Household customers privacy

Our privacy notice explains when and why we collect personal information about our household customers, how we use it and the conditions under which we may receive it and share it with others. It also explains how you can obtain details of the information we hold about you and the choices you have about how we use that information.

Southern Water is a water and sewerage undertaker. Its authority to act and carry out its duties is set out in the Water Industry Act 1991. Southern Water therefore relies on its statutory legal obligation and public task as its primary lawful bases to process Personal Data:

• To manage your billing account, including receiving payments
• To respond to any queries and/or complaints about our services
• To provide water and/or wastewater services, maintain and repair our infrastructure and assets, including those that may be on, or in the proximity of, your property
• To contact you if we need to maintain or repair our infrastructure that may be on, or in the proximity of, your property
• To share information with neighbouring water companies to complete the billing process, where applicable
• To provide you with information and updates about water efficiency and blockages, and to educate our customer population around water efficiency and related methods to reduce water consumption and/or waste
• To offer you a free water efficiency visit because of your water usage or financial circumstances
• To obtain customer feedback to improve the services we provide
• To notify you of changes to our services
• To track and record your water usage, including by using intelligent meters, leak detection and water efficiency methods
• To assist vulnerable customers, including managing Southern Water’s Priority Services Register
• To run our business and provide our statutorily required services, including maintaining and developing our IT infrastructure and support services
• To undertake debt collection and tracing activities
• To provide customer services facilities
• To communicate with our customers and other relevant third parties.

In certain other cases, Southern Water relies on its legitimate interest to process Personal Data, as per the below. In such instances, Southern Water has ensured that it has undertaken an appropriate assessment and where relevant, an appropriate balancing test to ensure your rights to private life are not inappropriately invaded.

• To consider your financial circumstances and demographics, including if we haven’t received payment from you and to allocate the most appropriate tariff, billing and/or collections route for you. (In some circumstances this may mean that your payment is referred to a debt collection agency working on our behalf or we’ll look to recover payment through the courts. We'll always take appropriate measures to ensure we've done this in accordance with our internal governance to ensure we are fair and proportionate).
• To offer you water and wastewater-related goods and services, including by third party partners.
• To track customer trends to improve the way we work and the services we deliver to you. This includes the use of cookies, such as Google Analytics, which may, depending on the preferences you set, track your activity/customer journey across our website by way assigning unique identifiers to your device/browser.
• To provide credit reference agencies and other bodies with information for credit management purposes, such as informing them of your payment history, status and performance against your payment plan, on an ongoing basis, and this information could be used by other third parties to make future credit assessments about you.
• To undertake public and customer consultations, surveys and research.

In limited circumstances, we'll use your consent to process your Personal Data. With your consent we will:

• Send you communications which you've requested.
• If you’ve asked to join the Priority Services Register, give you priority services in the event of an emergency.
• Obtain information that we deem appropriate from Equifax Open Banking to ascertain your financial circumstances for the purpose of assessing whether you qualify for assistance relating to your tariff and/or water bill. Further information on how Equifax Open Banking will process your personal data can be found on their website.

You may withdraw your consent at any time by contacting us on 0330 303 0277.

The exact information we collect may vary based on the service we provide to you. Typically, we need information as set out in the table below.

Southern Water collects information from you when:

• you set up an account with us, including via our website
• you contact us for any reason by phone, email, webchat and/or any social media platforms
• you visit our website
• you complete a Southern Water online form, and/or enter a competition or complete a survey sponsored by Southern Water
• you give us, or we take, water meter readings
• you sign up for special tariffs or discounts
• you register as a Priority Services customer
• we visit you at home, in connection with works, repairs, water efficiency visits or other valid reasons.

Southern Water collects information relating to you from third parties when they contact us directly e.g., landlords, Housing Associations and other water companies (in circumstances where the water companies share infrastructure with us and/or for joint billing purposes).

Southern Water additionally may receive information relating to you from data management organisations and/or tracing agencies, to ensure that the information that we hold about you is relevant, up-to-date and accurate. We may also use this information to identify current or previous occupiers of properties in our catchment area for billing purposes.

Further, Southern Water will also share and receive information relating to you from debt collection and tracing agencies, Credit Reference Agencies (CRAs) and publicly accessible sources such as the Register of County Court Judgments (CCJ) and the Register of Bankruptcies for the purposes of debt management.

Where information is received from CRAs, they will supply to us public information (including the electoral register) and will share credit, financial situation and financial history information and fraud prevention information.

We'll use this information to:

• ascertain and continuously verify the information about our account holder(s) and/or other liable residents of the household that has been provided to us is accurate
• ensure any financial support offers and advice are appropriate to your individual and/or household circumstances
• trace and recover any debts; and
• prevent criminal activity, such as financial fraud.

This means that we'll continue to exchange information about you with CRAs throughout your relationship with us as account holder(s) and/or other liable residents of the household up until your account is fully settled. We'll also inform the CRAs about your settled accounts. If you fail to make any payments and don't pay in full and/or on time, this will be reflected on your credit report with the CRAs.

