Privacy Policy

TWRC is committed to protecting your privacy whilst complying fully with the Data Protection Act 1998.

This policy sets out the basis upon which personal data is collected, used and disclosed as well as your rights in respect of such personal data.

References to “we”, “us” and “our” are to TWRC.

Updates to this privacy policy may occur from time to time. We shall state on the policy the date at which the policy was last updated.

Information we collect

We shall only request sensitive personal data from you where we believe it will help us manage your account in the best way for you and to ensure that we can respond to your needs during an incident should one occur. Scenarios in which we may request your sensitive personal data are, for example, if you are in default due to illness.

We shall collect sensitive personal data only with your explicit consent (unless we are legally entitled to do so in accordance with the Data Protection Act 1998). You are not obliged to provide us with sensitive personal data and we shall only request this information when necessary to assist you with your account.

Your personal data may be used in the following ways:

• To provide you with our products and services, and to develop and improve those products and services;
• To ensure that the information we hold is up-to-date;
• To protect, manage and administer your account and provide you with bills and statements;
• To resolve any problems or complaints that may arise in relation to your account;
• For assessment and analysis purposes to help improve the operation of our business;
• To prevent, detect and prosecute fraud and other crime; and
• For any other purpose for which you give us your personal data.

Sharing your personal data

We may share your personal data:

• with our employees, agents and/or professional advisors;
• with successors-in-title to our business;
• with other third party contractors who provide services to us which require the processing of personal data;
• with third party payment providers who process payments made over our website;
• where we are under a legal obligation to do so, for example where we are required to share information under statute or because of a Court Order;
• to relevant authorities in order to prevent fraud and other criminal offences;
• with external agencies like the police, fire service, or local councils in the event of an emergency situation, such as under the Civil Contingencies Act 2004;
• with credit reference agencies. (To find out more, explore the links below.)
• with carefully selected partners, to introduce you to water related news, goods and services (by post, phone, email, SMS) that we think you’ll find interesting. If you don’t wish to be contacted for this purpose, please let us know by emailing us at [email protected]

Collecting your personal data

We may collect your personal data in a number of ways, for example:

• when you contact us through our websites, by telephone, post, e-mail or through any other means;
• when you register with us and set up an account to receive our services;
• when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
• when you enter a competition or promotion;
• when you make payments to us, through this website or otherwise;
• when you set your preferences for receiving marketing communications from us;
• when you use our services;
• when we receive your personal data from third parties, for example credit reference agencies or fraud prevention organisations; and
• when we collect publicly available information about you.

Information collected automatically – statistical information

We automatically collect some information about your visit to our websites but this does not record personally identifiable information.

This aggregated information is used to help us make improvements to website content and navigation.

The sort of information recorded includes how many people visit our website, which pages and items are the most popular and about how you use and interact with our website.

Cookies

Our websites use “cookies”.

Cookies are small text files that are placed on your computer by websites that you visit.

They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

If you would like further information about our use of cookies please read our cookie policy here.

What type of personal data do we collect?

We may collect the following types of your personal data:

• Your name, address, email address, telephone number, date of birth and other contact information;
• Details of payments that you make to us. Payment card details and other transaction details are held by a third party payment provider;
• Information about your billing and payment history, and information we learn from the way you manage your account;
• Information about your credit history with other credit providers which we obtain from credit reference agencies;
• The preferences that you provide to us confirming whether you would like us (and selected third parties) to contact you with information and offers that may be of interest to you; and
• Information about your use of our services, including information about your water usage which we collect from meters.
• Some of the information we collect about you may include sensitive personal data as defined in the Data Protection Act 1998.

Why do we use smart meters?

Managing water supplies will only get more difficult as our population grows and our climate changes.

As a result, we need to modernise the way we manage supplies by fitting meters across our region, helping to protect supplies for future generation.

