This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you or that you provide to us or that we obtain about you will be processed by us. Please read the following carefully to understand how we use your personal data and your rights in respect of your personal data.
SES Water ("We") are committed to protecting and respecting your privacy.
This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you or that you provide to us or that we obtain about you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Requirements* (the DPR), the data controller is Sutton and East Surrey Water plc of London Road, Redhill, Surrey, RH1 1LJ (company number 02447875). This is our legal name and SES Water is our trading name.
*Data Protection Requirements means the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011, The UK General Data Protection Regulation 2021 and all other applicable laws and regulations relating to processing of personal data and privacy in any applicable jurisdiction as amended and replaced, including where applicable the guidance and codes of practice issued by the UK Information Commissioner or such other relevant data protection authority.
How to Contact us
email us: email@example.com
write to us: Data Protection Officer, SES Water, London Road, Redhill, RH1 1LJ
You can also contact the Information Commissioner's Office via https://ico.org.uk/ or at Wycliffe House Water Lane, Wilmslow, Cheshire SK9 5AF or 0303 123 1113 for information, advice or to make a complaint.
SES Water tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
We are also happy to provide any additional information or explanations needed. Any requests should be sent to us using one of the methods above.
Information we collect from you and what we do with it
We may collect and process a variety of data about you from information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register to use our website, establish an online billing account with us, search for a product or services, enter a competition, promotion or survey and when you report a problem with our website or our services.
The information you give us will vary depending on your relationship with us but may include your name, address, email address and phone number, financial and credit card information, household income, age, disability, age of children, number of children, receipt of benefits (value and which ones), as well as bank statements, driver’s licence, passports or other ID document. What we process in different circumstances is set out below. We will keep scanned copies of all of this for validation and audit, at which point this evidence will be deleted in line with our document retention rules.
We also collect information for discount tariffs such as WaterSure, Water Support and WaterSure Plus on behalf of Thames Water, where they provide sewerage services so that these can be processed (Water Support applications are shared with Citizens Advice Mole Valley). Our priority service customers may provide information to us about medical conditions to allow us to make suitable arrangements during supply interruptions; they will be given the opportunity to opt-out at any time from our use of their data for this purpose.
We use your information for the specific purpose(s) for which it has been provided to or collected by us and also to administer, support, improve and develop our business generally and to enforce our legal rights.
More detailed information on what we collect in different circumstances and how it will be used is set out below.
We must have a lawful basis for processing your information; this will vary on the circumstances of how and why we have your information, but typical examples include:
the activities are necessary for the performance of our public tasks as a water company supplying customers with water and administering our relationship with them e.g. arranging and maintaining your supply, billing you, maintaining our infrastructure
- you have given consent for us to process the information e.g. in relation to certain support and discount schemes or in relation to certain marketing activities
- the processing is necessary for a contract between us, or because you have taken steps to entering into a contract with us
- the activities are within our legitimate interests e.g. carrying out market research, customer satisfaction surveys and priority services
- the processing is necessary for compliance with a legal obligation to which we are subject e.g. we have to provide certain contact information and other details about our services to Ofwat and the Consumer Council for Water
- to protect your vital interests e.g. because there is a risk to you and your household due to water quality issues or where the water supply has been disrupted
If we process any special categories of information i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, processing of genetic or biometric data for the purpose of uniquely identifying individuals, health data, or data concerning your sex life or sexual orientation, we must have a further lawful basis for the processing. This may include:
- you giving us your explicit consent to do so e.g. in relation to a discount or support scheme
- the processing being necessary to protect your vital interests or someone else's vital interests
you making the information public
- the processing being necessary for the establishment, exercise or defence of legal claims e.g. because you have failed to pay your bills
- the processing being necessary for reasons of substantial public interest e.g. to protect our vulnerable customers, including priority service customers, where we suspect fraud on the part of a customer
the processing being necessary for reasons of public interests in the area of public health e.g. managing a water quality incident
What to expect when you contact us?
People who contact us via social media
It is never a good idea to post your personal contact information on a public social media site. If you contact us using social media to report an issue and we need more information, we will ask you to private message us with suitable communication information which we will use to contact you in order to resolve your concern or gather additional information for our investigation.
People who contact us by telephone
When you contact us by telephone your telephone number may be added to your account so that we can contact you in future in service of your water account. We record all calls for training and quality purposes.
