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Privacy Statement

CONTACT DETAILS

 

Guernsey Electricity Limited, Electricity House, Northside, Guernsey, GY1 3AD

 

The Data Protection Officer, Guernsey Electricity Limited, Electricity House as above.

E-mail: Communications@electricity.gg

Telephone: 01481 200700

 

 

The Data Protection (Bailiwick of Guernsey) Law 2017 (the Law) recognises the importance of safeguarding individuals’ personal information and places legal obligations on those who collect, control, handle or “process” Personal Data. Guernsey Electricity (We, Us, Our) is regarded as a “Data Controller “under the Law and as such, is required to provide You (Your) with information about Our handling of Your Personal data in the form of this Privacy Statement.  We are also required to make You aware of other legal rights that You have under the Law.  Our staff are bound by the requirements of the Law and Computer Misuse Law applicable in Guernsey and receives periodic information security and data protection training.

 

If You are 16 or under, please ask Your parent or guardians permission before entering any of Our competitions or providing any Personal information to Us.

 

1 Where do We obtain Personal data from?

Personal data may be collected from You when You talk to Us or in writing, e.g. by letter, e-mail or completing a form such as application forms or enquiry forms which may be found on the Guernsey Electricity website or upon request.  We also collect information when you enter a GEL promotional competition.

 

Certain personal data is acquired via Ourwebsite using “Cookies” which are small pieces of information that are sent to Your computer's browser when You access a Website.  When a cookie arrives, Your computer's browser generally saves this information in a file on Your hard drive.  If You do not wish to allow cookies on Your hard drive it is usually possible for You to block or prevent Your Web browser from accepting the data necessary to enable this to be done.  This may however restrict some of the functionality that You might otherwise receive from the site.

 

Guernsey Electricity uses cookies in the following ways;

 

Purpose of Cookie

Description

Anonymous Analytics

These cookies are used for statistical purposes and enable us to develop the website.  Statistical information will be kept in an anonymous format so that it will not be possible to identify any individual.

Targeted Marketing

Cookies are used by embedded adverts to target marketing based on the websites that you visit.

Other Third-Party Cookies

Other organizations may use cookies to track that you have visited our site.  We are unable to access these Cookies from our site.

 

We may also collect your IP (Internet Protocol) address.

 

Information may also be obtained from other people acting with Your approval or knowledge, on Your behalf, e.g. by family members, or professional advisors.

 

Data may be collected about You from commercial sources, for example for credit control, marketing, public relations or recruitment purposes, such as references from previous employers or by police disclosure.

 

Data may also be collected from publicly available sources such as social media, public records and newspaper reports. For information relating to our Social Media policy please see /social-media-policy/.

 

2 Why do We collect and how do We use Your Personal Data?

 

We collect and use Personal Data for a variety of purposes to enable Us to connect and communicate with You to enable Us to conduct and manage Our business relationship and provide goods and services to You to meet Your requirements. The Law requires that we have a “legal basis” (or lawful reason) for collecting and using any Personal Data. These are described in more detail in section 3 below.

 

For example, if You are a Customer, that is, a person who receives a supply of electricity from Us, We will collect Personal Data for reasons including;

 

 

Purpose of Processing

Legal basis

Further information

1

To provide You with a supply of Electricity

Contract

We have a responsibility under the Electricity (Guernsey) Law, 2001 to offer You contract terms to provide an Electricity Supply.

2

To provide You with the necessary electricity cables and equipment to make sure Your Supply is adequate for your electricity needs.

Contract

We will provide a Contract/Quote for this work when the work is being done at your request or We may undertake works to enable Us to develop & maintain the Electricity network for all of Our Customers.

3

To provide You with Electrical, Plumbing and other Services.

Contract

We will provide a Contract/Quote for this work when the work is being done at your request.

4

To provide You with retail products and "follow up" services and support e.g. Ordering, Delivery, access to Manufacturers warranties and aftersales support.

