SP Energy Networks Privacy Policy This privacy policy ("Policy") describes how SP Energy Networks ("SPEN") (which includes SP Distribution plc (company number SC189125), SP Manweb plc (company number 02366937), and SP Transmission plc (company number SC189126) collects, stores and uses information that identifies individuals ("Personal Information") in connection with its business activities. In this Policy, references to "we", "us", and "our" (and other similar terms) means SPEN and "you" and "your" (and other similar terms) mean our customers, contacts, suppliers and website visitors. Personal Information that SPEN may collect from you and uses made of it. We may collect Personal Information about you whenever we are in contact with you and if we are in a contract with one another. In particular, we may collect and process the following information about you: Information that you provide by filling in forms on our website. If you contact us by phone, email or post, we may keep a record of that correspondence; technical information collected by automated means such as smart meters We may also ask you to complete surveys that we carry out for regulatory reasons, for example when required by OFGEM, although you do not have to respond to them; When we enter into a contract or agreement with you. This includes the information you provide about you or your property. Please note that we will assume, unless you tell us otherwise, that we may use and disclose your Personal Information in such a manner as we believe is reasonably necessary to provide our services to you (including as described in this Policy and as otherwise agreed between us). More specifically we will collect, store and use your Personal Information for the following purposes: If you contact us in an emergency We will collect your name, email address, phone number, and the best time to reach you, the urgency of your enquiry, and your preferred way of being contacted and the nature of your query so we can respond to your query in the most efficient way If you contact us because your power is out: We will collect your personal contact details for the purpose of contacting and corresponding with you. We will also collect your address (including postcode) so that we can investigate and resolve the problem. If you are going to experience a planned power cut We will attempt to contact you at your home in advance of the work commencing to check the information we hold for you is accurate, we will with your consent update our records where new information such as name, address and contact details have changed. We will confirm if anyone in the property requires to be registered on our Priority Services Register for additional support. We will use this information to write out to you in advance of the work to confirm the date and time and text you where you have provided a mobile number to remind you of the work just before it starts. If you contact us because you require a new or upgraded connection to our network If you contact us to make a new connection or change an existing connection we will collect your name, address, phone number, details about your property, access arrangements and other site specific details for the purposes of carrying out the works. If you contact us with a general enquiry: We will collect your personal contact details for the purpose of contacting and corresponding with you. We will also collect your address (including postcode) so that we can deliver the service you require. Information will be shared with Service Partners working on our behalf delivering the above services. If you are a landowner: We will collect details of your property, your name, information regarding any wayleaves, servitudes, easements or consents over your property, how long you have owned it and details of any co-owners or others with rights over your property, for the purposes of obtaining access to or placing equipment on your property. If you are on our priority services register: We will collect your name, address, contact details, the nature of the support you require should you have a power cut. We will use this information to proactively contact you in the event of a power cut. We will also share this information with you electricity supplier & their agents (whoever you chose to pay your bill to) with your consent in order that they may provide the required support. If you contact us to request one of our Extra Help Support Services: We will collect you name, address, contact details and the support service you require. We will, with your consent pass your details to our partner delivering the services on our behalf in order that they can contact you and provide the service requested. We will get feedback from our partner when the service is completed and contact you to make sure you are satisfied If you are a supplier (or prospective supplier) to SPEN: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. We may also collect your Personal Information through materials you may provide to us in relation to the services you supply to us, as well as your bank account and/or other payment details for the purpose of paying your fees. Other uses of Personal Information On occasion we may collect additional Personal Information for a specific purpose. In such circumstances we will try to provide specific additional notice about that processing and purpose at the time those data are collected and any disclosures made and information given at the point of such collection will also form a part of this Policy. Who we share your Personal Information with We use consultants, suppliers and contractors to help us provide services and we give them Personal Information but only to the extent they need it to carry out their specific tasks. We have contracts in place with them containing obligations regarding the use, security and of Personal Information to ensure that it is protected as much as possible. Providing information to SPEN about third parties You should not give us Personal Information about someone else (such as alternative named contacts, co-owners or next of kin) without first getting their consent for it to be disclosed and used by us. If you provide such third party information we will assume they have consented, although we may still ask for confirmation. Where SPEN stores your personal data and security measures We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers. We will not pass any Personal Information collected to third parties for marketing purposes unless we tell you specifically. Your Personal Information may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may be accessed by SP group companies and may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. If you provide Personal Information to us via our websites, we will do our best to protect it, but we cannot guarantee its security and any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access. Chatbot Why do we collect and keep your personal information? The information collected from you by the chatbot will include: A timestamp of your interactions and also your conversation history e.g. any questions you have asked, information you have provided, responses to questions from the chatbot The legal basis for processing your data is legitimate interest. How is your information used? This information will be used by SP Energy Networks to provide the most relevant experience for you. This information will be stored within the chatbot application. SP Energy Networks will not share your information with any third party who is not directly connected with the chatbot. How long do we keep hold of your information? Once you have ended the chatbot session, the information will be held for 30 days and then deleted. SP Energy Networks will have no access to the data after this time. Cookies Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies enable us to: Ensure our websites are working correctly Offer you a customised web service Continually improve our websites for you We do not use cookies to: Collect any Personal Information Managing Cookies If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser. Further information can be found on your browser's site. Other circumstances in which SPEN may disclose your Personal Information We are regulated by OFGEM and sometimes they request information that includes Personal Information, for example, where they request information on areas affected by power cuts or in relation to low carbon initiatives. We take steps to ensure that any information provided to OFGEM is provided securely. We may disclose your Personal Information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may disclose your Personal Information to third parties: In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets, but only if such disclosure is reasonably required for the purposes of the sale or purchase; If all or substantially all of our assets are acquired by a third party, your Personal Information may be one of the transferred assets; If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of SPEN our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. What are your rights? In accordance with the GDPR, you can contact us at DP@spenergynetworks.co.uk to exercise any and all of the following rights that you have in relation to our processing of your personal information: Right of access – you have the right to obtain confirmation that your personal information is being processed and access to your personal information Right to rectification – you have the right to have your personal information rectified if it is inaccurate or incomplete Right to erasure (Right to be forgotten) – you have the right to request the deletion or removal of your personal information where there is no compelling reason for its continued processing by us Right to restrict processing – you have the right to request that we block or supress processing of your personal information Right to data portability – you have the right to obtain and reuse your personal information for your own purposes across different services as the processing is based on your consent Additionally, you have the right to lodge a complaint with our Data Protection Officer at dataprotection_corporate@scottishpower.com if you believe that your personal information is not being processed in line with this privacy notice. If you are not satisfied with the response, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) by contacting: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 Changes to the Policy Any changes we may make to our Policy in the future will be posted on this page Version date: November 2020