1. Introduction
Welcome to the Independent Water Networks Limited privacy policy.
Please note that, in this privacy policy, reference to “we”, “us”, “our” and ‘’IWNL” means Independent Water Networks Limited, registered number 05776438, whose registered address is: Company Secretary, Synergy House, Woolpit Business Park, Woolpit, Bury St. Edmunds, Suffolk, IP30 9UP. IWNL is registered with the Information Commissioner’s Office (with registration number Z9765869).
In this privacy policy, references to the “Data Protection Legislation” means any applicable law from time to time in respect of the processing of personal data and privacy, including without limitation, the UK Data Protection Act 2018, the UK General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (in each case, as re-enacted, applied, amended, superseded, repealed or consolidated). For the purposes of the Data Protection Legislation, IWNL is a “data controller” in respect of any personal data that you provide to us or that we collect from you.
IWNL respects your right as our customer to privacy and takes its responsibilities regarding security and privacy under the Data Protection Legislation seriously. This privacy policy sets out how we use and process personal data which we may collect or receive about you, including personal data which we may collect via our website https://www.iwnl.co.uk (the/our “Website”).
We have developed this policy because we want you to feel confident about the privacy and security of your personal data, so please read it carefully before using our Website or signing up for our services.
IWNL takes all reasonable care to prevent any unauthorised access to your personal data.
By visiting the Website or otherwise engaging with us, you acknowledge that we may collect, use and/or transfer your personal data as set out in this privacy policy.
2. About IWNL
IWNL is a licenced water and waste water company based in the UK. Please contact our sales office (details of which may be found on the “Contacting Independent Water Networks Limited” section of our Website) to find out if you are able to receive our services in your area, or alternatively check on our website at https://www.iwnl.co.uk.
3. Definition of personal data
When we refer to personal data in this privacy policy, we mean information which identifies you as an individual or is capable of doing so. This may include, for example, your name, address and/or telephone number.
“Sensitive personal data” is a particular category of information and is any personal data which concerns racial or ethnic origin, political opinion, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health or conditions, sexual life.
Any sensitive personal data that you provide to us will be processed in accordance with this policy and the Data Protection Legislation. We will not collect and/or use any sensitive personal data without your explicit consent, or otherwise where we have a lawful basis to do so.
4. Information that we collect
When you visit the Website or order any of our services via our Website (including when you complete our property occupation and contact forms), you may be asked to provide information about yourself including your name, contact details (being your home address, email address and telephone number) and payment information such as credit or debit card information and billing address. We may also collect information about your usage of the Website and we may collect personal data from you from the e-mails or letters you send to us.
As described above, in some instances, we may need your credit/debit card details to charge for the services. All financial transactions are secured by SSL encryption to offer secure communications of such data to and from our Website. However, no data transmission over the Internet can be guaranteed to be totally secure, and any information which you send to us is sent at your own risk.
We may also collect personal data from you when you sign up to receive our services, and we may continue to collect and/or process personal data from you in the course of providing those services. For example, if we provide water and or sewerage supply services to you or the property which you own or occupy, we may process personal data about you such as your name, address, usage information and billing and payment information (including details relating to non-payment).
We work closely with third parties (including, for example, our business partners) who may collect personal data from you and pass it on to us. For further information regarding our use of data which is collected by third parties, please refer to the “Use of your personal data” section of this privacy policy. Where third parties collect data from you and share it with us, the third party is responsible for informing you that they have shared your personal data with us and obtaining any relevant consents from you to ensure that you are happy with the ways in which your personal data will be used. However, once we are holding your personal data, we will only handle such data in accordance with this policy and the Data Protection Legislation.
5. Use of your personal data
We may use your personal data in order to:
- provide you with access to the relevant parts of the Website, and to help us to improve our Website and services to ensure you get the best online experience;
- provide our services to you or to a related third party;
- bill you or otherwise perform our obligations or exercise our rights pursuant to any agreement we have in place with you;
- contact you where necessary about our services;
- analyse the use of our website and services in order to continually improve our business and services;
- carry out credit and identity checks on you in order to assess your creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent fraud and criminal activity (we do this by working with credit reference agencies (“CRAs“) – for further information regarding our data sharing with third parties, please refer to the “Sharing your Personal Data” section below);
- carry out statistical analysis regarding the use of our services;
- comply with our legal obligations; and
- protect the rights, property, or safety of IWNL, its customers, employees or others.
We may process your personal data on the basis that it is necessary for our legitimate business interests in fulfilling the purposes described above, or otherwise on the basis that the processing is necessary to perform or enter into a contract with you and/or to comply with legal obligations.
Where you have consented at the time we collected your personal data or where we otherwise have a right to do so, we may use your information to let you know about our products and services that may be of interest to you and/or inform you about important changes or developments to the Website or our services, by post, telephone, mobile messaging (e.g. SMS, MMS etc.) as well as by e-mail. If you have provided your consent to us using your personal data in this way, but you later change your mind, please let us know by contacting us using the details set out in the “Privacy Support” section below and/or changing your account settings on the Website. You may also opt out of receiving marketing emails from us by following the instructions outlined in any marketing email.
6. Sharing your personal data
In order to provide our services to you, we may share your personal data with our group companies, noting that IWNL is part of the BUUK Infrastructure group of companies. IWNL ensures that all of its group companies treat your data securely and in accordance with this privacy policy, and we will take appropriate steps to enforce this. If our business enters into a joint venture with, purchases or is sold to or merges with another business entity, your personal data may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
We may also share your personal data with certain third party business partners, suppliers, subcontractors and service providers, including CRAs and fraud prevention agencies. Please see below for further details of the personal data we may share with these third parties.
