The Consumer Council for Water (CCWater) is committed to protecting the security and privacy of your personal data. CCWater is a data controller under the terms of the General Data Protection Regulation (GDPR) which came into effect on 25 May 2018. We are registered with the Information Commissioner’s Office (ICO) with the registration number Z9387556.
This privacy notice explains what personal information we collect, how we use it and your rights in respect of your personal data.
Who is the Consumer Council for Water?
We are the independent watchdog that represents the interests of water consumers in England and Wales. We have regional committees in England, a committee in Wales and a team of Local Consumer Advocates (LCAs) that represent your area. Our contact details are:
Consumer Council for Water
1st Floor Victoria Square House
0300 034 2222 (for Birmingham)
0300 034 3333 (for Cardiff)
What information do we process?
We process personal information in a number of ways to enable us to carry out our following duties:
- consideration and investigation 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, LCAs and employees;
- sending communications to stakeholders about the work we do;
- commissioning of research;
- internal support functions (suppliers etc.).
What types of data do we collect?
We process information relevant to the above reasons/purposes which include:
- 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 LCAs including pay details data relating to current and former employees;
- Information from our suppliers.
The legal basis for processing your information
CCWater processes personal information under the following legal bases:
Article 6(1)(a), Consent –CCWater will only process personal data with the consent of the data subject.
Article 6 (1)(b), Contract – CCWater process of personal data is necessary for the performance of a contract to which the data subject is party.
Article 6 (1)(c), – Legal obligation – CCWater processes personal data for compliance with a legal obligation to which we are subject (the Water Industry Act 1991).
Article 6 (1)(f), Legitimate interest – CCWater processing personal data is necessary for the purpose of our legitimate interest except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
Customer complaints against their water company
We share customer information with their water company in order to assist them in reaching resolution. We process this information as a legal obligation. We store personal information securely on our complaint management system which is accessible only to the relevant employees within our organisation. Telephone calls are recorded for training purposes and are stored for one week. We hold your information on our complaint management system for six years after we close the complaint. Information on our IT security is included later in this document. For more information, on how long we keep personal data please access our retention schedule:
Some complaints may fall 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 these circumstances we will not share your personal information without your consent.
Similarly, in the event that customers who we have assisted with their complaint remain dissatisfied with the outcome or the way we have dealt with it and approach WATRS or the Parliamentary and Health Service Ombudsman, we will not share any personal information without the consent of the data subject.
As a consumer body, it is important we ensure we deliver a good service to customers. In order to ensure we deliver an effective service, we use a market research company to survey customers we have assisted with their complaint to gauge feedback. We may share customer contact details with a market research company after we close a customer complaint. Our lawful basis for processing information is it is necessary for our legitimate interest.
We do not advise customers to send sensitive information to us in relation to their complaint unless absolutely necessary. Sensitive information includes racial or ethnic origin, political beliefs, religious beliefs, trade union membership, physical or mental health conditions, sexual life or commission / alleged commission of any offence or proceedings for any offence committed or alleged to have been committed. Our lawful basis for our processing sensitive information is set out in Article 9(2)(e) of the GDPR 2018 – information made manifestly public by the data subject.
We keep a record of individuals who request advice or information from us about water or wastewater issues. The lawful basis for processing is under Article 6(1)(c) of the GDPR: process is necessary for CCWater to be compliant with a legal obligation to which we are subject (Section 27C of the Water Industry Act 1991- the interests of consumers). The information is stored securely on our system and is held for one year after closure.
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 rate, click-through rate and the subscriber list growth for our newsletter. For our communications through our stakeholder database, CCWater’s lawful basis for processing information is our legitimate interest.
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.
For more information, please see MailChimp’s privacy notice. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any of our emails.
All information provided to us during the recruitment process will only be used to progress applications, or fulfil legal / regulatory requirements. The information is held securely by us whether it is held electronically or physically. We use your contact details for the recruitment process and other information to assess suitability.
Our lawful reason for processing is it is necessary for our legitimate interest. The information is stored for 2 years after the recruitment campaign.
For existing employees, Board members and LCAs we process the following information:
- Contact details;
- Pay details;
- Pension details;
- Annual leave;
- Sick leave;
- Disability details;
- Employment history.
We process this information under the lawful basis 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.
Personal data of suppliers whether they are an individual or an individual on behalf of an organisation is lawfully processed by CCWater under the performance of a contract. The information includes name, contact details and payment details. We hold this information for six years plus the current year.
Water meter calculator
We ask customers to include their post code 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 set out in Article 6 (1) (f) – the process is necessary for our legitimate interests. We delete the data after one year.
Water meter calculator and website feedback
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) (f) of the GDPR legislation 2018. The process is necessary for our legitimate interests.
We use Survey monkey to process this information and its privacy statement can be found here.
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 on 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 made easier to use and there is enough capacity to ensure they are fast;
- Analysing anonymised data to help us understand how people interact with government services so we can make them better.
When you visit our website 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 it 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 is 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: _utma, _utmb, _utmc, _utmz
- Purpose: To record how many people are using the CCWater 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:
- utma: Expires 2 years after your last visit to this site.
- _utmb: Expires 30 minutes after your visit, or after 30 minutes of inactivity.
- _utmc: Expires when you close your browser.
- _utmz: Expires 6 months after it was last set.
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.
