Privacy and Cookie Policy

This privacy notice explains what personal information we collect, how we use it and your rights in respect of your personal data.  We may provide additional tailored privacy notices on specific occasions that will inform you of how and why we are using that particular information.

This privacy notice will be reviewed and updated on a regular basis.

Information that we process

We process personal information in a number of ways to enable us to carry out our following duties:

• consideration and investigation and mediation of customer complaints;
• provision of advice and information;
• responding to information requests;
• maintenance of our own accounts and records;
• supporting and managing our Board Members, Consumer Advocates and employees;
• sending communications to stakeholders about the work we do;
• recruitment;
• commissioning of research;
• internal support functions (suppliers etc.).

Types of data we collect

We process information relevant to the above reasons/purposes which include:

• Name;
• Address;
• Telephone number (including mobile number);
• Email address;
• IP address;
• Details of enquiries, complaints, incidents and grievances;
• Responses to customer satisfaction surveys (via our research provider ORS);
• Freedom of Information and subject access requests;
• Subscriptions to our e-newsletters, social media sites, or requests for our publications;
• Personnel files of employees, Board members and Consumer Advocates including pay details data relating to current and former employees;
• Images of individuals for our publications;
• Information from our suppliers.

The legal basis for processing your information

CCW processes personal information under the following legal bases:

• Article 6(1)(a), Consent – the data subject has given consent to the processing (consent has to be specific, informed, freely given and unambiguous). Where you have given your consent to the processing you should be informed that you have the right to withdraw consent at any time.
• Article 6(1)(b), Contract – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Article 6(1)(c), Legal obligation – CCW processes personal data for compliance with a legal obligation to which we are subject.
• Article 6(1)(e), Public task – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
• The processing of special category data is only permitted when certain further conditions in Article 9 of the GDPR are met. In most circumstances CCW’s legal basis for processing special category personal data is covered by:-
  • Article 9(2)(a) – the data subject has given explicit consent to the processing of those personal data.
  • Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
  • Article 9(2)(g) – processing is necessary for reasons of substantial public interest … which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject.
  • Article 9(2)(h) – processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health and social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.

Customer complaints and enquiries

Why we need your information and how we use it

We need to collect and hold personal information about you in order to manage and investigate your complaint or enquiry and to obtain customer feedback to improve the services we provide. If you complain to CCW about your water company, we will hold the information you provide to us securely and use it to help us to process your complaint.

CCW will process your personal data in order to carry out our legal duties. In relation to complaints, this is specifically to enable CCW to investigate complaints about water and sewerage companies and retailers.

We may also use your information for training, monitoring and service improvement purposes. Failure to provide your personal data may make it difficult for us to investigate your complaint or enquiry effectively.

How we collect and process information from you

When you contact us with a complaint, whether this is by telephone or through our web form, we will ask for your name, address, contact number and email address. We will also ask you what your complaint is about, including which water company or water retailer it relates to. So that CCW can deal with all complaints fairly, complaints sent to other CCW departments, including the Chief Executive, will be forwarded to the Consumer Relations team for review.

Your call may be answered by our third-party call handling service and the data it collects is sent securely to us. We have contractual clauses in place to ensure that the information you provide to this organisation is protected to the same standard as if it was provided directly to us.

CCW records all calls made to and from its Customer Relations Team. This is the team that handles complaints. These call recordings will be used to assist in quality monitoring of staff and to investigate and resolve a complaint. You may request that we delete your call records. Callers that do not want their call to be recorded will normally be advised to contact us either in writing or by email.

How and why we share your information

Your information may be shared internally with CCW staff in relevant departments in order that we can handle, investigate and respond to your complaint. We may also share details of your complaint with third parties such as your water company in order to investigate your complaint. For example, as part of our investigation into your complaint, we may contact the water company that is the subject of your complaint to request further information and to clarify aspects of the complaint.

We may also share information about you with the following:

• Where you have agreed so, a member of your family, associates, or someone who represents you in relation to your complaint or enquiry.
• Where we receive a complaint that falls under the jurisdiction of another organisation such as the Water Services Regulation Authority (Ofwat), the Drinking Water Inspectorate (DWI) or the Environment Agency (EA). In this situation, we will not share your personal information without your consent.
• Where we have agreed to source a legally binding decision from our outsourced Alternative Dispute Resolution partner, your information will be shared with them in order to secure a decision.
• If you are dissatisfied with our handling of your complaint and contact the PHSO we will share the information the they request with them.
• Research companies appointed by CCW to obtain customer feedback to improve the services we provide.
• We may also share your information with other organisations, such as government departments, and the police if we think it is necessary to do so.