Legitimate Interest

The information is required for accounting and/or operational purposes e.g. to record a sale, arrange delivery of goods, to provide after sales service or for dealing with general customer matters.

5

Customer Administration, Billing, Meter Reading, Enquiries, Complaints, Claims and Debt Recovery.

Legitimate Interest

To enable Us to manage Our relationship with You, resolve any queries or issues and ensure that We receive all revenues due.

6

Direct Marketing and Promotional Competitions

Consent

To allow Us to keep You informed of any Product or Service offering that You may be able to benefit from.

 

We cannot use Your personal data for Marketing without Your clear and freely given consent. You have the legal right to withdraw Your consent at any time.

7

Hire Purchase or other Credit Finance.

Contract

Where You purchase goods using HP or another form of credit.

8

Statistical / management and planning Purposes.

Legitimate Interest

e.g. Sales figures Electrical consumption.  This data will usually but not always be anonymised.

9

Testing Electrical Installations.

Public Authority

Required by the Guernsey Competition & Regulatory Authority.

 

 

 

 

Typically, the information collected will consist of some or all the following details:-

 

 

Full Name

Phone number (s)

E-Mail Address

House / Building name

Street (optional)

Parish / Town/ City

Post code

Meter number

Customer number/reference

 

In addition, We collect information for specific purposes.  For example, if You require a new connection, or altered electricity supply to your premises, We would require additional information regarding Your premises, Your electricity usage profileand Your future requirements.  We will also need the contact details of any persons that You have employed to act on Your behalf so that We can work with them as necessary.

 

For identification purposes and where appropriate, We will collect and record information, such as Your Date of Birth. This information will be used as a security measure to ensure that We are dealing with the correct person.

 

We collect financial information such as Bank Account details for collection of payments for electricity supply. Debit and credit card details used for transactions over Our Website are NOT collected or stored.

 

Some features on Our website such as “PAY360” require You to registerdetails such as Your e-mail address and Your customer number.  Access to the online account will require you to input Your e-mail address and Your password.  We will store your e-mail address to enable Your use of this service. If You wish to un-subscribe please e-mail customer@electricity.gg

 

In addition, We will also collect Personal Data if

 

a)     You have a question, complaint, claim or general enquiry about anything relating to our activities, services or products, We will keep a copy of the correspondence, together with any other relevant details that will enable Us to deal with the matter satisfactorily and as soon as possible.

 

b)     You are a landowner, leaseholder, tenant or property developer.  We will process Personal Data in respect of property negotiations or agreements relating to electricity mains services or other electrical equipment on privately owned land.  We also maintain a geographic information system (GIS) database.  Information is also kept in relation to tenancies and leaseholds in respect of properties owned by the Company.  We also offer a” ClickB4UDIG facility, which is a free online and telephone service that enables you to check for cables on your property before carrying out any excavation or other works.

 

c)     You are a contractor. We hold information to enable Us to control any work that might be carried out and toenable Us to order and pay for goods and services received.

 

d)     You are a past, present, or prospective Employee. Data is recorded toenable the every-day working relationship between the Company and the employee.

 

If you are considering seeking employment with Guernsey Electricity Ltd, Your enquiry/application will remain private and will stay on Our records for a period of 6 months if your application is unsuccessful and for the duration of Your employment if successful.  We shall not disclose any of Your details or information to anyone, except the people handling submissions.

 

See also  https://www.electricity.gg/about/careers/

 

e)     You are a Director, Officer or Shareholder of Guernsey Electricity Limited.

 

 

 

 

Other

 

Statistical data.  We may also collect and use Your Personal information for business and statistical planning, e.g. Sales information and electricity consumption analytics.  This data will usually be pseudonymised so that Your data will not be recognisable as relating to You.

 

Marketing and Promotional Activity.We can only use Your Personal Details for marketing or promotional purposes with Your specific and clear consent.  You can withdraw Your consent at any time.

