Privacy Policy
Last updated April 2019
1. INTRODUCTION
Protecting our customer’s personal data is important to Energia. This Privacy
Statement sets out how we collect, use, store, share and protect your personal
data in compliance with Data Protection legislation.
1.1 Company Information - Energia is part of the Energia Group, the leading
independent energy company in the all-Ireland market. Energia is the
trading name of Energia Customer Solutions Limited (in respect of
customers connected in the Republic of Ireland), a company registered in
Ireland with company number 306035 and having its registered office at
The Generali Building, Blanchardstown Retail Park, Dublin 15, D15 YT2H and
Energia Customer Solutions NI Limited (in respect of customers connected
in Northern Ireland), a company registered in Northern Ireland with
company number NI035800 and having its registered office at Greenwood
House, 64 Newforge Lane, Belfast, BT9 5NF. Further information can be
found at
https://www.energia.ie/home
1.2 Contact us - If you have questions as to the manner in which your personal
data is being handled or if you require any further information you can
contact the Data Protection Officer at Dataprotection@energia.ie or by
writing to the :
• (ROI customers) Data Protection Officer, Energia, The Generali Building,
Blanchardstown Retail Park, Dublin 15, D15 YT2H.
• (NI customers) Data Protection Officer, 64 Newforge Lane, Belfast, BT9 5NF.
1.3 Statement Review - This Statement will be regularly reviewed to ensure
we continue to meet our obligations in processing your personal data
and protecting your privacy. In order to do so we reserve the right to
update, modify and amend this Statement at any time as required. We
would recommend that you check back regularly to keep informed of
any updates. We will not make any significant changes to the Statement
without informing you.
1.4 Protecting your Information - We are committed to protecting your personal
data and to implementing appropriate technical and organisational security
measures to protect it against any unauthorised or unlawful processing and
against any accidental loss, destruction, or damage.
2. DATA WE COLLECT
In order to provide energy products and services and provide you with information
on these products and services we need to collect a number of categories of
personal data through a number of channels including from you, third parties,
other energy suppliers, the network providers and credit reference agencies. We
obtain this personal data during the registration process, marketing or through
our on-going management of your account. We cannot provide you with energy
services or offer you a contract based on the products or services which best suit
your requirements unless we have the necessary information.
These personal data categories include:
Name, address, contact details such as telephone number, mobile phone
number, email address, date of birth, property details, bank details, credit and
debit information, records of payments and any arrears , marketing preferences,
property categorisation, telephone recordings, website usage on
https://energia.ie/home
and
https://www.energia.ie/business
, IP address, energy
usage, contract duration, identity verification questions (such as mother’s
maiden name), and contact notes.
In certain circumstances and as part of our regulatory requirements we may
collect special categories of personal data for the customer care register
including any disabilities or special needs information necessary to support the
provision of service to you.
3. HOW WE USE YOUR INFORMATION
We will use your personal data to provide you with energy products and services
and to allow us to better manage your customer account. In particular we may
use your personal data for the following purposes:
3.1 Account Management - In order to set up and administer your account
and manage your customer journey and contact with us we are required to
process your personal data. This involves processing personal data for the
purpose of account set up, monitoring, identity verification and managing
your account including obtaining credit references, implementing a
change of supplier and obtaining, maintaining and exchanging information
on meter points, occupancy details, billing purposes and processing
payments.
Legal Basis: The processing is necessary for the performance of the
contract which you are party to or in order to take specific steps prior to you
entering into a contract.
Legal Basis: The processing is necessary to comply with our legal obligations.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to use certain
personal data to establish, maintain and review an account to allow Energia
to better manage customers’ accounts, enforce rights set out in the terms
& conditions of supply, and to ensure customers are provided with the most
appropriate products and services.
3.2 Customer Support - In order to respond to queries and manage and
investigate any complaints we are required to process your personal
data. If you contact our customer service team or if we contact you we will
use personal data such as account information and contact history. We
may monitor and record such communications, instant messaging (web
chat), email and other electronic communication to help investigate any
complaints and for training purposes.
Legal Basis: The processing is necessary for the performance of the
contract which you are party to in order to take specific steps prior to you
entering into a contract.
Legal Basis: The processing is necessary to comply with our legal obligations.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to use certain
personal data to establish, maintain and review an account to allow Energia
to better manage customers’ accounts, enforce rights set out in the terms
& conditions of supply, and to ensure customers are provided with the
most appropriate products and services and that customer complaints are
resolved appropriately.
3.3 Marketing - In accordance with your marketing preferences, from time to
time we may provide you with information on our products and services/
promotional efforts and those of carefully selected third parties (whose
products and services may be unrelated to ours) which we feel may be of
interest to you. Again depending on your marketing preferences we may
also contact you after you have ended your account with us to make you
aware of our products, services and any available offers.
Depending on your marketing preferences and as otherwise permitted by
law we may contact you by:
(a) Non-electronic means, including by post or in person; and
(b) Electronic means including live telephone calls, email, SMS (texts),
multimedia messaging or social media (e.g. Facebook and Google).
