Privacy policy

1 About us

Electricity North West Limited is committed to protecting the privacy and security of your personal information and to being transparent about how we collect and use that data to meet our data protection obligations in compliance with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act (DPA) 2018.

This privacy notice describes how we collect and use personal information about you, in accordance with the UK GDPR and the DPA. This privacy notice covers the following processing activities of Electricity North West:

Customer operations and complaints
Connections
Land Rights and Consents
Innovations
Stakeholder engagement
Priority services (including our Extra Care Register)
Smart Meters

Electricity North West Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your information.

2 Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

used lawfully, fairly and in a transparent way
collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
relevant to the purposes we have told you about and limited only to those purposes
accurate and kept up to date
kept only as long as necessary for the purposes we have told you about
kept securely

3 Information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection. Further information on how and why we collect, process and share special category and criminal offence data can be found in our Appropriate Policy Document (available on request from the Data Protection Officer).

We collect basic personal data from you when you contact us. Specifically, your name, address, telephone number and email address. We may also collect your bank details in certain limited circumstances. If you contact us, or we contact you, by telephone, we may also record the call for training and service improvement purposes and make notes in relation to your call.

We will also receive personal data about you from your electricity supplier. Bill payer details and metering point information is received by ENWL, in line with industry agreements and codes, such as the Retail Energy Code.

Electricity North West Limited may also receive your personal data from other third parties in relation to your electricity supply, such as your water and gas suppliers, our sub-contractors, National Grid, Members of Parliament, local authorities, housing authorities, charities and the Office of Gas and Electricity Markets (“Ofgem”).

For more information on personal data collected for our Extra Care Register specifically, please refer to this section below.

4 Why do we need your personal information?

We need to know your basic personal data (including your address, name and contact details) to be able to maintain and operate the electricity distribution network for which we are responsible, to support and provide assistance where needed, to communicate effectively with you about your electricity supply and to make payments to you in the event that you are entitled to compensation.

5 Legal basis for processing

In order to process and use your personal information lawfully, we rely on the following legal bases:

to comply with our legal obligations under the Electricity Act 1989, and associated licence conditions and industry codes
the processing is necessary for us to perform a task in the public interest, such as sharing information with our welfare partners to protect our most vulnerable customers
for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract
for our legitimate interests in ensuring effective operational management and internal administration, document retention/storage, compliance with regulatory guidance, exercise or defence of legal claims, product/service improvement and communicating with you
with your consent, to maintain and develop our relationship with you, including marketing our products and services and market research. You may withdraw your consent at any time.

For more information on the legal grounds required for processing your data on our Extra Care Register specifically, please refer to this section below.

6 Situations in which we will use your personal information

The personal data we process is processed by our staff to:

enable our customer contact centre to help you with any enquiries or complaints
communicate with you by telephone, mail, text, email or social media about issues that may affect your electricity supply
enable us to provide you with assistance in order to ensure the distribution of electricity to you and to contact you in the event of a loss of supply, an emergency or other incident, such as severe weather or an event which may jeopardise your electricity supply
monitor our work and maintain our records
obtain feedback on how we can improve our services
allow us to process charges in the event of damage to our equipment
provide compensation to customers in certain circumstances
comply with legal or regulatory requirements.

For additional information on what we do with your personal data for our Extra Care Register, Connections, Innovations, Stakeholder Engagement, Smart Meters or Land Rights and Consents specifically, please refer to the relevant sections below.

For the purposes of Network Management, IT support, email support and maintenance, we, or a third party who we share personal information with, may store and handle that personal information outside of the United Kingdom.

We will only permit this to happen if adequate safeguards have been put in place to protect your personal information. This means that we will:

ensure that the country in which your personal information will be handled has been deemed "adequate" by the European Commission or Information Commissioner’s Office; or
include standard data protection clauses approved by the European Commission or Information Commissioner’s Office supported by the International Data Transfer Agreement (IDTA) for transferring personal information outside the UK into our contracts with those third parties.