We may also use a telephone number listed on your account to text you in the event that there is a water supply interruption or water quality concern (you will be given the option to opt out of the text messages).
People who email us
If you email us, we will respond to you using the email address you gave us. Please try to avoid sending personal data such as bank account details by email as this is not considered to be a secure communication method. Your email address will be added to your account and may be used for future service communications. Any email sent to SES Water, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Emails are also backed up by our data processor Mimecast. Emails are deleted in line with our retention rules. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who make a complaint to us
If you make a complaint to us, we will follow our complaints procedure. We may need to share details about your complaint internally in order to fully investigate. If you escalate your complaint to The Consumer Council for Water (CC Water) we will share information with them in order to resolve your complaint. This exchange of personal data with CC Water is a legal requirement under section 27B of the Water Industry Act (as amended by the Water Act 2003).
When we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies any individuals.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention rules. This means that information relating to a complaint will be retained for seven years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
People who report a water leak
If you are kind enough to report a water leak, we may take contact details from you in order to contact you if we need more information about the location or nature of the leak. You do not have to leave your contact information but it would be helpful for us if you can so that we can quickly identify the leak and repair it, minimising the amount of water that is wasted.
People who visit our website
With regard to each of your visits to our website we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information gathered through cookies and similar technologies are used to measure and analyse information on visits to our websites, to tailor the websites to make them better for visitors and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.
Our website may also, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Information about Cookies we use
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Unique identifier for each computer generated by the server to keep track of the user’s current session state.
No personal information is kept in the session cookie and it is destroyed when the session ends.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. More information can be found here: http://www.allaboutcookies.org/manage-cookies/
People who are water supply customers
People who report a water quality concern
If you report a water quality concern, for example dissatisfaction with taste, odour or the aesthetic appearance of the water provided to you, we will need to investigate. This means that we may use your telephone number to call you and discuss your concern. It is likely that a water sampler will need to visit your home to take some samples. We will keep you informed of planned visits and of any results we find by letter or by telephone. If you have provided an email address a copy of any letter may also be sent using this for your convenience.
People who are Priority Customers
In some circumstances you may not be able to make an informed decision for yourself or there may be some overriding safeguarding concern, and we feel it may be in your best interests to be on our priority service register. For example if there is a Court of Protection Order in place or your health is such that you are unable to make decisions for yourself. In these circumstances we may rely on an alternative lawful basis to process this data, for example to protect your vital interests.
Priority customers are customers who may need additional assistance either in communicating with SES Water or in the event of a water disruption. Priority customers include people with physical or mental impairments/ medical conditions or who have children who are under 12 months old and may not be able to easily leave their home to collect bottled water or who have a significant need for water as a result of their medical condition. We will only ever add customers to this register having first explained what we intend to do and with the opportunity to opt-out from this service. We use needs codes to minimise the amount of personal data we collect. As a priority customer we may contact you by telephone, email, text or a physical visit to your premises in the event that there is a water disruption, and you may be without running water. If you have provided a password then this will be used. If you have informed us that it takes time to answer the door, our employees will wait longer for you to answer the door. They will always have identification and if you are not sure you can always call us and check your visitor is genuine. You do not need to share full details of your medical condition with us to be added to the register and you can be removed from the register at any time if your circumstances change.
People who need financial help to pay their water bill
We have several schemes to help support customers who have financial difficulty. These schemes are: WaterSure, WaterSure Plus, Water Support, and Water Direct.
In support of the application for a scheme, we may request evidence of one or more of the following
- A medical condition resulting in increased water use
- A family, with three or more children living at the property under the age of 19
- The household income is less than the published amount and responsible for a child under the age of 5 (living at the property) or someone in the household is over 62 years of age
- Received Disability Living Allowance (DLA) or Personal Independence Payments (PIP)
- Income Support
- Income-based Job Seekers Allowance (JSA)
- Housing Benefit
- Council tax Benefit
- Pension Credit
- Working Tax Credit
- Child Tax Credit (other than just the family element)
- Income-related Employment and support Allowance (ESA)
- Universal Credit
- Proof of Income
People who are E-Billing Customers
There may also be links within the e-billing portal to leaflets which are normally sent out with paper bills, offering additional information about the water services we are providing to you, encouraging you to be water efficient or if you are an unmetered customer asking you to consider having a water meter.
