Legal
Privacy Policy
At Switch2 Energy Limited, we understand that our customers expect their personal data to be handled in a careful, considerate, and legally compliant manner.
The purpose of this Privacy Notice is to provide comprehensive information to Switch2 end customers of when, how and why we process your personal data. This applies where Switch2 are data controller and are the energy scheme operator for a heat network. Our service provision on this type of site will include any number of the following:
- Operation and maintenance of domestic heat network equipment
- Operation and maintenance of the onsite energy centre and plant room(s)
- Metering and billing service
Switch2 also process personal data on behalf of other organisations such as when we are contracted to provide metering and billing or operation and/or maintenance services to the energy scheme operator. In these instances we are acting as the data processor on their behalf and therefore this Privacy Notice may not be applicable where the data controllers own Privacy Notice will supersede this. For more information about your data protection rights in this scenario, please speak directly to the scheme operator who are the data controller.
1. How we get your information
We typically collect your personal data when you provide this to us as part of our process for registering you as a heat network customer at the site. This includes registration by email, telephone and/or submitting your personal information on our online residents portal (www.resident.switch2.co.uk) in order to register as a customer with Switch2 and receive relevant heat network services.
We may also receive and/or request your personal data from third parties such as housing associations, managing agents, landlords and property developers when you rent or purchase a property from them.
2. Type of data we process
The type or category of personal data belonging to our customers that we process may include any of the following:
- Full name
- Gender
- Billing address
- Supply address
- Contact details including phone number and email address
- Bank details (account number and sort code to set up direct debit instructions)
- Date of birth
- Previous addresses lived at
We may also process ‘special category data’ as part of our service provision, specifically for our Priority Services Register. This includes information relating to your personal health. We only process this data with your explicit consent to do so and where you have made clear that you wish to be added to the Priority Services Register having met one or more of the qualifying criteria.
3. Data processing purpose and legal justification
Switch2 provide a range of services to you as the end customer which require us to process your personal data in order to fulfil this service obligation. For each service provision we rely on a specific legal basis to lawfully process your personal data. This does not include services where your data is shared with a third-party organisation. Details of our lawful basis for this type of activity can be found in Section 4 of this Privacy Notice.
The details of our different type of service provision and the relevant legal basis are as follows:
| Service Provision | Lawful Basis |
|---|---|
| Issuing bills to you as the customer for your energy usage | Contractual – this is necessary to fulfil our contractual obligation as the energy supplier |
| Maintenance, repair, and upgrade of the heat network equipment in your property | Contractual – this is necessary to fulfil our contractual obligation as the energy supplier |
| Handling queries, issues or complaints from you relating to the energy service | Legitimate interest – we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service |
| Taking payment for heat network services | Contractual – this is necessary to fulfil our contractual obligation as the energy supplier |
| Contacting you for customer feedback relating to our service provision | Legitimate interest - we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service |
| Administration of your customer account on our different digital systems | Legitimate interest - we rely on this lawful basis as we believe you would reasonably expect us to process your data to provide this service |
4. Sharing your data
Your personal data will be shared with authorised people working for Switch2 where this is necessary to fulfil one of the stated processing purposes in the previous section. We take suitable measures in line with our Access Control Policy to ensure that your data is only shared with employees that have a genuine business reason for having access to your personal data to allow them to provide a service to you.
We may also share your personal data with third party organisations as part of our service provision to you.
