Customer Privacy Notice

At Switch2 Energy Limited, we understand that our customers expect their personal data to be handled in a careful, considerate, and legally compliant manner.

The purpose of this Privacy Notice is to provide comprehensive information to Switch2 end customers of when, how and why we process your personal data. This applies where Switch2 are data controller and are the energy scheme operator for a heat network. Our service provision on this type of site will include the following:

  • Operation and maintenance of domestic heat network equipment
  • Operation and maintenance of the onsite energy centre and plant room(s)
  • Metering and billing service

Switch2 also process personal data on behalf of other organisations such as when we are contracted to provide metering and billing or operation and maintenance services to the energy scheme operator. In these instances we are acting as their data processor and therefore this Privacy Notice is not applicable. For information about your data protection rights in this scenario, please speak directly to the scheme operator who are the data controller.

1. How we get your information

We typically collect your personal data when you provide this to us as part of our process for registering you as a heat network customer at the site. We may also collect your personal data from third parties such as housing associations, managing agents, landlords and property developers when you rent or purchase a property from them where we have overall control for the heat network as the energy scheme operator.

2. Type of data we process

The type or category of personal data belonging to our customers that we process may include any of the following:

  • Your name
  • Gender
  • Billing address
  • Supply address
  • Contact details including phone number and email address
  • Bank details
  • Date of birth
  • Previous addresses lived at
  • Credit or debit card details (for when payments made by card)

We may also process ‘special category data’ as part of our service provision. This includes information relating to any disabilities or illness. We only process this data where we have your explicit consent to do so and we process this data to provide tailored services to you where additional assistance and support is needed.

3. Data processing purpose and legal justification

Switch2 provide a range of services to you as the end customer which require us to process your personal data in order to fulfil this service obligation. For each service provision we rely on a specific legal basis to lawfully process your personal data. This does not include services where your data is shared with a third party organisation. Details of our lawful basis for this type of activity can be found in Section 4 of this Privacy Notice.

The details of our different type of service provision and the relevant legal basis are as follows:

Service Provision Lawful Basis
Issuing bills to you as the customer for your energy usage  

Contractual – this is necessary to fulfil our contractual obligation for energy supply

 

Maintenance, repair, and upgrade of the heat network equipment in your property  

Contractual – this is necessary to fulfil our contractual obligation for energy supply

 

Handling queries, issues or complaints from you relating to the energy service  

Legitimate interest – we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service

 

Taking payment for heat network services  

Legitimate interest – we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service

 

Contact you for customer feedback relating to out service provision  

Legitimate interest – we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service

 

Administration of your customer account on our different digital systems  

Legitimate interest – we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service

 

4. Sharing your data

Your personal data will be shared with authorised people working for Switch2 where this is necessary to fulfil one of the stated processing purposes in the previous section. We take suitable measures to ensure that your data is only shared with employees that have a genuine business reason for having access to your personal data to allow them to provide a service to you.

We may also share your personal data with third party organisations as part of our service provision to you.

The types of third-party organisation we use to deliver these services to you include:

Third Party

 

Purpose

 

Lawful basis

 

Landlord and/or Managing Agent

 

To provide information about the account balance and any payment arrears on the account

 

Legitimate interest
IT services or software providers

 

To facilitate the processing of data on digital systems

 

Legitimate interest

 

Business support companies

 

To provide business support services such as out of hours call handling

 

Legitimate interest

 

Mailing company

 

To provide customer billing services by mail

 

Legitimate interest

 

Sub-Contractors

 

To provide maintenance and repair services to the heat network

 

Legitimate interest

 

Providers of customer satisfaction surveys

 

To deliver specialised customer feedback services to allow Switch2 to improve their service provision

 

Legitimate interest

 

Credit reference agencies

 

To help prevent fraud or as part of debt collection services

 

Legitimate interest

 

Enforcement authorities

 

To provide data to police, fire services, medical or other enforcing authorities where this is required under specific circumstances

 

Legal obligation

 

Where we actively engage a third party that will have access to your personal data, this processing will be done under strict contractual terms mirroring the terms we agree with the data controller. All third parties acting on our behalf are required to take suitable and satisfactory security measures to protect your data and these must be in line with our own internal policies and procedures. Third parties are only permitted to process your data for specified purposes and in accordance with our instructions.

5. How is your data kept secure

When we use information about you, we take all reasonable efforts to do so fairly and lawfully. 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.

6. Your rights

The UK GDPR gives you certain rights towards your personal information. We take all reasonable efforts to ensure we allow you to exercise those rights.

Your rights are:

  • The right to be given specific information on your personal data we collect.
  • The right of access to your personal data.
  • The right to rectify any of your personal data which is inaccurate.
  • The right to erase your personal data in certain circumstances.
  • The right to restrict processing of your personal data.
  • The right to data portability.
  • The right to object to certain processing.
  • Rights in relation to automated decision making and profiling.

If you want more information about your rights under UK GDPR or if you wish to contact us to exercise one of your rights as listed above, the quickest way is to email our Data Protection Officer at dataprotection@switch2.co.uk.

We may reply to you where we need further information to help respond effectively to your request. Switch2 is not a ‘public authority’ as defined under the Freedom of Information Act and we will not therefore respond to requests for information made under this Act.

If you are not satisfied with the response you receive, you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:

Information Commissioner’s Office

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Telephone: 0303 123 1113

7. How long do we keep your data

When we collect your personal information, the length of time that we retain it is determined by a number of factors, including the purpose for which we use that information. Typically however we will retain personal data for the full length of time that we are providing a service to you on behalf of our client (the data controller) and then for a period of 5 years subsequent.

At the end of the retention period, your personal data will be destroyed and removed from all systems.

8. Further information

Should you have any queries regarding the processing of your personal data please email our Data Protection Officer at dataprotection@switch2.co.uk