CCW publishes an annual summary of activity in relation to complaints and enquiries received, including complaints accepted by the Parliamentary and Health Service Ombudsman. This summary does not include any individual’s details or personally identifiable information.

Where your personal information is stored and how long we keep it

We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it.  If you send CCW paper documents, disks or USB’s containing information about your complaint w we will upload these to our secure system and, unless you ask for them to be returned to you, the originals will be destroyed.

Your personal data will be stored securely in CCW’s complaints handling/case management system and in our telephony system. It may also be stored in other CCW systems as we investigate your complaint, for example, in our email system.

CCW will hold written details of your complaint, including your personal data, for six years after the date of case closure. Recordings of calls made to and from the Consumer Relations team will be held for 12 months after the date of the call.

Recordings of calls made to our third-party call handling service and the data that it sends to us will be retained by the supplier for up to 60 days.

Cases managed by our outsourced Alternative Dispute Resolution partner will be retained by them for six years after the date of case closure. Should the outsourcing contract end during that period the case files will be returned to CCW who will retain the information for the remainder of the period.

Research

We commission research companies to undertake research projects for us.  For some of our research work we have established a ‘research community’ that we contact on a regular basis. Our lawful basis for processing personal data for this work is consent.

Our people

Recruitment

All information provided to us, or our recruitment partner Greenbean, during the recruitment process will only be used to progress applications, or fulfil legal/regulatory requirements. We hold the information securely whether it is held electronically or physically.  We use your contact details for the recruitment process and other information to assess suitability for the role you are applying for.

We use a third party organisation to carry out background screening of successful applicants for us and will share the successful applicant’s, name, address and email address with the processor. This information is held by the processor for six months.  Our lawful reason for processing this data is it is necessary to take steps prior to entering into a contract – Article 6(b) GDPR.

Employees, Board Members and Consumer Advocates

For existing employees, Board members and Consumer Advocates we process the following information:

• Contact details;
• Pay details;
• Annual leave;
• Sick leave;
• Qualifications;
• Training;
• Performance;
• Ethnicity;
• Disability details;
• Employment history.

Our lawful basis for processing this information is that it is necessary for the performance of a contract. Sensitive information is processed under Section 9(2)(b) – employment. We keep personnel files for six years post-employment.

Supplier information

Personal data of suppliers whether they are an individual or an individual acting on behalf of an organisation is processed by CCW as  it is necessary for the performance of a contract. The information processed includes name, contact details and payment details. We hold this information for six years plus the current year.

Feedback on our website and water meter calculator

We ask customers to include their postcode when inputting information relating to their assessed water consumption the water meter calculator on our website. This information is held internally in order for us to assess customer usage of the application. The lawful basis for us to process this information is for the performance of a task carried out in the public interest.

To make improvements to our website and water meter calculator we ask visitors to give their feedback. The basis of lawful processing we use is Article 6(1)(g) of the GDPR legislation 2018. The processing is necessary for the performance of a task carried out in the public interest. We delete the data after two years.

We use Survey Monkey to process this information and you can read their privacy statement here.

Individual’s images for our publications

On some occasions we may use an individual’s image, voice, or video footage of an individual at our events for our literature. We process this information under the lawful basis of Article 6(1)(a), consent of the individual.

Mailing Lists

We keep stakeholders up-to-date about our customer research reports that we conduct, our annual reviews, Forward Work Programme, stakeholder events and our newsletters.

The success of our email campaigns is measured by looking at the analytics of open rates, click-through rates and the subscriber list growth for our newsletter. For our communications through our stakeholder database, CCW’s lawful basis for processing information is necessary for the performance of a task carried out in the public interest particularly helping stakeholders to engage with CCW’s work.

Individuals can sign up to our newsletters through our website. We process this information with consent of the data subject.

For communications we use a free version of MailChimp that allows up to 2,000 subscribers. We have multiple lists according to each campaign we send which varies in size.

For more information, please see MailChimp’s privacy notice (now apart of Intuit!). You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any of our emails.

How your information is stored and deleted

Customer information is stored electronically on our complaint management system, other information is stored on our secure servers.  The data will not be transferred outside the United Kingdom or European Union.

For more information, on how long we keep your personal data please see our data retention policy.

Keeping your information up to date

If your contact details or other personal information change or if you think that the information we have isn’t accurate. Please contact us as soon as possible.