Your email address or telephone number may be used to contact you about the water services that we provide. If we want to use your email address to send you direct marketing communications including those of our group companies, we will ask you to consent to this when you log onto e-billing. It is your choice whether you consent and consent can be withdrawn at any time by contacting us using the details above or using the "unsubscribe" function in any communication itself. Unsubscribing from marketing communications will not impact on any service messages we may send to you by email or SMS.
People who fall into arrears or fail to pay their water bill
In respect to a customer’s responsibility for paying their bills, SES Water has a regulatory requirement to provide a safe, maintained supply of fresh water to your property. In section 5 of our Water Charges Scheme, which is approved by our industry regulator, Ofwat, we explain that water charges are payable by the occupier of the premises, or the person who uses the supply, except where the owner of the premises is liable by enactment or by agreement with SES Water. Our Water Charges Scheme is further supported by the Water Industry Act 1991, which gives Water Companies the powers to charge and recover charges. This is referred to in Section 142 of the Water Industry Act 1991.
The information that we hold about customers may be used to recover arrears in line with our regulatory obligations and in doing so we may use third party debt collection/ management companies and credit reference agencies to assist us where it is in our legitimate interest to do so.
Profiling and automated decision making
All customers are given a High, Medium or Low risk rating which is based on previous payment history. Customers always begin with us on Low and will remain in this category as long as they pay their bills on time. Customers who fall into arrears or fail to pay their water bill may receive a higher rating which will directly influence how our customer liaison officers approach debt recovery with them. This ensures that first time late payments are dealt with proportionally. You can ask any customer services advisor to tell you your current rating. Some automated processing is used to send reminder letters and schedule visits but your account will always be reviewed by a person before legal action is taken to recover your debt.
We also profile our customers by whether or not they have a water meter so that we can target unmeasured customers to encourage them to have a meter fitted in the legitimate interests of water efficiency.
We receive some information about area affluence so that we can target particular customers who may benefit from financial support with paying their water bill. We will in the future receive and share additional information about individuals with the specific purpose of offering financial support in line with the Digital Economy Act.
Market Personal Data - Non-household customers
For the purposes of Market personal data SES Water acts as a joint controller with Market Operator Services Limited (MOSL). Their Privacy Policies and Notices are available on their website: https://mosl.co.uk/privacy-policies
Market personal data is personal data collected by Trading Parties and MOSL, for the purposes of providing the services and fulfilling our obligations under the Market Codes, which is stored in the MO Systems (central Market operating systems) and/or shared between parties in accordance with the Market Codes.
Non-household (NHH) customers: we may process personal data where these are sole traders or unincorporated partnerships, or relating to the individual employees of NHH customers, as well as the personal data of developers, and the representatives and employees of Trading Parties registered, or which may become registered, to eligible water supply points in the non-household retail water market (as defined in the Water Act 20214 and Market Codes).
Trading Party Personal Data is personal data collected by MOSL, about individuals, representatives or employees from Trading Parties, for the purposes of providing the services and fulfilling the obligations under the Market Codes. We might access such data in the MO Systems.
What data is collected?
Personal data is processed for the provision of water and sewerage services for managing NHH customer accounts, and general operation of the Market in compliance with the Market Codes; this includes the following:
- contact and communication details, including full names, email address, address, telephone number, job title, the organisation/business that a person works for, log-in details, records of any communications whether written or spoken; and
- billing information, including billing address, and information relating to credit ratings or credit scores; and
- account details and supply point details, including customer classifications including unique identifiers, meter information or Market consumption data.
Information is collected by direct interactions with NHH customers, including correspondence such as telephone calls, emails, webforms, and letters. Market personal data is then stored and accessed in the MO Systems for 6 years. For further details on the IT and back office systems used by MOSL, please refer to their Privacy Notices, as linked above.
What purposes do we use the data for?
We process contact and communication, account and supply point details in order to:
- to provide new and ongoing water and sewerage services, such as meter reading or repairs;
- to administer the billing and provision of these services, including switching retailers; and
- to comply with the requirements of the Market Arrangements Code or the Wholesale-Retail Code, to which we are a party and any additional regulatory requirements of regulators (such as Ofwat) to which we are subject.
The lawful basis for processing in these cases is:
- Personal data is necessary to perform a contract with that individual or take steps to enter into a contract with that individual.