Legal Basis: The processing is based on your consent for the specific purpose
(e.g. by opting in and receiving certain marketing communications on sign
up or otherwise, including by joining the Energia Extra Rewards Scheme).
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to provide you
with information on Energia products and services including information
that we have tailored to your interests.
If you wish to change your marketing preferences you can do so at any time by
writing to us at the address provided above, emailing us at homeenquiries@energia.ie or by calling customer services on 1850 405 405.
3.4 Customer Loyalty Programme - If you sign up to the Energia Extra
programme in order to verify you are an Energia customer we are required
to process your personal data.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to verify that
those signing up for Energia Extra are entitled customers.
Legal Basis: When you sign up to Energia Extra, you are requested to
consent to the processing on your personal data as stated in our sign up
process, which you may withdraw at any time by leaving Energia Extra.
3.5 Credit Reference Checks & Fraud Prevention (Commercial Customers
Only). - In order to enter into an agreement with you and assess any level
of risk we may carry out necessary credit reference checks.
Legal Basis: The processing is necessary for entering into or the
performance of a contract to which you are subject.
Legal Basis: The processing is necessary to comply with our legal
obligations.
Legal Basis: The processing is necessary for the legitimate interests of the
controller or a third party. It is within Energia’s legitimate interest to carry out
such processing to assess creditworthiness and protect Energia from fraud.
3.6 Improving our Products & Services - In order to improve our products,
services and customer interaction we carry out customer surveys and
market research which involves the processing of personal data.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to provide you
with the best customer experience by ensuring that we continually improve
our processes and offerings.
3.7 Debt Management - In order to allow Energia to appropriately manage any
debt issues if they were to occur.
Legal Basis: The processing is necessary for the performance of the
contract to which you are party or in order to take specific steps prior to
entering into a contract.
Legal Basis: The processing is necessary for our legitimate interests of the
controller or those of a third party. It is within Energia’s legitimate interest
to use certain personal data to help manage a debt issue and enforce rights
set out in the terms & conditions of supply.
3.8 Regulatory & Licence - In order to meet our regulatory and licence
requirements Energia is required to process personal data and provide
information to the Regulatory Authorities and government departments.
Legal Basis: The processing is necessary to comply with a legal obligation
to which we are subject under our Licence requirements.
3.9 Website Statistics - Like most websites, we gather statistical and other
analytical information of all visitors to our website including cookies and
click trails. We use the data gathered to get a better understanding of
where our visitors come from and to help us better design and organise
our website and for the purposes set out below at Assessment of Customer
Preferences and Account History.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to provide you with the best customer website experience by ensuring that we continually
improve our processes and website.
3.10 Assessment of Customer Preferences and Account History - Our systems
assess customer profiles such as payment preferences, online account
preferences, payment history, contract duration, services delivered,
contact history, website visits, sign up behaviour/channel etc. in order to
assess customer loyalty for marketing or contract renewal purposes and
to determine what services or special offers or, where available, customer
rewards, may be of interest to certain customers. Profiling may result in
customers being offered different customer rewards or rewards of different
value or may result in customers being specifically contacted (in accordance
with any consents given) to be informed of our service offerings or contract
renewal options. Any customer may contact our Customer Service Teams
at any time to enquire about our latest offers or contract renewal options.
Legal Basis: The processing is necessary for our legitimate interests or
those of a third party. It is within Energia’s legitimate interest to provide
you with the best customer experience and offers relevant to you.
3.11 Recruitment - If you submit a job application online, we will use your
personal data for recruitment-related purposes, which may include
contacting you via email, telephone, SMS or post.
Legal Basis: The consent of the individual.
Legal Basis: The processing is necessary to comply with legal obligations
to which we are subject under our employment law.
3.12 Special Categories of Personal Data - In order to support customers
requiring additional account management support (e.g. customers with
poor eyesight or blindness requiring bills to be provided in braille or
assisting customers in ill health with debt or payment management plans),
we may from time to time obtain data concerning a customer (or previous
customer’s) health such as a vulnerable customer checklist.
Legal Basis: The explicit consent of the individual.
Legal Basis: Where required to protect the vital interests of the individual
where the individual is physically or legally incapable of giving consent to
such processing.
Legal Basis: The processing is necessary to comply with legal and regulatory
obligations to which we are subject under our Licence requirements.
4. SHARING YOUR INFORMATION
There are a number of circumstances in which we may share your personal data
within the Energia Group and with other parties. Below is a list of such potential
recipients or categories of recipients with whom we may share information.
• In order to meet our Licence and Regulatory requirements we are
required to share certain personal data such as with the Network
Companies (a) ROI customers – Electricity Supply Board (ESB) and Gas
Networks Ireland (GNI) (b) NI customers – Northern Ireland Electricity
Networks Ltd (NIE).
• In order to meet our requirements with the Regulators (a) ROI –
Commission for Regulation of Utilities (b) NI – Utility Regulator.
• In order to support the process for transferring customers between
Energy Service Providers we are required to share certain personal data
with previous, current and future suppliers to establish all relevant details
to help transfer supply and establish the details of any outstanding debt.