Governance

As we are classified as a public authority, we have appointed a Data Protection Officer (DPO) to ensure we comply with data protection law. Our DPO operates with independence and is supported by suitability skilled individuals granted all necessary authority. The DPO’s duties include:

• Informing and advising CCW and its employees who carry out data processing pursuant to data protection regulations, European Union or other Member states data protection provisions;
• Monitoring compliance in relation to the protection of personal data, including providing relevant training to employees involved in controlling customer data;
• Providing advice and guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);
• Operating as a point of contact for and cooperating with supervisory authorities, notably in the event of any data breaches;
• Implementing and operating a register or system which records requests for information;
• Reviewing personal data, ensuring that any data which is not necessary to be retained for longer than is necessary is effectively destroyed or obfuscated to reduce CCW’s compliance footprint;
• Updating CCW’s data protection, privacy and cookie policies to reflect operational changes as a result of audits and corrective actions;
• Ensuring employees are fully briefed on any changes made to CCW’s data protection, privacy and cookie policies.

How CCW protects your personal data

CCW takes the security of your personal data seriously and has internal policies and controls in place to protect your data from loss, accidental destruction, misuse or disclosure. Some of the ways in which CCW protects your personal data include:

• Implementing appropriate technical and organisational controls to protect the confidentiality, integrity and availability of personal data and information
• Regular review of CCW information assurance and security policies and procedures
• On-going training and awareness for staff on data protection and security
• Use of the government Supplier Assurance Framework and Crown Commercial Services frameworks when working with suppliers and third parties
• Regular review of security and cyber risks

Your rights over your personal data

CCW is committed to being transparent about how it collects and uses your personal data and to meeting its data protection obligations. CCW is a Data Controller under data protection legislation and we comply with the data protection principles when processing your personal information.

Under data protection laws, you have a number of rights. You can:

• Access and obtain a copy of your personal data
• Require CCW to rectify/change incorrect or incomplete personal data
• Require CCW to delete/erase your personal data
• Request CCW to restrict the processing of your personal data (in certain circumstances)
• Request your personal data in a portable format
• Object to the processing of your personal data

If you would like to exercise any of these rights you should contact CCW’s Data Protection Officer via email at [email protected]. You can also write to the Data Protection Officer at:

CCW
23 Stephenson Street
Birmingham
B2 4BH

How to find out more

The Information Commissioner’s Office (ICO) is the UK’s independent body set up to uphold information rights. If you would like to know more about your rights under data protection laws, and what you can expect from us, please visit the ICO website at www.ico.org.uk.

Complaints

If you believe that CCW has not complied with your data protection rights you should contact its Data Protection Officer in the first instance. You can also complain directly to the Information Commissioner at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113

Changes to our Privacy Notice

We may amend this privacy notice and will update it to reflect feedback or make it more accessible. We recommend you regularly read this to be informed how we are protecting your privacy.

Alison Townsend is our Data Protection Officer. Should you have any concerns about your personal data held by us please contact us at [email protected].

This notice sets out how CCW will use respondents’ personal data for the purposes of its Draft Strategy and Forward Work Programme (FWP) for 2024-25 consultation and explains their rights under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).

The data controller for any personal data collected as part of this consultation is CCW, the contact details for which are CCW, 23 Stephenson Street, Birmingham, B2 4BH [email protected]

The data – data subject categories

This consultation is open to all interested persons and organisations. Therefore, personal information that we will collect could relate to members of the public, parliamentarians, and representatives of organisations and companies.

The data we will collect – data categories

Information will include the name, address, email address, job title and where relevant the employer of the correspondent, as well as their opinions and answers to the questions posed by this consultation. It is possible respondents may volunteer additional identifying information about themselves or third parties.

Legal basis of processing

5The processing we will conduct is necessary for the performance of a task carried out in the public interest – namely, consulting on policies or proposals, or obtaining opinion data, in order to develop good and effective policies.

Special data categories

Although not being requested, it is possible that special category data may be processed if such data is volunteered by the respondent.

Legal basis for processing special category data

If special category data is volunteered the legal basis relied upon for processing will be explicit consent of the data subject.

Purpose

The personal information collected will be processed in order to obtain the opinions of interested persons and organisations about CCW’s policies, or generally to obtain public opinion data on an issue of public interest.

With whom we may share responses – and confidential information

Information provided in response to this consultation may be published or disclosed in accordance with the access to information regime. These are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 2018 (DPA) and the Environmental Information Regulations 2004 (EIR).