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 information, data retention periods and your data protection rights with the CRAs are explained in more detail at:

• Equifax: Privacy & Cookie Policy | Equifax UK and equifax.co.uk/crain
• Experian: Experian Privacy Policy

Southern Water has a suite of companies that work on its behalf. Southern Water has appropriate contractual clauses in place with such companies to ensure that your information is protected to the same standard.

We set out below the categories of organisation who work on our behalf.

• Capita, who provide us with customer service functions/facilities, and/or who assist us to manage your billing account (including receiving payments), and/or who respond to any queries and/or complaints about our services.
• Third-party partners who undertake debt collection activities for us. Please note that, at all times, the debt remains Southern Water’s. The names of these third-party partners under this category are: UK Search Ltd, Moorcroft Debt Recovery Services Limited, Orbit UK Limited, Philips & Cohen.
• Any third-party partners who:
• Undertake tracing activities for us.
• Provide us with IT, IT infrastructure and support services.
• Provide us with meter reading and related support services.
• We've engaged to offer you water and wastewater-related goods and services.
• Assist us with delivering water and/or wastewater services, including maintaining and repairing our infrastructure (including any such infrastructure/assets that may be on, or in the proximity of, your property).

In addition, we may share information about you with the following people/organisations.

• Any of your family, associates, or someone who represents you, where you’ve asked us to do so only.
• Our regulators (e.g. Ofwat, the Drinking Water Inspectorate and the Environment Agency), the Consumer Council for Water, Natural England, Public Health England, local authorities and other water companies to meet our obligations under the Water Industry Act 1991 and related legislation.
• BMG Research on behalf of Ofwat to conduct surveys to meet our regulatory obligations to rate Southern Water’s performance against other water companies.
• External agencies like the police, fire service, or local councils in the event of an emergency situation (e.g. loss of water).
• Other water companies that supply your drinking water or that remove your wastewater that is not Southern Water - this is to calculate your bill or to provide common billing.
• Charities and not for profit organisations, including those to support Priority Services customers who have explicitly agreed by consent that we can pass their details on.
• Credit reference, fraud prevention, debt collection and/or tracing agencies and data management organisations to help prevent and detect fraud, to keep our contact data up to date and to recover debt. Southern Water uses Experian and Equifax. Further details as to how Experian and Equifax use your personal data can be obtained by clicking the links in this bullet point.
• Payment service providers, including World Pay. Further details as to how World Pay uses your personal data can be obtained by clicking the link in this bullet point.
• HomeServe Limited, a separate Data Controller, to offer you insurance products and services relating to the supply and collection of water. If you want to know how HomeServe will process your information, please see their Privacy Notice.
• Any of our partners who work with us in relation to public and customer consultations, surveys and research.
• Local Councils and Local Authorities, as required by law, and also in circumstances where properties have had water efficiency measures installed by such Local Councils/Local Authorities, for the limited purpose of providing them with data for their own analytical and statistical purposes, e.g. Crawley Borough Council (whose privacy notice can be accessed here: Crawley Borough Council privacy notice | Crawley GOV).
• Other utility companies, to make sure our/their Priority Services Register is as comprehensive as possible.

Southern Water does not undertake any full automated decision making and/or profiling but we sometimes use profiling to identify which of our customers need additional help from us and to ensure that customers get an experience that is most appropriate for them and/or are on an appropriate tariff.

We use your payment history, and data from the Office of National Statistics on the level of deprivation in your area, to determine whether you might need additional financial support from us. This could be in the form of communications about support available to you, or fast-tracking you through refunds you are eligible for, without you having to apply. We also use your payment history to determine how we communicate with you about your future bills and any collections activity we may need to undertake.

We'll tell you about water-related products, services which we think may be of interest to you, including products provided by HomeServe. You may ask us at any time to stop sending you these communications by contacting us on 0330 303 0277.

Please note that you’ll still receive non-personalised information about us or water-related goods and services. These are delivered by Royal Mail. You can opt out of receiving these by:

• Email optout@royalmail.com
• Telephone 0345 266 0858
• Visit Royal Mail

For details visit the Royal Mail.

We sometimes share your information with carefully selected organisations outside the UK, such as contractors working on our behalf to provide services to you. In such instances, we ensure that an appropriate and valid derogation is used for international transfers of data compliance.

We’ll hold the information on our system for as long as is necessary for the relevant activity, or as long as is needed to meet our legal and accounting obligations.

Please tell us as soon as possible if your contact details or other personal information change, or if you think that the information we have isn’t accurate. You can contact us on 0330 303 0277.

When you’re no longer liable for our charges, for example, if you’ve moved house, or there’s a change to the people who are jointly liable with you, you should tell us about this as soon as possible. If you don’t, it could result in incorrect data being shared and used by credit reference agencies, which may affect how other organisations view your credit worthiness.