Smart meters send us regular meter reads (hourly/daily/monthly), so we can:

• Give you frequent information so that you can be in control of your water use and your bill.
• Let you know if you have a leak on your external pipe.
• Give you accurate bills based on what you have used.
• Help you with any queries quickly.
• Measure the amount of water that is used by our customers so we can maintain our network more efficiently.
• Identify leaks on our network and act quickly to fix them.

More information about smart metering

Using the information we collect

We may use your personal data in the following ways:

• To provide you with our products and services, and to develop and improve those products and services;
• To ensure that the information we hold about you is kept up-to-date;
• To protect, manage and administer your account and provide you with bills and statements;
• To deal with any problems or complaints that arise in relation to your account;
• For assessment and analysis purposes to help improve the operation of our business;
• To prevent, detect and prosecute fraud and other crime; and
• For any other purpose for which you give us your personal data.

Sharing your personal data

We may share your personal data:

• with our employees, agents and/or professional advisors;
• with other third party contractors who provide services to us which require the processing of personal data;
• with third party payment providers who process payments made over our website;
• where we are under a legal obligation to do so, for example where we are required to share information under statute or because of a Court Order;
• to relevant authorities in order to prevent fraud and other criminal offences; and
• with credit reference agencies. (To find out more, explore the links below.)
• carefully selected partners, to introduce you to water related news, goods and services (by post, phone, email, SMS) that we think you’ll find interesting. If you don’t wish to be contacted for this purpose, please let us know by emailing us at [email protected]

Transferring personal data outside the EEA

In some cases we may transfer your personal data to countries outside the European Economic Area.

Where we do so we will ensure that such transfers are compliant with the Data Protection Act 1998 and that appropriate measures are put in place to keep your personal data secure

Credit reference agencies

We share your personal data with, and receiving your personal data from, credit reference agencies in order to help us maintain up-to-date customer records, manage our customer debt risk, and feed information into our debt collection process.

Information that we give and receive from credit reference agencies includes:

• information about your personal accounts with us and about your accounts with other organisations such as other utility companies;
• where you are the owner, director or partner in a small business, information about your business.
• In addition, credit reference agencies may provide us with public information about you such as County Court Judgments, bankruptcies and Electoral Register Information.

How do we use the information we receive?

The information we receive from credit reference agencies may be used in the following ways:

• to assess your account and decide what payment terms are appropriate
• to verify your identity
• To manage your personal account
• To maintain up-to-date customer records
• To manage our customer debt risk and our debt collection process
• To undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services

If you owe us money and do not repay in accordance with our payment terms, we will notify you of our intention to file a default. If your bill remains unpaid then we will notify our credit reference agency. This could result in your credit rating being negatively impacted.

The use of credit reference agencies for debt management

What is a Credit Reference Agency (CRA)?

Credit Reference Agencies give companies a range of information about potential customers, which companies use to make their decisions regarding their customer accounts.

The information shared may include information about your previous credit history and how you have repaid credit or bills in the past.

They hold certain information about most adults in the UK and collect and maintain information on consumers’ and businesses’ credit behaviour, on behalf of organisations in the UK.

This information is called your credit reference file or credit report.

CRAs may get information from places such as:

Publicly available information:

• The Electoral Register from Local Authorities.
• County Court Judgments from Registry Trust.
• Bankruptcy (and other similar orders) from the Insolvency Service.
• Credit information from information on applications to banks, building societies, credit card companies, and other companies such as energy and utilities companies, and also from the conduct of those accounts.

What personal information may be retained by CRAs?

The Personal Information section of your credit report may include items such as your name, date of birth and/or your current and previous addresses in addition to credit information which describes account details and payment history details that credit providers and other lenders have provided to CRAs.

How will Credit Reference Agencies use my data?