We may share your information with:

your electricity and water suppliers
your gas distribution network operator
other parties to energy industry agreements and codes, including the Retail Energy Code
Ofgem, the Energy Ombudsman and any other regulatory authority we may be subject to for the purposes of demonstrating compliance with applicable law and regulations
any member of the Electricity North West group of companies, sharing the same ultimate holding company or ultimate parent undertaking as Electricity North West Limited, as defined in sections 1159 and 1162 of the UK Companies Act 2006
our sub-contractors for the purposes of carrying out work on our electricity distribution networks
third parties contracted to provide services to us (including carrying out surveys on our behalf, assessing appliance damage, logging faults or checking the accuracy of our data)
local public agencies such as the NHS, emergency services and local authorities (as required by the Civil Contingencies Act 2004)
our partners, at your request, to support you with being more energy efficient
our welfare partners to support our more vulnerable customers.

We may also use aggregate information and statistics in order to help us develop our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

Electronic Communications

For time to time, we may send routine customer service messages by electronic means, such as telephone, text or email, as required by our regulator, to let you know about issues that may affect you, to check your details are up to date or to check whether anyone at your property requires additional support in the event of a loss of supply.

If you have provided consent, or we otherwise have the legal right to do so, we may send to you direct marketing and promotional materials relating to our services, engagement activities or related products, for example sending you communications (including by email) for these purposes. You can opt out of these messages at any time by clicking the “Unsubscribe” link in any of our emails or by emailing electricitycustomerrelation@enwl.co.uk.

7 Data security

We take the security of your data seriously. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8 How long will we keep your information for?

We will keep your information only for as long as necessary depending on the purpose for which it was provided. When determining the relevant retention periods, we will take into account factors including:

our contractual obligations and rights in relation to the information involved
legal obligation(s) under applicable law to retain data for a certain period of time
regulatory requirements
(potential) disputes
guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting us using the details below in the Contacting Us section.

9 Your rights

You have the following rights regarding your information:

Right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this privacy notice.

Right of access

You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this privacy notice). This is so you are aware of the information we hold about you and can check that we are using your personal data in accordance with data protection law.

Right to rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

Right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not a general right to erasure; there are exceptions.

Right to restrict processing

You have rights to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.

Right to data portability

You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

Right to object to processing

You have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests or on public interest grounds; the right to object to processing for direct marketing purposes (including profiling); the right to object to the use of your personal data for scientific or historical research purposes or statistical purposes in certain circumstances.

Right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to the use of your personal data for direct marketing purposes.

For more information on your rights or if you would like to exercise any of your rights, you are welcome to contact us at the contact details set out below.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10 Contacting us

If you would like to contact us in relation to your rights, or if you are unhappy with how we have handled your information, you may contact us as follows:

Address: Customer Relations Team, Electricity North West, 304 Bridgewater Place, Birchwood Park, Warrington, Cheshire, WA3 6XG

Email: electricitycustomerrelation@enwl.co.uk

If you would like to contact our Data Protection Officer, you may do so by contacting them at:

Address: Data Protection Officer, Electricity North West, Borron Street, Stockport, Cheshire, SK1 2JD

Email: dataprotection@enwl.co.uk

If you are not satisfied with our response to any concerns about your data or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or write to them at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

11 Supplemental information

11.1 Extra Care Register

Please read this section if you have registered with our Extra Care Register.

Special categories of personal data

In addition to collecting your basic personal data (name, address, telephone number and email address), if you have registered for our Extra Care Register, we process special category or “sensitive” data about you (e.g. personal data concerning health):

for reasons of substantial public interest to ensure we meet and protect the needs of the most vulnerable in our society who may be at risk of harm
to protect your vital interests or the vital interests of another person, if you or they are incapable of providing consent
as required under the Civil Contingencies Act 2004, or
for the establishment, exercise or defence of legal claims.

Further detail on how we process and manage sensitive personal data can be found in our Appropriate Policy Document, available on request. You may withdraw from the Extra Care Register at any time by contacting us on 0800 195 4141 or emailing us at customerwelfareteam@enwl.co.uk.

What do we do with your personal information?

We use your information to:

add you to our Extra Care Register
ensure that you are provided with the ongoing support you need in an emergency, bad weather and for planned supply interruptions (including providing you with updates and alerts) both onsite and through our customer contact centre
share that data with your water and electricity suppliers
liaise with your nominated contact (where provided)
periodically check with you that the information we hold is correct and up to date.

If the only contact detail we hold for you is your home address, we may periodically share these details to a third party to write to you and confirm that the details we hold for you are up to date.

We may also receive personal information about you from your electricity suppliers, gas suppliers, water company, welfare organisations and NHS organisations to include you on our Extra Care Register so that you will benefit from this service.

