose the most appropriate way to recover debts owed to us

 

The profiling we use is based on information provided by our chosen credit reference agency along with data NWL already hold about you. The profiling undertaken is always in line with the law, and on the basis of our legitimate interests or in line with our legal obligations.

We’re keen to promote efficient water use and we may send you offers or make you aware of products that help with this.

 

Also, from time to time, we may tell you about other offers we think may interest you.

 

We may do this, or we may share your information with carefully selected partners who offer services or products that we think you may be interested in. Every time we contact you about such offers we will give you the opportunity not to hear about anymore.

 

If you don’t want to receive such offers at all, please let us know via the online form (opens new window).

 

Please note, though, that you may still receive non-personalised marketing material through your letterbox

 

You may also let us know by calling 0345 733 5566, or write to us at:

 

Northumbrian Water
Customer Centre
PO Box 200
Durham
DH1 9WQ

 

Soft Opt-In Marketing

 

What is Soft Opt-In?

Soft opt-in allows us to send you marketing communications about similar products or services if you have previously purchased something from us or made an inquiry about our services, and you have not opted out of receiving such communications.

 

Types of Communications

Under the soft opt-in provision, we may send you:

• Newsletters and promotional emails about our products and services
• Special offers, discounts, and updates relevant to your previous purchases or interests

 

How to Opt Out

You can opt out of receiving marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email you receive from us
• Contacting us directly using the details above

 

Visiting our sites

 

When you sign in as a visitor you will need to provide information such as your name and vehicle registration number (if you are parked at our site). This information is used for security reasons and for health and safety e.g. to ensure we know who is on site in case of an evacuation.

 

Our premises are monitored by CCTV so your image may be captured whenever you enter our site boundary. There are signs to show you when you are entering an area monitored by CCTV. CCTV Images are held for 30 days and then deleted.

 

If you have an accident while you are on Northumbrian Water’s premises this must be reported and will be recorded for the purposes of health and safety and insurance requirements.

 

Drones

 

We may occasionally use Unmanned Aerial Vehicles (“Drones”), for example to survey our remote network or sites; and where we do so we may use third party specialist providers. Where we do, we will always try to minimise our collection of personal data such as images of people or private properties. Where we use drones we will always do so in compliance with all relevant laws.