- Personal data is necessary to support 'Legitimate Interests' that we, as a Trading Party or MOSL, which is responsible for the provision of water and sewerage services and the general operation of the Market, are required under the Market codes and our licence to undertake, including the billing and administration of these.
- Personal data is necessary to comply with a relevant legal or regulatory obligation that we are subject to (e.g. to comply with Ofwat, Defra or the Information Commissioner’s Office (“ICO”) requirements).
- Before collecting and/or using any special categories of personal data we will establish an additional lawful basis to those set out above which will allow us to use that information.
Moving out of our supply area
If you move out of our supply area, your account will be closed once any outstanding balance has been paid but your data in relation to water consumption and charges will be kept on record for seven years. If you wish to object to any of the information we keep you can make an application to have further information deleted.
When you sign in to our visitor system your name will be entered and there will be a photograph taken. All visitor information is deleted from the system every 6 months. 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 SES Water premises this must be reported and will be recorded for the purposes of health and safety and insurance requirements. Accident reports are retained for a minimum of 3 years.
If you are an interested party or stakeholder to SES Water, e.g. parish council, wildlife trust, local politician, neighbour to one of our sites, we will ask you to sign up to our new portal where you can stay up to date with SES Water activities. There is a separate privacy notice for the portal.
Use of our Company drone
We have a company drone which we use on our land above our sites to monitor for the purposes of maintenance and to track progress with large projects. The drone is flown by our CAA qualified pilots, is only flown above company land and not within 50 meters of a person. If you have any privacy related concerns about the use of our drone please contact us.
We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this website.
We may also receive information about you in some of the circumstances set out above e.g. if someone else reports a possible water leak, makes a complaint or confirms information needed in order to provide you with a discount or support scheme.
We also work closely with trusted partners (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, local authorities and credit reference agencies) and may receive information about you from them.
The obligations that we have to our Regulator
We have legal obligations to share data with our regulators. For example, we are required to share contact information with our water regulator Ofwat (and third parties working on their behalf) for the purposes of the water industry's Customer Measurement of Experience. We also have to share any personal data related to a water quality incident with the Drinking Water Inspectorate (DWI). Occasionally if you are part of an incident investigation there is a chance that data may be shared with Health and Safety Executive or the Environment Agency if it is part of the reporting requirements.
Agreements we have with other organisations for sharing information
We have in place some data sharing agreement for mutual benefits. For example, we have data sharing agreements with some local authorities including Reigate & Banstead Borough Council, Sutton Council, Tandridge District Council and SES Home Services to help keep our customer data accurate. This may involve names and addresses of customers.
We also have legal requirements for sharing data with sewerage companies Thames Water and Southern Water who operate in our supply area.
If customers fall behind with their payments and we are unable to locate them to chase their debt, we may share their data with credit reference agencies that will help us to track people’s locations for the purpose of collecting debt.
Circumstances where we can pass on personal data without consent
Sometimes we are contacted by HMRC, the Department for Work and Pensions DWP, the police, fraud agencies or Immigration asking for information about individual customers. Under the DPR, we are permitted to share this data with them without your consent and you will not be notified that this has been done. This is in the support of the prevention and detection of crime.
Ofwat C-MeX & D-MeX
All customers who contact us may have their contact information passed to a third party processor acting on behalf of our water regulator Ofwat for the purposes of the Customer Measurement of Experience (“C-MeX”) and Developer Measurement of Experience (“D-MeX”). These measures help to regulate customer service in the water industry in England and Wales. You may be contacted by this third party about the service you received from SES Water and asked to score our performance. This is not a marketing call. As this is a Water Supply Licence Obligation we have to share your data and are not permitted to remove any contact details.
Other third parties
If we merge with another business entity or divests a part of our business or carry out internal corporate restructuring, your information may be disclosed to SES Water's new business partners or owners or the new corporate entities.
Trusted partners we use who may have access to your data
We use trusted partners to help us process your data and provide services to you. All of our data processors have a binding contract with us that restricts their access to and handling of your personal data to only what is necessary in performance of their contract.
We use software providers for different systems, like our billing system, digital portal, job management system, and meter reading system, to support us with the large amounts of data that we need to manage. We use Computershare to assist us with printing bills and customer communications. We use Citizens Advice Bureau in Mole Valley to process Water Support applications. We use companies to help us process payments including card payments, payment cards and to process cheques.