• In order to carry out credit checks when entering into an agreement we
may share personal data with financial institutions and credit reference
agencies.
• In order to meet legal and regulatory requirements we may share
personal data with fraud prevention agencies.
• For debt management purposes we may in certain cases be required to
share personal data with debt collection agencies.
• We may disclose information when required by law or legal process for the
administration of justice, to protect your vital interest, for investigations
by law enforcement or regulatory bodies, to protect and defend Energia’s
property and legal rights or by order of a valid order from a court or law
enforcement agency.
• Organisations who act as service providers to Energia such as providers
of telecommunications, postal services, records storage, data storage,
document production and destruction, IT services and security, fraud
detection, customer loyalty programmes, marketing and market
research, and making and receiving financial payments.
We may pass personal data to our agents and service providers and group
companies when relevant for these purposes, including the use of cloud
providers. This may involve passing your personal data outside of the European
Economic Area and any such recipients will be bound to comply with the European
Commission standard contractual clauses for the transfers of data outside the
EEA. Further information is available from homeenquiries@energia.ie.
5. RETENTION OF YOUR INFORMATION
We will retain your personal data only for as long as is necessary for the
purposes for which it was collected and in order to meet the legal and business
requirements of managing your customer account and experience with us. In
particular:
• We will retain personal data that is necessary for us to provide you with a
product or service that you have requested or purchased for as long as it
takes us to provide that product or service;
• We will retain your contact details for marketing purposes for as long as
we have your permission to send you marketing information or for as long
as we are permitted to do so, subject to your right to object at any stage;
• We will retain records of any transactions you enter into with us or
products or services you receive for up to seven years after the date of the transaction. This is so that we can respond to any complaints or disputes that arise in that period;
• We will retain any financial transaction information for seven years after
the date of those transactions; and
• We will retain other personal data necessary for us to do so to comply with
our regulatory and legal requirements.
6. YOUR RIGHTS
The General Data Protection Regulation provides you with a number of rights
under the legislation as a data subject. We will respond to your requests within
one month of the receipt of your request or inform you in circumstances where
an extension may be required.
6.1 Right of access - You have the right to be provided with details of the
processing of your personal data and to obtain a copy of the personal data
we hold about you, subject to applicable exemptions. To help us better
deal with your request please provide us with the information necessary to
identify you (name, address, account number) and to identify the personal
data you require.
In order to make an access request please email Dataprotection@energia.ie or
send your request in writing to:
• (ROI customers) the Data Protection Officer, Energia, The Generali Building,
Blanchardstown Retail Park, Dublin 15, D15 YT2H.
• (NI customers) the Data Protection Officer, 64 Newforge Lane, Belfast,
BT9 5NF.
6.2 Right to rectification - If the personal data we hold on you is inaccurate or
incomplete you have the right to rectify such personal data and we would
encourage you to ensure the personal data we hold on you is kept as up to
date and accurate as possible.
6.3 Right to Erasure - In certain circumstances you have the right to request
the deletion of your personal data where there is no compelling reason for
us to continue processing it.
6.4 Right to restrict processing - In certain circumstances you can request
the restriction of the processing of your personal data where you contest
the accuracy of the information; where you object to processing which is
based on legitimate interests; where the processing is unlawful and you
wish to restrict the processing rather than seek erasure; or where we no
longer require to retain your personal data but you wish the personal data
to be held while you establish, exercise or defend a legal claim.
6.5 Right to data portability - You can request to receive your personal data,
which you provided to us, in a structured, commonly used and machine
readable format and have the right to transmit this data to another
controller.
6.6 Right to withdraw consent - If we are processing your personal data on the
legal basis of consent you have the right to withdraw your consent at any
time. If you withdraw your consent we will no longer be able to carry out
processing based on your consent. However by withdrawing your consent
it does not invalidate any processing which was undertaken prior to the
withdrawal of your consent.
6.7 Right to object to processing - You have the right to object to
processing based on legitimate interests and to direct marketing
(including profiling for the purpose of direct marketing).
Where we have indicated that we are processing your personal
data based on legitimate interest you are entitled to object to such
processing on grounds relating to your particular situation. We will
stop processing your personal data unless we can demonstrate
compelling legitimate grounds for the processing which overrides
your interests, rights and freedoms or where the processing is
necessary for the establishment, exercise or defence of legal claims.
If you wish to object to receiving direct marketing please use the
provided opt-outs or contact us to do so.
6.8 Automated Decision making including profiling - You have the right not
to be subject to automated individual decision making, including profiling,
which produce legal effects concerning you or similarly significantly affect
you unless it is necessary for the entry into or performance of a contract,
authorised by EU or member state law, or based on your explicit consent.
6.9 Right to lodge a complaint with Data Protection Commissioner - You
have the right to lodge a complaint with the:
• (ROI customers) Data Protection Commissioner by emailing
info@dataprotection.ie
or writing to the Data Protection Commissioner,
Canal House, Station Road, Portarlington, R32 AP23 Co. Laois.
• (NI customers) Information Commissioner’s Office by emailing via
https://ico.org.uk/global/contact-us/email/
or writing to the Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.