We offer guest Wi-Fi to internal and external stakeholders visiting our Victoria Square House and Cardiff offices. When CCWATER GUEST Wi-Fi, is used, we may collect data about:
- the device used
- the volume of data which used;
- the applications and websites accessed; and
- your usage by frequency and location and access time.
How your information is stored
Customer information is stored electronically onto our complaint management system. This system, and our network, comply with ISO 27001 I/L2 data security hosting standards, the EU Safe Harbour Data Protection Directive and Telecoms Data Protection Directive. Employees are advised of our IT security policies and procedure and sign a declaration annually. An ICT security report is also submitted annually to our Audit and Risk Management committee.
How information is deleted
Any correspondence we receive about a consumer complaint against a water company is scanned or inputted onto our complaint management system and information we receive by post is filed securely and shredded after four weeks of receipt, as outlined in our data retention policy.
All other information we receive on paper/hard copy (e.g. paper questionnaires, written notes from focus groups, etc.) is destroyed at our premises by a professional shredding and recycling company which is ISO 27001 accredited and which is controlled by contract and supervised by a CCWater employee whilst performing their task. They provide us with evidence of secure disposal as part of their service.
Hardware and devices which have had personal data stored on them are also destroyed using an appropriate and secure method.
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 CCWater 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 CCWater’s compliance footprint;
- Updating CCWater’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 CCWater’s data protection, privacy and cookie policies.
The right to be informed
You have the right to be informed about the collection and use of your personal data, including:
- the type of data being processed;
- recipients of your data;
- the purposes of the processing;
- the legitimate interests for the processing (if applicable);
- the likely period that your data will be retained or the decision process for eventually deleting it; and the existence and details of any automated decision making;
- the rights available to you in respect of the processing.
The right of access (commonly referred to as Subject Access Requests (SARs))
You have the right to request a copy of the information that we hold relating to you. In order to search for the correct information, we may need to confirm your identify via the use of security questions or ask for certain information to conduct accurate searches. Should you request a copy of some, or all of your personal information, please email email@example.com or write to the following address:
FAO: Information Team
Consumer Council for Water
1st Floor, Victoria Square House
Depending on the circumstances we can accept verbal requests for information. If you have a condition which impacts on your ability to request information in writing, we can make a reasonable adjustment for you under the Equality Act 2010 and we would treat your verbal request as though it were a valid SAR.
An administration fee will not be imposed for considering and/or complying with such a request unless the request is deemed to be complex or excessive in nature. We have a statutory duty to respond to a SAR within one calendar month of receipt, although we can extend the period of compliance by a further two months if a request is deemed to be complex or numerous. If this is the case, we must inform you within one month of the receipt of the request and explain why the extension is needed.
The right to rectification
You have the right to rectify any inaccurate data held by CCWater. You can make a request for rectification verbally or in writing. The request can be made to any part of our organisation, and is not confined to one particular point of contact or individual.
However, it should be noted that data which has been stored for statistical purposes represent a fixed period in time and therefore we are not obliged to amend any data which was correct at the time of collection.
Depending on the circumstances, you may have the following additional rights:
The right to withdraw consent
Where you have consented to us processing your personal data, you are within your rights to withdraw your consent at a later time. For any such request, we will review your withdrawal of consent within a month. We will usually agree to such a request. However where the data is used for reporting purposes, we normally have the right to continue processing your data and only redact or obfuscate the information that would make you identifiable. We will notify you in the event that this situation arises. No fee will be incurred for withdrawal of consent.
If you do not want to be contacted again, we keep ‘no further contact’ lists. Please contact us if you would like to be included on these lists.
The right to erasure (the right to be forgotten)
You may have a right to have all, or some of the information we hold about you erased. You can make a request to have your data erased verbally or in writing. We must act upon a request within 1 month of receipt and we will notify you if your data has been erased. In circumstances where we are unable to erase your data, we will notify you to explain the reasons for refusal.
The right to object
You are within your rights to object to the processing of your personal data depending on our reason for processing. In some circumstances we may have a compelling reason to continue processing your data. We will advise you accordingly. You can make an objection verbally or in writing and we will respond to you within one month.
The right to restrict processing
You sometimes have the right to restrict the processing of your personal data or object to its processing. Should you wish to withdraw the consent for processing of your personal data please contact us. The right to restrict processing applies where:
- the accuracy of personal data is in question;
- processing is deemed to be unlawful but you do not want your data erased;
- we no longer need the data but you need it kept for legal claims; or
- where you have challenged the balance of our own and/or our clients’ legitimate interests in processing as opposed to your own interests.
We will consider each request on a case by case basis.
The right to data portability
You have the right to receive personal data that we hold in a structured machine readable format and to reuse this for your own purposes to another data controller without hindrance from CCWater. For any requests made, we would be responsible for the transmission of the data and would need to take suitable measures to ensure that it is sent securely to you.
Automated decision making
CCWater does not use personal information for any automated decision making activities.
Submitting a complaint with respect to our data handling
We will work with you on any request, complaint or enquiry you have about your personal information. However, should you be dissatisfied with the way a request has been handled, you can initially ask for a review by a senior employee. Should you still be dissatisfied after the internal review has been conducted, you can submit a formal complaint to the Information Commissioner. Contact details for the Information Commissioner are:
Information Commissioner’s Office
Tel: 0303 123 1113
Fax: 01625 524 510
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.
Colin Lench is our Data Protection Officer. Should you have any concerns about your personal data held by CCWater please contact us at DPO@ccwater.org.uk.