 

 

3. What Legal authority do We have to Use Your Personal Data?

 

The legal bases for Our use of Your Personal data for the most part is either “Legitimate Interest” or Contractual.

 

Legitimate interest This is a wide-ranging basis which covers, for example, all those matters which You would reasonably expect Us to need to keep and use Your data for on a day to day basis, such as administering Your Electricity account or dealing with Your enquiry.  

 

 

Contractual This is a much clearer basis and may be used if, for example, You are an employee (Contract of Employment), a Supplier (Contract for Services) or a Customer that requires a supply of Electricity (Application Form).

 

Consent is the legal basis for processing Data in relation to Marketing and Promotional activities.  Your Consent can be withdrawn at any time by contacting Our Communications team, by email at Communications@electricity.gg.

 

Guernsey Electricity Ltd, as the Island’s primary generator, distributor and provider of Electricity may be regarded as a Public Authority and this may be used as a legal basis for holding Personal Data in some scenarios.  An example of this is testing electrical installations, as required by the Guernsey Competition and Regulatory Authority.

 

In addition to the above, We may also be obliged to disclose Personal Data, to Public and Regulatory authorities, Law enforcement agencies and similar official bodies.

 

4. What “Special Categories” of Data are collected?

 

Some Personal Data is treated as falling within a special category if it is of a sensitive nature.

 

Health Data. Guernsey Electricity offers additional services for vulnerable customers e.g. the elderly and infirm.  Customers can apply to be included on this register.  Health Data will also be kept where it is reasonably necessary to do so in respect of employment, health and safety, and legal and insurance matters.

 

Criminal Data. This information will be kept where it is reasonable and necessary to do so, including such areas as “pre-recruitment vetting”, investigating and handling of any crime or suspected crime, insurance claims, vandalism to property or damage to the electricity network or fraud.

Trade Union Membership. For paying subscriptions from members.

Bio Metric data. CCTV footage and photographic images

Security: Guernsey Electricity seek to ensure the security and safety of Our staff, premises and systems against criminal damage or anti-social behaviour by employing CCTV camera coverage.

 

 

5 How long is Your Personal data stored?

 

We will only retain Your Personal Data for as long as is reasonably and legitimately necessary.  

 

We will take care to ensure that the data retained is relevant, and accurate. To assist Us in this, although We will periodically confirm Your details with You, We would ask that You update Us of any changes to Your Personal Data.

 

We will retain Personal Data, in relation to Your Electricity supply and Electricity Accounts whilst You remain  a customer or whilst Our business relationship remains.

 

We will retain certain Data for a period as required by law or as may be necessary for tax purposes.

 

Personal Data relating to contractual, legal or insurance matters or disputes may need to be retained for legal and evidential purposes for a minimum period of six years. And in some types of personal injury cases, it may be necessary to retain records for significantly longer.

 

General “everyday” communications, orders and invoices will be retained in most cases, for a period not exceeding two years after the matter is resolved.

 

 

6. We may share Your Personal Data with the following:

 

a)    You.  In response to a query concerning your account.

Please note that We can only provide information about property that You own.

 

b)    Relatives, Guardians or persons associated with You or acting on Your behalf.  We will only share information with relatives or persons associated with You or who are acting on Your behalf, with a) Your agreement and knowledge (e.g. a professional advisor acting on Your behalf) and b) Your instruction or written permission for Guernsey Electricity to share the data.

 

c)    Employees and agents of Guernsey Electricity. From time to time it will be necessary to share your Personal Data with Our staff and agents in the ordinary course of business.

 

d)    Business associates, lawyers, insurers, medical, and other professional advisors.We may need to share Your information with these professionals to meet and deal with any matter that You might wish to draw to Our attention.

 

We would also need to share Your data with Our professional advisors where for example You have appointed a professional advisor (e.g. an architect) and / or We need to appoint an advisor to enable and assist Us to resolve any query or issue or provide any services that You may have raised or require.