As part of our billing system upgrade and the introduction of a digital platform, all relevant customer data will be migrated into our new billing system. Our new billing system is a cloud-based system and all data is housed in secured data centres. It operates an information security management system (ISMS) in accordance with the ISO 27001 international standard.
We work closely with our primary contractor Clancy Docwra for mains replacement and pipe repairs and they will have access to some customer information relevant to their work.
We use a company called ‘RMS’ to provide additional support with answering calls related to supply issues out of normal office hours.
We use one of our group companies, SES Home Services, to make leak repairs at customer properties. If you contact us about a leak in your home and are eligible for a visit, your data will be shared with SES Home Services in order to provide this function on our behalf. If you live in the Tandridge Council area and we detect higher consumption at your property, as part of a trial we will pass your information over to SES Home Services in order for them to contact you directly to investigate and carry out any efficiency of leakage work required.
From time to time we require legal advice and may need to share your personal data with our legal advisers or our insurance company or other professional advisors in order to obtain advice or make a claim.
SES Water also uses a trusted partner service to help maintain the security and performance of the SES Water website. To deliver this service the trusted partner processes the IP addresses of visitors to the website.
Where we store your information and how we keep it safe
All customer personal data is held in our billing system in the EU, which has controlled access. We use anti-virus software and fire walls to protect against cyber-attack. All access to our systems is strictly controlled by our IT department. We also operate strict physical security at all our sites and employees all receive security and data protection awareness training.
Where we transfer information to third parties to enable them to process it on our behalf (see the information about Trusted Partners above), we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data to them and keeping it secure.
We also ensure that where information is transferred to a country or international organisation outside of the UK/ EEA, we will comply with the relevant legal rules governing such transfers.
How long we will keep your information
We keep customer billing and correspondence for 7 years after you have ceased to be a customer. We hold voice recordings for 6 months.
Your data protection rights
You have certain rights in relation to your personal information, although those rights will not apply in all cases or to all information that we hold about you. For example, we may need to continue to hold and process information to establish, exercise or defend our legal rights.
You have the right to be informed and we will try to be as transparent as possible in our interactions with you. Any time you give us personal information you have a right to be informed about why we need it and how we will use it. You can find most of the information you need right here in this Privacy Notice.
You have right of access to any personal data we hold about you. You can contact us at any time to gain information about what data we hold, why we hold it, where we got it from and how we will use and share it. You may choose to write to us to exercise your Subject Access right. If you make a formal written request we will respond to acknowledge your request and check your identity, we might also ask you for information about what you are looking for to help us make sure we meet your request fully. You will receive a full response at the earliest opportunity but in any event within a month of your request. In most cases there is no charge made for this by SES Water.
To make a request to SES Water for any personal information we may hold you need to put the request in writing addressing it to our Data Protection Officer, or writing to the address provided below. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
You have the right to have any personal data we hold corrected at any time if you believe it to be inaccurate e.g. the spelling of your name or your contact information.
You also have the right to ask for our processing of your personal data to be restricted for example if you are contesting the accuracy of data we are using to bill you. We will restrict our processing while we verify the accuracy of the data that we hold.
You can also ask for certain information about you to be deleted for example if you are moving out of our supply area and you are not behind with your water bill payments or if you are no longer part of a discount or support scheme. We will not be able to delete any data relating to outstanding debts until the debt has been repaid as we have a legal obligation to collect debt. We will also not be able to delete your information if there has been a water quality concern related to the water supply for your property, as this data must be kept for seven years, or any information that we need to retain in connection with our Water Supply Licence.
You have the right to data portability where our lawful basis for processing is consent and where processing is automated, although we don't currently carry out any such processing. If we do in future, you can make a request and this data can be exported from our systems for you.
You have the right to ask us not to process your personal data for marketing or profiling purposes. We will ask for your consent (before collecting your data) if we intend to use your data for such purposes, not already detailed above or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org
Changes to this Privacy Notice
This privacy notice will be kept up to date as our business and internal practices and/or the DPR change and so may be subject to change at any time to reflect any changing activities. The most up to date version will always be available on our website.
We will not make any use of your personal information that is inconsistent with the original purpose(s) for which it was collected or obtained (if we intend to do so, we will notify you in advance wherever possible) or otherwise than is permitted by the DPR.
We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 18 February 2022.