We can all benefit from a bit of extra help at some stages of our lives. This could be due to age, ill-health, disability, mental health problems, financial worries or language barriers. United Utilities helps thousands of customers every year through our priority services.
In order to carry out this service well, United Utilities needs personal information, often sensitive information, about our customers in order to plan and deliver our services.
At United Utilities, we are proud of our strong commitment to having high moral standards in the way that we work. We take our Data Protection duties very seriously and follow strict guidelines to protect your personal information, which is why we created this document to give you the comfort that your information is safe in our hands when you are added to our Priority Services Register (PSR).
United Utilities will, through appropriate safeguards, policies, procedures, training and controls ensure that:
- Personal data collected is processed in line with the requirements of UK Data Protection laws;
- Appropriate personal data is collected and processed only to the extent it is needed to fulfil operational needs;
- The quality of the personal data is maintained;
- Personal data is securely stored and in line with our Information Security Policy Framework;
- There are appropriate technical and organisational security measures to safeguard personal data;
- The length of time personal data is held is determined and it is not retained longer than necessary. In some instances the retention period is defined by legal or regulatory requirements;
- Personal data is only transferred to third parties that take similarly appropriate steps to ensure protection;
- Rights of people about whom the information is held can be fully exercised under UK Data Protection laws;
- We maintain documentation of our processing activities. We complete regular Data Protection Impact Assessments and regularly review our data protection policy and associated controls.
We offer a range of services which means we may have to collect and store specific information about you as a priority services customer, this is to provide you with specific support such as:
- Offering you a choice to have your bills in a readable format unique to your needs eg braille, large print;
- Informing our employees and partners of the support required prior to a visit eg knock and wait and the password scheme
- In the event or likelihood of a water incident, telling you about interruptions of water supplies
- Providing any extra assistance you may need for water billing purposes
The personal information we collect will be dependent on your needs and requirements, the description of individual needs we collect and hold are:-
- Blind/ Partially sighted
- Extreme financial difficulties so we can help if you are struggling to pay
- Dialysis, feeding pump and automated medication
- Mental health
- Developmental condition (eg learning difficulties)
- Medical Condition Dependant on Water
- Hearing loss (including speech difficulties due to deafness)
- Password on your account (bogus callers)
- A chronic or serious illness
- Unable to answer door or have restricted movement
- Hearing impaired
- Speech difficulties
- Pensionable age
- Unable to communicate in English
- Families with young children 12 months and under
- Temporary - Life changes
- Temporary - Post hospital recovery
- Temporary -Young adult householder (age 16 to 18)
We understand that certain health needs mean that some customers are unable to contact us themselves, so we can take registrations direct from our customers over the phone or via our on-line form, plus register customers via third parties in certain situations, such as:
- If you tell one of our employees or contractors that you suffer with a certain health issue or need extra support
- Another organisation has let us know about your additional needs. If we add you to the PSR because of this, we will let you know
- A trusted partner has shared your information as part of an incident or in the event of an emergency
- A carer or family member tells us you need additional support and would like to add you to our PSR
By registering with us you will automatically added to the registers of your electricity distribution network operator. Once you are registered you’ll be offered help from your electricity providers if there’s ever a problem. We may also share your information to assist in the event of an incident for example with your local council.
When we collect, use and share the information we need a lawful genuine interest and reason to do so. We use a lawful purpose of ‘substantial public interest’. This allows us to put the interests of our customers first, and we are allowed to accept registrations from third parties on your behalf or send to appropriate 3rd parties.
United Utilities holds personal and special category data in respect of customers who wish to join the PSR. For an organisation to process (store, use, share,) they must have a legal basis under the UK General Data Protection Legislation (Article 6) and if the data is special category (for example health data) then a further Legal basis (Article 9) must also apply.
United Utilities processes personal data under the following basis:
UK GDPR Article 6 (1) (f) Legitimate Interest
“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child”.
UK GDPR Article 9 ( 2) (g) substantial public interest.
“processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right of data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject”.
As we are relying on the substantial public interest condition we also need to meet one of 23 specific substantial public interest conditions set out in Part 2 of Schedule 1 of the DPA 2018.
Paragraph 6 permits us to record data for statutory, governmental and other related purposes.
Paragraph 18 Safeguarding of children and individuals at risk.
We will contact you or your nominee every two years to verify your personal information, that it is up to date and that your service needs are still relevant.
If you no longer require any of the priority services or no longer want to be on the register, you can contact our billing department and ask to speak to the Priority Services Team. We will review all requests and one of our priority service advisors will discuss this with you, as we want to ensure you are getting the service you need. There may be instances where we would have to object to the removal from our register, for example if you use a dialysis machine and/or are medically dependent on water.
We will review our policy on an ongoing basis, when there are changes to our processes and at least once a year.
Date created: September 2021