Waterlink is part of South East Water. It carries out some of South East Water’s regulatory requirements such as assisting with customer side leak repair. However it is also the commercial arm of South East Water and provides commercial services to people in the South East of England. Its customers do not have to also be customers of South East Water.
Waterlink (“We”) takes care to protect and respect your privacy.
For the purpose of the Data Protection Requirements*, the data controller is South East Water Ltd of Rocfort Road, Snodland, Kent, ME6 5AH (company number 02679874).
This is our legal name and our trading name is Waterlink and we operate from Leitrim House (West
Wing), Coldharbour Lane, Aylesford, Kent, ME20 7NS.
* Data Protection Requirements means the Data Protection Act 1998 (or The Data Protection Act
2018), the EU Data Protection Directive 95/46/EC, 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 General Data Protection Regulation (from 25 May 2018) 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: Dataprotection@southeastwater.co.uk
write to us: Data Protection Officer, Waterlink, Rocfort Road, Snodland, Kent, ME6 5AH
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.
Waterlink strives 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.
The information you give us will include your name, address, e-mail address and phone number and occasionally history of your supply and consumption. 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 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.
Lawful basis for processing
We will only process your information if we have a lawful basis to do so. There are 6 lawful basis of processing as set out in the Data Protection Requirements and the ones that most apply to Waterlink are set out below.
Where we assist South East Water in carrying out its regulated activities we are acting in accordance with the legal obligations of South East Water to act as a statutory water undertaker, for example, promoting water efficiency by assisting customer side leak repair.
Where the activities are not strictly necessary for compliance with a legal obligation we may process your information in accordance with our legitimate interests e.g. carrying out market research or customer satisfaction or feedback surveys.
We always check that our legitimate interests are not overridden by your rights and that such processing is set out in this privacy notice.
Where you purchase any of our commercial services we will process your personal information to fulfil the terms and conditions of that contract.
What to expect when you contact us?
Contacting us by telephone
When you contact us by telephone and a service request is made we will look to collect your name, address and telephone number. This is so we can contact you during the lifecycle of your request, such as arrange an appointment or discuss further works.
Contacting us by email
If you email us, we will respond to you using the email address you gave us. Please try to avoid sending personal data by email as this is not considered to be a secure communication method. If a service request is made, your email address will be added to your request and may be used for future communications during the lifecycle of your request.
Any email sent to Waterlink, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance. Emails are also backed up and thereafter 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.
Contacting us by post
All letters are scanned and saved electronically. The hard copy letters are then destroyed.
How we can identify you
In order to ensure that we are speaking to the right person when arranging appointments to be carried out we will ask you to confirm your name and address.
Making a complaint
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).
We will only use the personal information we collect to process the complaint in accordance with our complaints process. For more detail see https://www.southeastwater.co.uk/media/1278/cop-if- things-go-wrong-2015.pdf
Visiting our offices
When you sign in to our visitor system you will need to provide information such as your name and vehicle registration number (if you are parked at our site).
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 South East Water premises this must be reported and will be recorded for the purposes of health and safety and insurance requirements.
Visiting 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.
atuvc utma utmb utmc utmz
These cookies are used to collect information about how visitors use our site.
We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
More information: Google Analytics
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
Works order from South East Water
As part of its statutory obligations, South East Water may send Waterlink to undertake works with its customers. This may be to enforce a leak repair where there may be wastage of water occurring for example.
Commercial Services to customers
Waterlink offers commercial services such as water audits, water conservation work, water testing, borehole spring and well works, leak detection and repair, pipework and plumbing and drain cleaning.
Waterlink acting for South East Water offers mapping searches as part of CON29D&W land searches during property sales to sewerage companies in the area.
Waterlink also provides maps of the mains in a particular location for a fee of £14.64 per map.
People who fall into arrears or fail to pay their invoices for works
The information that we hold about customers may be used to recover arrears and in doing so we may use lawyers, local authorities, the DWP and debt recovery or tracing agents, credit reference or fraud prevention agencies, in order to help us trace and collect money owed to us.
Potential Candidates for jobs at Waterlink
We will process the personal information you provide to us as part of your job application and there is a separate privacy notice for this on the South East Water careers web page.
Information we collect or obtain from others about you
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 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.
Information we share with others
We manage all arrangements for sharing your data with the strictest of care and would never sell your data to be used for marketing purposes.
The obligations that we have to our Regulators
Where we are acting for South East Water we may also have to comply with our legal and regulatory obligations we may provide personal data to the following authorities:
- Drinking Water Inspectorate
- Environment Agency
- Natural England
- Public Health England
- Environmental Health Authorities
- Local Authorities
- Police, Fire, Ambulance, and other emergency services
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 Service Incentive Mechanism. 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 don’t have any in place at present.
Circumstances where we can pass on personal data without consent
Information about the job would be passed back to South East Water and the customer account would be updated to reflect this.
Other third parties
If we merge with another business entity or divest a part of our business or carry out internal corporate restructuring, your information may be disclosed to Waterlink's new business partners or owners or the new corporate entities.
In the event that we sell or buy any business or assets we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Waterlink or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Waterlink, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
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. Our contracts detail how
personal data should be handled and protected while being processed by any third party. We conduct due diligence checks on third party processors to ensure they comply with their obligations to us.
We use software providers for different systems, like our works order system, to support us with the large amounts of data that we need to manage.
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.
Waterlink also uses a trusted partner service to help maintain the security and performance of the Waterlink 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
Please note that commercial services are limited in terms of the regulators it has and this will be a smaller list, for example, HSE and the police etc.
All customer personal data is held in our system in the UK, which has controlled access and is subject to strong cyber security measures. All access to our systems is strictly controlled. 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
Works orders and records of services provided will be kept for 7 years after the job has been completed.
E-mails sent to the Mapping department will be retained for 3 years.
Where you have requested one of our commercial services we may contact you with a follow up survey for market research purposes.
We will also keep your information on file and contact you within the following 12 months to ascertain whether you require further similar services from you.
If you have not requested any additional services in the following 12 months we shall no longer contact you in relation to the services we offer.
For customers who have completed the water hygiene training we will send one reminder just before the qualification is due to run out towards the end of the 3 year period to see if you would like to rebook your update qualification. I understand that I can withdraw my consent at any time and be removed from the reminder list by emailing firstname.lastname@example.org
We will contact you using the method of communication that you requested at the time of the purchase of the services. You can opt out of this contact at any time.
Automated decision making and profiling
We do not currently conduct any automated decision making, or profiling, as defined by the DPR.
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 a 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 one month of your request. There is no charge made for this by Waterlink.
To make a request to Waterlink for any personal information we may hold you need to put the request in writing (post or email) addressing it to our Data Protection Officer to the address provided above. If you agree, we may 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 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 email@example.com
Changes to this Privacy Notice
This privacy notice will be kept up to date as our business and internal practices and/or the Data Protection Requirements 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 Data Protection Requirements.
We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 27