Only the Best Deals backed by the best service

Privacy Policy

 

GDPR Privacy Policy


What users can expect will happen to their data

The following sections are provided for under this document;

Lawful bases for processing data?

What information is being collected?

Who is collecting it?

Why is it being collected?

How is data collected?

How will the data be used?

Who will it be shared with?

What will be the effect of this on the individuals concerned?

Is the intended use likely to cause individuals to object or complain?

Lawful bases for processing

The lawful bases for processing are set out in Article 6 of the GDPR.

This states that at least one of these must apply whenever you process personal data:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Innovative Energy Solutions Ltd can identify three of the above options as being lawful, applicable reasons under which we process data.

Options B, C and F apply to our organisation; however, we intend to operate going forward under option “F” as a lawful basis for processing and the following detail provides the rationale behind this decision. Appendix “One” also provides evidence of a client’s “legal Obligation” for utility services, under their tenancy agreement.

Why is the data being collected?

Our organisation provides an “outsourced” utility management service to the UK residential sales

and lettings industry as well as the Social Housing sector. We create a formal, contractual

relationship with sales and lettings agents and social housing depts, in handling the complete change

of occupier function on their behalf.

Who is collecting it?

To allow our organisation to carry out its agreed services, we need to receive, distribute and

retain a specific amount of client data. Innovative Energy Solutions Ltd are both “Data

Controllers” and “Data Processors” under our current data protection laws.

What information is being collected?

In respect of our tenants, the following fields are collected and sent out to councils, water

and energy providers;

o Tenant(s) full names

o Tenant(s) contact telephone numbers(s)

o Tenant(s) email address

o Tenancy address

o Lead tenant employment status

o Tenancy start/end date

o Tenant “move in” or “move out” date

o Meter read information, to allow “opening/closing” bills to be issued

o Tenant forwarding address (if applicable)

In respect of our landlords, the following fields of data are collected and sent out to the

respective councils, water and energy providers;

o Landlord/Agent name

o Full property address

o “Move in” or “move out” dates

o Meter read information, to allow “opening/closing” bills to be issued

o Void period billing address

Each “change of tenancy” which occurs in a rented property, carries a legal obligation on the

responsible party to undertake the communication of any such “change of occupier” status

to their local water authority.

The Flood and Water Act 2010 (Paragraph 45(1) states the following;

45 Water and sewerage charges: non-owner occupiers

(1) After section 144B of the Water Industry Act 1991 (charges: charging by volume) insert—

“144CNon-owner occupiers

(1) This section applies to residential premises which are occupied by one or more persons other

than the owner (and not by the owner).

(2) The owner must arrange for the undertaker to be given information about the occupiers.

(3) If the owner fails to comply with subsection (2), the occupiers' liability for charges under this

Chapter becomes shared jointly and severally with the owner.

How is data collected?

All data collected and distributed using the following methods:

Encrypted csv/xml file

SFTP transfer

Encrypted email

Encrypted online SSL webform

How will the data be used?

Our organisation provides proof that reasonable steps were taken in communicating the

relevant change of tenancy data to each respective water authority, council and energy

provider. Indeed, councils across the land are also placing a liability on the owner of a

property to communicate any change in occupancy in a timely manner and if reasonable

steps cannot be proved, then a financial penalty can be applied. Our model affords the

owner of said properties the reassurance that they are compliant with each relevant

authority and any such orders and legislation.

A fundamental aspect of our service is to ensure that all tenants are made aware of their

“contractual obligations” in relation to utility services within their new home. This can be

provided for in a variety of ways, and historically was provided for by relying on a tenant to

read the relevant section within their tenancy agreement (See Appendix One). This has proven

to be ineffective and has led to issues when it comes to the closing and opening of utility

bills within rented properties.

Our model has been created to deal with this ongoing issue and is designed to “educate and

support” our tenants in fulfilling their own legal and contractual responsibilities. Our

extensive experiences in this field, proves that the optimum delivery method is to verbally

communicate this with each specific lead tenant, allowing us to support each individual

where required in fulfilling their legal responsibilities and at the same time recording the

entire process to provide a robust audit trail in the event of discrepancies later.

Who will it be shared with?

In addition to current councils, water, energy or managing agents, there may be occasion

where we need to deal with issues or discrepancies relating to previous utility

services/billing. To ensure that we can confirm all change of occupancy details at any time,

we retain the above data for a minimum period of six years.

When it comes to new services, then these are always instigated at the request of our

tenants. To fulfil this request, we would need to pass on personal financial data to our many

service providers. This operation is carried out securely, using the appropriate

communication methods (portal, email or “hotkey”) and while providing this service, we

never retain client personal financial data within our systems. confirmation of their legal responsibilities towards utility services and the provision of ongoing support for the responsible party, we reduce the likelihood of issues arising from billing and other service related problems commonly associated when renting a property within the UK.