 

We may need to share Your information with Our Insurers and / or Our legal advisors in the event, of any insurance claim or potential claim or any legal matter which involves or, might involve, Us.

 

We will share, with Your consent, personal information with Our advertising, marketing and public relations business associates.

 

e)    Government, Public Authorities/Services, Law Enforcement and Security Services, Non -government entities, Regulatory Authorities, Courts and tribunals.

 

We may in certain circumstances be obliged by law, to disclose Your Personal Data to the above.  However, in addition, such information may also need to be shared with these bodies to deal with any correspondence, query complaint, claim or any other matter.

 

f)     Suppliers of Goods and Services

 

We will share Your Personal Data about goods and services supplied where it is necessary, amongst other things to:

 

a)     Order or obtain and deliver an item purchased from Our Showroom or otherwise, and where possible, provide You with after- sales assistance.

                                                     

b)     Activate Suppliers Warranties and Guarantees.

 

c)     Order or arrange a “job-sheet” or quote for electrical contracting etc, instruct sub-contractors if used.

 

d)   Deal with any complaint or issue regarding any item supplied or work carried out.

 

e)   In addition, We will share information with companies or organizations which undertake, on an “outsourced” contractual basis, certain business processes, such as for printing and post out all electricity bill to Our customers, on Our behalf.

 

g)       Financial Organisations and Advisers.  Thisincludes credit reference agencies and debt collection and tracing/ investigation agencies.

 

h)      Survey and Research Organisations

 

We may use Personal information for Statistical, Management and planning purposes which may include planning marketing campaigns.  As mentioned previously, Your Personal Data will not be for marketing purposes unless You have given Your consent and have not You have not withdrawn it.

 

Statistical information in anonymous aggregate form, may be supplied to interested parties such as States departments, suppliers, trade bodies and consultants undertaking work on behalf of Guernsey Electricity.

 

i)        The Media (including social media)

 

If You have consented to the use of Your Personal Data for marketing and promotional activities, We may share Your Personal Data with the Media for those purposes.

 

We may share anonymised information with third party such as analytics and search engine providers to enable us to develop and improve Our website.

 

j)        Automated Payment Process - Credit and Debit Card Information

 

You may wish to pay an account using Your credit or debit card via our online payments facility.  To facilitate this, We have secured the services of a company known as Paypoint.net which is a secure, online, real-time payment service provider, supporting all major credit and debit cards.

 

We will ask You to supply Your customer reference, name, amount to pay, supply address and email address.  This information may be kept for a period of up to 6 years for accounting purposes by Guernsey Electricity.  You will then be transferred to a secure payment area maintained by Paypoint.net where You will be prompted for Your credit/debit card details to complete the transaction.  This will process Your payment and provide Us with confirmation and details of Your payment.  These details include Your IP address.  This information is retained for 6 years as part of Guernsey Electricity's accounting records Credit and Debit Card numbers are not collected through the payment process.

 

 

7. Personal Data shared outside of the European Union or an Authorised Jurisdiction

 

We have a policy of preferring to store Personal Data only in “equivalent jurisdictions” (which means places where there are data protection laws which give at least as much protection to Personal Data, as does the Law). However, there will be cases where it is necessary or desirable to store Personal Data in other “non-equivalent” jurisdictions. In these cases, We will do so only where adequate contractual provision can beagreed between Us and the person storing the Data or where Your written consent is obtained.

 

 

8. Automated Processing

 

  1. 1.     Automatic Meter Reading

Automatic meter reading technology is in use for the majority off properties on the Island.  Electricity meters collect and transmit meter readings to Guernsey Electricity Limited automatically. The information collected is stored in various receiver units within the Electricity network until it is downloaded to Our central database.