Third parties that we may share your personal data with are:
| Third Party | Purpose | Lawful basis |
|---|---|---|
| Landlord | To provide information about the account balance and any payment arrears on the account where the Landlord is liable for the account balance | Legitimate interest |
| Managing Agent | To provide information about the account balance and any payment arreas on the account where the Landlord is liable for the account balance and have authorised a Managing Agent to act on their behalf. | Legitimate interest |
| IT services and digital software providers | To facilitate the provision of our various company services to end user customers | Legitimate interest |
| Digital communication systems (e.g. email, WhatsApp Business) | To facilitate communication between Switch2 and our end user customers and enhance our service provision | Legitimate interest |
| Business support | To provide business support services such as out of hours call handling | Legitimate interest |
| Mailing company | To provide cutomer billing servcies and other physical communication by mail | Legitimate interest |
| Sub-Contractors | To provide maintenance and repair services to the heat network | Legitimate interest |
| Providers of customer satisfaction surveys | To deliver specialised customer feedback services to allow Switch2 to improve their service provision | Legitimate interest |
| Credit reference agencies | To help prevent fraud or as part of debt collection services | Legitimate interest |
| Enforcement authorities | To provide data to police, fire services, medical or other enforcing authorities where this is required under specific circumstances | Legal obligation |
Where we actively engage a third party that will have access to your personal data, this processing will be done under strict contractual terms. All third parties instructed by us and acting on our behalf are required to adopt suitable and satisfactory security measures to protect your data and these must be in line with our own internal policies and procedures and/or recognised and accredited standards of practice. Third parties are only permitted to process your data for specified purposes and in accordance with our instructions and must sign a Data Processing Agreement reflecting these terms of processing.
5. How is your data kept secure
When we use information about you, we take all reasonable efforts to do so fairly and lawfully. We have robust and independently verified security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your personal data. We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that there is no unauthorised access to your personal data.
6. Your rights
The UK GDPR, along with the Data (Use and Access) Act gives you certain rights towards your personal information. We take all reasonable efforts to ensure we allow you to exercise those rights.
Your rights are:
- The right to be given specific information about your personal data we collect.
- The right of access to your personal data.
- The right to rectify any of your personal data which is inaccurate.
- The right to erase your personal data in certain circumstances.
- The right to restrict processing of your personal data.
- The right to data portability.
- The right to object to certain processing.
- Rights in relation to automated decision making and profiling.
If you want more information about your data protection rights you can email our Data Protection Officer (DPO) on dataprotection@switch2.co.uk.
We may reply to you where we need further information to help respond effectively to your request. Switch2 is not a ‘public authority’ as defined under the Freedom of Information Act, and we will not therefore respond to requests for information made under this Act.
If you are not satisfied with the response you receive, you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:
Information Commissioner’s OfficeAddress: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.Telephone: 0303 123 11137. Complaints about data handling
If you have a complaint about the handling of your personal data by Switch2 you can contact us by the following means:
Website Contact FormOn our Privacy and Cookies section of our website Privacy and cookies - Switch2 there is a section titled ‘How to make a complaint on data handling’. In here you will find all information you need on our complaints handling process including a web form to submit a complaint.
EmailEmail our data protection team directly on dataprotection@switch2.co.uk
Once we receive your complaint, it will be assigned to the relevant person in the organisation to review and respond within 30 days of the complaint being made.
8. Automated decision making
As part of our commitment to supporting customers and ensuring fair access to our services, we use energy usage and payment data to help identify customers who may be at risk of financial difficulty. This allows us to offer appropriate support, such as tailored payment plans or early intervention to prevent debt escalation.
This process involves automated analysis of personal data to assess patterns in energy consumption and payment history. Under the UK General Data Protection Regulation (UK GDPR), this may be considered profiling, as it involves evaluating aspects of your economic situation.
We want to reassure you that:
- This profiling does not involve automated decision-making that has legal or similarly significant effects.
- The insights gained are used solely to inform our customer support efforts and are not used for marketing or commercial targeting.
We rely on our legitimate interest to carry out this processing, as it helps us to proactively support customers and maintain responsible billing practices.
9. How long do we keep your data
When we collect your personal information, the length of time that we retain it is determined by a number of factors, including the purpose for which we use that information. Typically however we will retain personal data for the full length of time that we are providing a service to you and then for a period of 5 years subsequent. This allows for the resolution of any disputes regarding the account after the termination of your customer status.
At the end of this retention period, your personal data will be destroyed and removed from all systems.
10. Further Information
For more information about this Privacy Notice please email our DPO at dataprotection@switch2.co.uk