We may share your information with welfare organisations, local authorities, and emergency services for those organisations to provide support and assistance to you in special circumstances or emergencies; and our sub-contractors to provide onsite support during planned supply interruptions, bad weather or emergencies.

11.2 Connections

Please read this section if you have requested a new connection, service alteration, disconnection, diversion, additional load or have applied to install a low carbon technology such as EV chargers or solar panels.

What do we do with your personal information?

We use your information to:

process your application and provide you with designs and quotations for a new connection to our electricity network
enable you to make payment for your connection service online, via the payment gateway Lloyds Bank Cardnet
provide feasibility and budget estimates
move or divert your existing supply of electricity to a new location as requested by you
manage applications for disconnection from our electricity network
manage generation applications, which is reportable to our regulator Ofgem
provide our operational teams and sub-contractors with the necessary information to carry out the connection works onsite
share your contact details where you are the primary generator with a flexible connection to assist other applicants who are interested in shared capacity connections
contact you to invite you to take part in connections engagement activities, provide comment/feedback on changes in policy and improvements to systems
comply with legislation associated with the provision of electrical connections; carry out inspections to comply with our legal and regulatory obligations; and investigate reports of potential cases of electricity theft.

We may share your information with our data processors Lloyds Bank Cardnet, Mailchimp and subsidiary Mandrill, Mando Group Ltd and Episerver AB for processing your estimates, quotations and payments and for keeping in touch with you. We may also share your information with Explain Market Research Ltd for the purpose of service evaluation.

11.3 Innovations

This section applies to you if you have registered an interest in being kept up to date with new projects.

What do we do with your personal information?

If you register an interest in being kept up to date with any new innovations projects undertaken by us, a particular project or sign-up to be part of a particular project, we use your information to:

send you newsletter communications with updates about our ongoing or new innovations projects; this may also include information on wider industry events such as those organised by other DNOs or the Energy Networks Association
design projects to trial innovative technologies to help manage our network
effectively deliver innovations projects
verify any analysis carried out on those projects (which could include monitoring devices installed in customer homes and businesses)
conduct surveys during or after participation in such projects.

We may receive your information from third parties working in association or partnership with a particular project e.g. local housing associations.

In many cases, we deliver innovation projects with external partners such as local housing associations, and we may need to share your information with them to ensure that we can deliver the project successfully.

We may share your information with our third-party service providers, such as Impact Research Limited, who carry out engagement activities, surveys and/or research on our behalf.

11.4 Land Rights and Consents

Read this section if you are a landowner who has equipment belonging to Electricity North West situated on your land.

What do we do with your personal information?

We use your information to:

agree rights in land
manage existing land rights
carry out administrative duties relating to rights agreed inclusive of payments
carry out other land liaison duties such as notification of project work, operations and maintenance
process wayleaves payments and operational property rental
facilitate access to install, repair, monitor, maintain and remove apparatus lawfully situated on your land.

We may also share your information with our legal and professional representatives and any legal professional representatives you have appointed to liaise with us on your behalf and with contractors undertaking development projects and maintenance.

11.5 Stakeholder engagement

What do we do with your personal information?

We use your information to:

fulfil and evidence regulatory stakeholder engagement targets and obligations
record your consent and marketing preferences
invite you to future stakeholder activities and events that may be of interest to you
record your attendance at events and any feedback you have provided
provide you with updates and relevant information on our activities, including progress of initiatives, forthcoming developments and opportunities to engage and consult
capture and use photographs, recording or filmed footage for public display, such as online, commercial publications and non-commercial publications.

If we take your photograph at an event, we will seek your agreement to do so and provide you with separate terms and conditions explaining how your image will be used under contract.

We may share your information with our third-party service providers who carry out engagement activities, surveys and/or research on our behalf. These service providers include Impact Research Limited, Explain Market Research Ltd, DJS Research Limited and Feedback Market Research.

11.6 Smart Meters

Read this section if you have a Smart Meter.

What do we do with your personal information?

We collect data relating to the electricity consumption of the property which we have chosen to treat as personal data. We do not associate this data with any personal information about your household or occupants.

We use your information to:

decide if our distribution network is overloaded or has spare capacity
help us restore supplies or reconfigure the distribution network if there is a fault, and
optimise the configuration of the distribution network.

We may also share this information with other parties who have a legitimate reason to require it relating to design and management of the electricity distribution network.

Updated June 2023