If a respondent wishes the information they provide to be treated as confidential, please be aware that under the FOIA there is a statutory code of practice with which public authorities must comply. It deals with, amongst other things, obligations of confidence.

In view of this it would be helpful if respondents could explain to CCW why they regard the information they have provided as confidential. If we receive a request for disclosure of the information, we will take full account of the reasons provided, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on CCW.

Where someone provides special category personal data or personal data about third parties, we will endeavour to delete that data before any publication takes place.

How we will use your response

When the consultation has closed we will analyse the responses. When we publish the final Strategy, in March 2023, we will publish the responses we received in full unless you ask us not to. We will not include personal details but will include, where appropriate, the name of organisation represented unless you ask us not to.

How long we will retain data provided

For this consultation CCW will keep your personal data (if provided) for a period of 1 year after the close of the consultation.

Your data and rights

Your personal data:

• will not be sent outside of the European Economic Area
• will not be used for any automated decision making
• will be kept secure

Rights of respondents

Respondents have the following rights in relation to this consultation:

• access personal data relating to you
• have all or some of your data deleted or corrected
• prevent your personal data being processed in some circumstances
• ask us to stop using your data, but keep it on record

If you would like to exercise any of these rights, please contact [email protected] or the use address at paragraph 2 above.

Complaints

If a respondent has any concerns about the use of their personal data, they should contact our Data Protection Officer at [email protected]

If we are unable to address your concerns to your satisfaction, you can make a complaint to the Information Commissioner, the UK’s independent regulator for data protection – Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or [email protected]

Our website www.ccw.org.uk uses cookies to collect and store information.

Cookies are small text files placed on an individual’s computer and other mobile devices upon browsing our website. They are used to collect standard internet log information and visitor behaviour data. We may use the information stored in cookies to track visitor use of our website and generate reports on website activity. They cannot be used to identify you personally.

Cookies are used to improve services for visitors to our website through, for example:

• Enabling a service to recognise a device so the user does not have to give the same information several times during one task;
• Recognising the individual may already have given a username and password so does not need to do if for every web page requested;
• Measuring how many people are using services so they can be improved and there is sufficient system capacity;
• Analysing anonymised data to help us understand how people interact with government services so we can make them better.

For further information about cookies, please visit http://www.whatarecookies.com/

Google Analytics

When you visit ccwater.org.uk or http://ccwater.custhelp.com/ we utilise a third party service, Google Analytics, to:

• collect details of visitor behaviour patterns;
• collect standard internet log data; and
• monitor the number of visitors to various parts of our website.

We use Google Analytics to collect information about how people use this site. We do this to make sure our website is meeting its users’ needs and to understand how we could do it better.

Google Analytics stores information about what pages are visited visit, how long users are on the site, how they got here and what they clicked on. We do not collect or store personal information (e.g. name or address) so this information cannot be used to identify an individual. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Google Analytics cookies: _ga, _ga_<container_id>

• Purpose: To record how many people are using the CCW website and how they move around the site once they’ve arrived: o _utma tracks how many times (if any) you have visited our website before. o _utmb and _utmc are connected, and track how long you stay on the site. o _utmz tracks identifies where you’ve come from e.g. from a search engine or from another website.
• Benefit: So service is available when required we measure numbers and volumes of visitors.
• Data stored by cookies: No personal information about you, just information about your computer and your browser.

Duration of cookies:

• _ga: Expires 2 years after your last visit to this site.
• _ga_<container_id>: Expires 2 years after your last visit to the site.

ReciteMe cookies: Recite.Persist, Recite.Preferences

• Recite.Persist : Allows the toolbar to persist across subsequent web pages on client site once toolbar launched. Expires 365 days after your last visit.
• Recite.Preferences : Allows user-selected settings to auto-load on subsequent web pages on a client site once toolbar launched. Expires 365 days after your last visit.

HACIVIC4

This cookie is used by CIVIC’s load balancer to identify the server that is active for your request on our cluster. Its purpose is to improve the performance of the website. The cookie is essential to the operation of the site and is always set by the load balancer, but does not store any personal information.

CookieControl

Cookie Control cookies. This cookie is set to remember the user’s preferences about cookies.

Cookies set by our consumer support site

Customer Portal: cp_session, cp_profile, cp_login_start, oauth_token

• Purpose: store session specific user data including session ID, answers viewed, number of searches, previously viewed answers, previous searches, previously seen e-mail
• Data stored: information about the session; the cookie itself contains no personal information.
• Duration of cookie: expires when you close your browser.