 

The automatic meter reading technology has the technical capability to record energy consumption readings at intervals and allow profiles of consumption to be plotted accordingly.  The ability to produce load curves if required allows us to identify system faults or losses or answer customers’ queries and provide customers with energy efficiency advice in respect of their electricity consumption.

 

  1. 2.     Automated Payment Process Billing

 

A computerised automated system is used for most tasks relating to credit control management including making decisions regarding the following;

 

a)     Determining the amount of a money required as a monthly standing order to cover the expected electricity consumption to be used for the year and / or recover outstanding amounts.

 

b)     Determining whether a security deposit, as permitted under the Electricity (Guernsey) Law 2001 is required from a Customer.

 

c)     Determining when and which automated credit control related letters need to be sent to You up until the point when it becomes evident that manual intervention through the Law.

 

9. Important – your legal rights

 

The Law grants You a number of significant rights to which We are obliged to draw Your attention as follows. If You have any questions about them You should contact Our Data Protection Officer at the address shown. Please note, however, that We cannot give legal advice on Your rights, and You should seek Your own independent advice or contact the Guernsey Data Protection Authority at the following address;   

 

Data Protection Authority

Guernsey Information Centre

North Esplanade

St Peter Port

Guernsey

GY1 2LQ

 

Your Important Legal Rights. 1

Conditional Rights

(depends on certain circumstances)

Notes

 

Provided another person’s interests & Personal Data is not disclosed, as a result, you may on request and free of charge, seek confirmation as to whether any Personal data about You is held for business purposes.

A single copy of the Personal Data must be provided to You, free of charge.

 

To object to Your Personal Data being processed if;

 

a)  because it is of public interest

 

or,

 

b)  it is of historical interest

 

or,

 

c)  it is being used for direct marketing purposes.

 

To correct, change or rectify any Personal Data e.g. which is wrong or misleading.

 

 

 

To have Personal Data corrected (rectified) or erased.

 

To restrict the extent to which Your Personal Data can be processed or Used.

 

To be informed when data is rectified, erased, or restricted.

 

.

To prevent decisions from being made about you by an automated process

e.g. a computer programme might be used in deciding whether to make credit available.

 

Providing another person’s interests & Personal Data is not disclosed, as a result You have right to have Your Personal Data transferred from one data controller to another without interference (e.g. undue delays etc.) from the data controller.

For example, if You were changing banks.  The bank You would be leaving must co-operate with Your new bank to enable Your new account to be set up.

 

 

Your Important Legal rights 

 

Your Important Legal Rights. 2

Conditional Rights

(depends on certain circumstances)

  Notes

To make a complaint to the Data Protection Authority (DPA) if You are unhappy about how Your data is being handled or used or not in keeping with the law.

 

  The DPA will consider Your complaint and         providing it considers it to have reasonable   grounds and is generally appropriate, carry out   an investigation.

To take legal action against the DPA if You are unhappy with their response to Your complaint or the conclusions reached after an Investigation.

 

You may appeal against any decision made by the DPA and seek a ruling from the Court concerning Your original complaint.

 

Where You have given Your specific consent for Your data to be processed and this is the “legal basis” of processing You have the right to withdraw it. To do this You should contact Communications@electricity.gg.

For example, if You have given Your consent to receive direct marketing.

 

 

 

IMPORTANT

The details above are not nor intended to be a definitive statement of the law of data protection as applied in Guernsey and should not be taken as legal advice. Nor are We able to give any legal advice on any matter referred to in this Privacy Statement.

Please note that We keep this Privacy Statement under constant review and that its content may vary from time to time.

If You do have any questions complaints or concerns or any other matter relating to data protection at Guernsey Electricity, please contact Us, preferably in writing, to the address below:

Postal Address: The Data Protection Officer, Guernsey Electricity Limited, Electricity House, Northside, Guernsey, GY1 3AD. E-mail Communications@electricity.gg. Telephone 01481 200700. Website: https://www.electricity.gg