We will only share your personal data with third parties where: (i) we have a legitimate interest to do so; (ii) you have given express consent to us doing so; or (iii) it is required for compliance with our legal or regulatory obligations. By submitting your personal data to us and using our services, you acknowledge that your personal data may be transferred or processed in this way.
- Landlords
If you are a tenant of a property which we supply services to, we may share certain details with your landlord, such as material non-compliance with our agreement with you (e.g. failure to pay for our services).
- CRAs
In order to provide our services to you, we may share your personal data with one or more CRAs. In return, the CRAs will provide us with certain information about you which is collected from both public sources (including the electoral register) as well as secure credit, financial history and fraud prevention information. For further information regarding our use of personal data that is received from CRAs, please refer to the “Use of your personal data section” above.
In addition to providing your personal data to CRAs to process your application, we will also continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse, civil partner or financial associate, CRAs will link your records together with those of your spouse, civil partner or financial associate and these links will remain on your and their files until such time as one of you successfully files for a disassociation with the CRAs to break that link. Therefore, before making a joint application, you should make sure that you discuss this with your spouse, civil partner or financial associate, and share this information with them, before lodging the application.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal data, data retention periods and your data protection rights with the CRAs are explained in more detail at www.experian.co.uk/crain.
- Government agencies and other water companies
As referenced above, in connection with the performance of our services, we may share your personal data with government agencies, such as the Department of Work and Pensions (DWP). This is to enable us to offer you services which are tailored to your financial circumstances and determine, for example, whether you are eligible for any of our Social Tariffs or WaterSure schemes.
There may also be circumstances in which we are required contractually to share your personal data with other water companies. This includes, for example, in the event that we need to share information with other water companies for the billing and metering of your services.
- Third party advertisers
If you have consented or we otherwise have a legal basis upon which to do so, we may share your personal data with carefully selected third parties, including marketing and advertising companies and our business partners (including other members of our corporate group) who wish to contact you about services that may be of interest to you. They may contact you by telephone, post, SMS, as well as by e-mail.
If you change your mind about being contacted by these third parties at any point, please let us know by contacting us using the details set out below and/or by amending your account settings on the Website. You may also opt out of receiving any marketing communications you receive by following the instructions outlined in any of these communications.
In addition, from time to time, we may provide our advertisers with aggregated information about our customers – this could include, for example, information regarding the locations from which our services are being used. Whilst this information will generally relate to a number of our customers (and will not, for example, specifically identify you by name), it may nevertheless still be possible to identify you from this information, meaning it may still constitute your personal data. If you do not want your information to be used in this way, please contact us using the details set out below.
7. Call recording
Please note that, subject to receiving your prior consent or us letting you know that we will do so, we may record inbound and outbound telephone calls made to and by our customer support centre for training and quality purposes. In addition, (and where we have received your consent to do so) in some instances we may be required to send call recordings to third parties for whom we sell products or services over the phone. This is so that they can monitor the quality of our calls when selling their products or services.
8. Storage and transfer of personal data outside the UK
The personal data you provide to us will be transferred to and stored on our servers in the UK.
The personal data that we collect from you may also be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data or using our services you are acknowledging this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and Data Protection Legislation. This means that we will only transfer your information to third parties that (a) are in countries that have been confirmed by the UK Information Commissioner’s Office to provide adequate protection to personal data; or (b) with whom we have put in place appropriate measures to protect your personal data, as required under the Data Protection Legislation.
9. Retention and security of personal data
We will only keep your personal data for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.
We take steps to protect your personal data from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Where you have chosen a password which allows you to access certain parts of the Website, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Website; any transmission is at your own risk.
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal data via these websites.
10. Your rights in relation to your personal data
You have the following rights in relation to the personal data that we hold about you:
(a) the right to be informed about how we are using your personal data;
(b) the right to access the personal data that we hold about you;
(c) the right to request the correction of inaccurate personal data that we hold about you;
(d) the right to ask us to erase or stop processing any personal data we hold about you where there is otherwise no longer a legal ground for us to hold it;
(e) the right to ask us to restrict the processing of your personal data in certain circumstances;
(f) the right to request that we transfer certain personal data;
(g) the right to withdraw consent to any consent-based processing at any time; and
(h) rights in relation to automated decision-making and profiling.
If you wish to exercise any of these rights, please contact us using the contact details set out in the “Privacy Support” section below.
11. Changes to our privacy policy
IWNL may amend this privacy policy at any time without notice. By continuing to use the Website and/or making use of our services, you acknowledge that we will process your personal data in accordance with the updated privacy policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to our privacy policy will be posted on the Website and, where appropriate, notified to you by e-mail.
12. Privacy support
All comments, queries and requests relating to our use of your information are welcomed (including in relation to transfer of data outside the UK) and should be addressed to Independent Water Networks Limited, Driscoll 2, Ellen Street, Cardiff CF10 4BP. Alternatively, you can call us on 02920 028711 or contact us via email at dataprotection@bu-uk.co.uk.
Should you wish to take any complaints or queries further, you also have the right to contact the Information Commissioner’s Office regarding such issues.
13. Use of cookies
We collect some information about you through the use of cookies. For more information, please see our Cookie Policy, which is available here.
