It is important that you read this Notice so that you are aware of how and why we are processing your personal data and your rights.
Introduction
Pozitive Energy Limited is a company registered in England & Wales (registration number) with a registered office at The Octagon, 27 Middleborough, Colchester, CO1 1TG and is licensed as an energy supplier under the Gas Act 1986 and the Electricity Act 1989.
Pozitive Energy Limited provides energy and related services to customers. The personal data we process is used to manage our commercial relationship with you, comply with legal obligations and pursue our legitimate business interests.
We are the data controller of your personal data and we are responsible for deciding how we process personal information about you. This Privacy Notice sets out how Pozitive Energy Limited processes your personal data.
Any changes we may make to this Privacy Notice will be updated on our website and, where appropriate, notified to you in writing.
What data we hold?
We only process basic personal data. What is considered personal data depends on whether you are a domestic consumer, sole trader or corporate entity.
The personal data we collect includes personal data of individuals representing the entity contracting to our service provision and any additional contacts on the account, including your first and last name, email address and telephone number.
If you are a domestic customer, your personal data also includes address, your MPAN or MPRN, your consumption and meter details.
If you are a domestic customer or sole trader, your personal data includes payment information, including bank name, account number and sort code.
For certain domestic customers, we also collect the details of their eligibility for inclusion on our Priority Services Register.
Where do we get it from?
Your personal data is provided to us in a number of ways:
- By you when you contact us directly by phone or email, or when you use our website, including our customer portal
- From your smart meter
- From third parties such as brokers, Ofgem, other members of Pozitive Group
- From other industry participants, for example your incumbent supplier
What we use your data for?
We require your basic personal data to provide you with energy supply and related services in accordance with the contract between us (which may deem to occur under law) and the terms of our supply licence. That means we only request as much information from you as we need to carry out the activity you have requested or to enable us to carry out commercial transactions.
We may process your personal data to comply with legal obligations in connection with the terms of our supply licence, relevant laws or industry codes.
Your personal data may be used to pursue our legitimate business interests, provided that your legal rights do not override those interests. Your data will be anonymised when we use it to develop and improve our products and services.
We do use automated decision making when processing your personal data.
Your personal data may be shared with third parties to fulfil part of the contract between us and them to enable us provide energy supply and related services to you and to comply with legal obligations:
- Credit Reference Agencies (CRAs) in order to process your application, we will supply your personal data to CRAs and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.
- Organisations which provide us with customer management services in order to manage your account.
- Organisations which manage payments and direct debit instructions on our behalf in order to collect payments from you.
- Organisations that manage our meter estate and data in order to ensure that your metering is in a working order and you are billed accurately for your energy.
- Energy distribution companies, gas shipping companies in order to comply with legal obligations in our supply licence and industry codes.
- Revenue protection and debt collection services in order to enable debt recovery.
- Organisations that help you with complaints management in order to respond to a complaint you made about us.
- Industry code bodies in order to comply with a legal obligation, we supply information about customers who are subject to theft investigations and respond to requests for information about our customer base.
- Research agencies – in order to gain your feedback following a smart meter installation and other surveys.
Your personal data may be shared with brokers and other members of Pozitive Group to pursue our legitimate business interests in order to:
- Keep you informed of products and services that are available from us or may be of interest where permitted by law, including via our social media and digital communications.
- Test our IT systems to develop and improve the services offered to you.
- Ofgem in order to comply with legal obligations, we supply information about customers who benefit from the Feed-in Tariff or Smart Export Guarantee.
How data is stored?
Your personal data is stored in a secure, password-protected and encrypted bespoke database. It is accessible by our designated data processors only for the purposes stated above.
Outside the UK and/or EU
Your personal data may be processed in other countries and regions. At all times your personal data will be subject to the terms of this Privacy Notice and appropriate technical and organisational security measures to prevent the loss of or unauthorised access to your personal data.
How long your data is retained for?
Your personal data will be kept for as long as necessary to fulfil the purpose for which it was obtained as outlined above or as required by current legislation.
Your rights
Data protection laws provide you, as an individual, rights to:
- Right of access – you can request access to your personal information (a data subject access request), so you can check what data we hold about you and are using it in accordance with the law
- Right to rectification – you can ask us to correct personal information that we hold about you
- Right to erasure – you can ask us to delete your personal data where there is no good reason for us to hold this data. You can also ask us to delete or remove your personal information where you have exercised your right to object to processing
- Right to restriction of processing – you can ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
- Right to data portability – you can ask for a copy of the data we hold about you, in an accessible format and the right to transfer it, or to require us to transfer it directly, to another controller.
- Right to object to processing – you can object to the processing of your personal information and there is something about your particular situation which makes you want to object to processing on this ground.
No fee is required to claim any of these rights. However, we may charge a reasonable fee or refuse to comply if your request for access is considered to be unfounded or excessive.
You have the right to make a complaint at any time to the Information Commissioner’s Office. Their contact details are:
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF at.
However, please contact us in the first instance if you have any issue that you wish to discuss.
CONTACTING US
If you have any queries, comments or requests regarding this Privacy Notice you can contact our Data Protection Manager at datacontroller@pozitive.energy.