1. PURPOSE OF OUR PRIVACY STATEMENT
Under the Data Protection Act and the General Data Protection Regulation, we are required to explain to you why we are asking for information about you, how we intend to use the information you provide to us and whether we will share this information with anyone else.
2. Who are we?
We are Affiliated Utilities Ltd, and we are the Data Controller and Data Processor.
Our contact details are:
102 Great Clowes St
0203 603 6011
3. Our data protection officer
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to
The Data Protection Officer,
102 Great Clowes St
or email firstname.lastname@example.org
4. WHO IS THIS FOR
This privacy statement is targeted at all individuals we interact with:
- Our clients and customers.
- People we invoice as part of our billing services.
- Energy industry suppliers
- Members of the public
- Our own employees.
- Consultants and advisors.
- Other stakeholders we interact with to deliver our services
5. Why are we collecting your information?
We are collecting and or processing your information in order to fulfil our commercial purposes and provide the services of our company. For full list of our services, please visit our website www.clever-energy.co.uk.
6. What information are we collecting?
All the information we collect about you will be stored and used by us in accordance with this privacy statement and in accordance with your rights as described in Section 12 of this statement under the Data Protection Act and the General Data Protection Regulation.
Your personal data is most usually provided to us during the course of you entering into an agreement for the provision of our services. You will have entered into such an agreement with us by, using an online form on our website, delivering to us, by post or email, a signed letter of authority, or by entering into a verbal agreement with one of our agents on the telephone.
We may ask you directly for your personal data when we correspond with you by e-mail, letter or telephone, in order to fulfil our contractual obligations. This is data obtained by your consent.
The information which we collect about you through the above processes will typically be your name and contact information such as postal address, email address and telephone numbers, financial information, including banking and credit/debit card details, contact history, meter data that identifies and records usage of your gas and electricity supply, the details of your energy supplier including current contract status, and energy usage history.
7. What is the lawful basis for using your information?
In accordance with the data protection laws, we need a “lawful basis” for collecting and using information about you. There are a variety of different lawful bases for processing personal data which are set out in the data protection laws.
The lawful bases on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
We have a Legitimate interest in processing your personal data and it would not be possible to perform our function as an energy brokerage and or service provider, without processing your data.
Using your information is necessary to fulfil a contract you have with us (most usually because you are a supplier of Gas, water, electricity, hot water (through a communal or district heating network), or cooling system, and you have contracted with us to provide one of our services or products such as, billing, metering installation, metering monitoring and/or data collection, debt management, and pre-payment systems.
8. What are we going to do with your information?
We use personal data held about you in the following ways:
- To notify energy suppliers of our interest as your agent.
- To deal with and manage your energy contracts, as agreed in the letter of authority you provided to us.
- To take steps generally such as a responsible energy broker could be expected to, on your behalf.
- To resolve any issues with energy suppliers.
- To provide you where relevant, suitable reports, and keep you updated by way of our e – newsletter. ( which you can opt out at any time by pressing the unsubscribe link on the newsletter)
- To comply with any applicable legal obligation.
- To supply you with requested information.
- To fulfil any contractual obligations between us.
- To assist us in keeping our Products safe.
- Provided you have expressly opted -in; to provide you with marketing material about other goods and services that we provide that are congruent with those which we previously had correspondence or business dealings with you.
- To notify you about changes to our Products or Services which you have purchased from us and/or made enquiries about.
9. Sharing your information
Contractors and sub-contractors
DISCLOSURE OF YOUR PERSONAL DATA
It may be necessary to share your information with our contractors and sub-contractors so they can provide a service to you or to enable us to deliver our services.
We will ensure that a contract is in place between us and the contractor so that the contractors or sub- contractors will only be able to use the information while carrying out work on our behalf. They will not share your data. They will be required to adhere all relevant data protection requirements including GDPR.
Subject to a contract ensuring compliance with DPA and GDPR, we may share your personal data with:
- any department within Affiliated Utilities Ltd.
- Where we are contracted by a third party to provide any of our services on their behalf to you, we may share your information with that third party.
- Our sister company, Clever Energy Ltd.
- Third parties who can provide further associated services.
- Third parties for marketing purposes, if you have given consent.
- Potential, or actual, buyer(s) of any part of our business.
- Potential seller (s) of any asset to our business.
- A recognised statutory body or regulator, where we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or where there is legitimate legal basis to do so.
- Other companies, organisations, consultants, advisors, solicitors, legal enforcement agencies such as the courts or police, in order to:
- Recover a debt, obtain damages or other relief.
- Prevent fraud
- Reduce risk to credit
- Enforce our contractual terms
- Protect the safety, property, or rights of Clever Energy ltd, our clients or others.
10. Security of your personal information
We treat the security of your personal data very seriously.
Our security procedures, which are audited and reviewed, include:
- Storing your information securely on our electronic systems
- Storing, when necessary, using paper files, which will be held under lock and key.
- Only relevant staff members will have access to the information.
- Members of staff receive data protection training.
- External drive features are disabled on our computers.
- Our building is locked and alarmed when not in use.
- Any payment transactions will be encrypted.
- If you have a password in order to access any of our online services, you must keep it confidential.
- We shall notify you and the Information Commissioner’s office, as soon as we become aware that a personal data breach has occurred and we have procedures in place to minimize the damage that may be caused in those circumstances.
11. Storing your information and deleting it
We shall only retain personal data for as long as is necessary for the legitimate purposes for which the personal data is processed. When those purposes come to an end, we shall securely delete the personal data unless the retention of the personal data is required and allowed for in accordance with GDPR or other applicable provisions under the Data Protection legislation.
Your personal data will be stored within the European Economic Area (EEA). If it becomes essential for us to transfer your personal data to a country outside of the EEA we will ensure that your personal data has the same level of security as if it remained within the EEA.
12. Your rights
In relation to the information which we hold about you, you are entitled to:
- see a copy of the information;
- ask us to erase the information,
- request the rectification of inaccurate information.
- request that we restrict what we do with your information.
- ask that we stop using your information.
- Object to direct marketing based on your personal data.
- Request we transmit your data to another party.
- Have your personal data provided to you in a structured and commonly used format.
- If we are using your information with your consent, you are entitled to withdraw your consent at any time.
You can do this by writing to us at:
Unit 9, Knoll Street Industrial Park
or emailing email@example.com complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO who’s details are available at www.ico.org.uk.
Our obligations to comply with the above rights are subject to certain exemptions.
13. Making an application in respect of your rights:
Contact us at
102 Great Clowes
Manchester, M7 2RN
with your request
Provide proof of identity
Usually we will action the request within one month. If, however, the request is very complex or we receive a large number of requests, the time frame may be extended for a further two months.
14. Policy Review.
Our policy will be reviewed periodically and any changes will be posted on our website, and where applicable, you will be notified by e-mail.