The information which we and other organisations provide to the credit reference agencies about you may be supplied by credit reference agencies to other organisations and used by them to:

• Check the operation of credit and credit-related Accounts
• Manage your personal, your partner’s and/or business (if you have one) credit or credit related account or other facilities
• Trace your whereabouts for debt recovery purposes
• Undertake statistical analysis and system testing

How will data NOT be used by Credit Reference Agencies?

It will not be used to create a blacklist
It will not be used by the credit reference agency to make a decision
It will not be used to create marketing lists

How can I get a copy of my credit report?

You can get a copy of your credit report from any of the Credit Reference Agencies.

Where can I get a copy of my credit reference file?

You are allowed to write to any of the credit reference agencies and ask for a copy of your credit reference file, be aware though that there may be fee involved. The information they hold may not be the same so it is worth contacting them all. Your letter should include:

• Your full name
• Any other names you have used or been known by in the last six years e.g. your maiden name
• Your full address including postcode
• Any other addresses you have lived at in the last six years
• Your date of birth; and the credit reference agency
• You should keep a copy of your letter and you may want to send it by recorded delivery. Unless the agency needs more information, they have seven working days from receiving your letter to provide you with a copy of your file.

How we use credit reference agencies (CRAs)

If I am a new customer, what steps will TWRC take in setting up my account?
Personal data of all new customers that join TWRC will be shared with the CRA that TWRC has chosen to work with.

What about if I am an existing TWRC customer? Will TWRC also share my personal data with CRAs?
Yes. We will periodically share existing account holders’ personal data with CRAs to ensure the accuracy of the information we hold and to manage your accounts appropriately.

What will TWRC do with my personal data that is obtained from the credit reference agencies?
With the personal data that we obtain, we may do some or all of the following:

• Assess your account and decide what payment terms are appropriate
• Verify your identity
• We may use scoring methods to assess our future relationship
• Manage your personal account with us
• Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services

What happens if I do not pay my water bill?
If you owe us money and do not repay in accordance with our payment terms, we will notify you of our intention to file a default. Further to this, if your bill remains unpaid then we will notify a credit reference agency, which could have an impact on your credit rating.

Who controls what credit reference agencies are allowed to do with my data?
All personal data shared with, and received from, CRAs is subject to the Data Protection Act 1998. Compliance with the Data Protection Act 1998 is overseen by the Information Commissioner’s Office (ICO) and all credit reference agencies are in regular dialogue with the ICO.

Can just anyone look at my data held at credit reference agencies?
No, access to your personal data is very strictly controlled and only those that are entitled to do so may see it.

What do I do if I think the personal data shown on my TWRC account is incorrect?
Please contact TWRC as soon as possible if you believe that certain details on your  TWRC account are incorrect.

Your rights

If you provide us with sensitive personal information, you consent to the processing of this information for the purposes which you have provided it.

You can request a copy of the information that we hold about you at any time by contacting us at the address below. The provision of this information may be subject to the payment of a fee.

You have the right to ask us not to process your personal data for marketing purposes. We will usually seek your consent if we intend to use your data for such purposes.

Please let us know if the personal data that we hold about you needs to be updated by emailing us at [email protected]

If you contact us by email, or provide your email address for us to contact you, we may use the details provided to contact you about anything to do with your query, or managing your account.

If you no longer wish us to contact you by email, please let us know and, if necessary, provide alternative contact details.

If you contact us by telephone, your call may be recorded for training and service-related purposes.

Communicating with you

From time to time we, and other companies in the TWRC, may tell you about water-related goods or services that we believe may be of benefit to you.

When we contact you for this purpose we will give you an opportunity to opt-out from receiving such communications in future if you so wish.

We may share your information with carefully selected partners, to introduce you to water related news, goods and services (by post, phone, email, SMS) that we think you’ll find interesting. If you don’t wish to be contacted for this purpose, please let us know by emailing us at [email protected].

Security

The security of your personal data is very important to us.

We will take appropriate technical and organisational measures to prevent unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data.

We will ensure that the personal information that you provide us via this website is held on secure servers.