Forbury Assets Limited has become Optimal Power Networks Limited, a part of SSE.

Privacy Notice

Optimal Power Networks (IDNO)
Last Updated January 2022

We are committed to ensuring your privacy is protected. This privacy notice explains how we use the information we collect about you.

1. About us

This privacy notice applies to Optimal Power Networks Limited company no. 11024024.

The registered office of Optimal Power Networks Limited is 1 Forbury Place, 43 Forbury Road, Reading, Berkshire RG1 3JH and the company is subject to the laws of England and Wales.

Optimal Power Networks will be referred to as “Optimal Power Networks”, “we” or “us” throughout this privacy notice.  We will be the “controller” of the information you provide to us.

We are an Independent Distribution Network Operator. We are responsible for managing and operating our networks, including all future maintenance and fault repairs. As such, we are legally required by our Electricity Distribution Licence to collect your personal data so that customers can be contacted in case of an emergency or a planned outage.

2. What information do we collect and how do we do it?

We, or third parties on our behalf, collect your personal data when you use our website, communicate with us by phone, letter, or email. We may collect the following personal data and we refer to this as “personal data” throughout this notice:

  • Your name;
  • Telephone number(s);
  • E-mail address;
  • Address;
  • Customer Password;
  • Customer Password effective date;
  • Meter Point Administration Number (MPAN) to identify your electricity supply;
  • Priority Services Register (PSR) Code;
  • PSR Code expiry date;
  • Call recordings;
  • If someone has committed fraud or stolen energy, e.g. by tampering with a meter or diverting the energy supply, we will record that information; and/or
  • If you visit our website, we store your IP address, the browser software you use and your behaviour on our website (for example, the pages that you click on). This information is collected through cookies. More information on how we use cookies can be found in our cookie policies on the relevant website.

In addition to collecting your basic personal data, if you have registered for our Priority Services we will process personal data concerning your health. This is known as special category or “sensitive” data. Our Priority Services Register allows us to review any vulnerability that you, the customer, may have so that we can appropriately prioritise our response in case of an emergency for example power failures.

We may also receive personal information about you from your electricity suppliers, gas suppliers, water companies, welfare organisations and NHS organisations to include you on our Priority Services Register so that you will benefit from this service. We will send you a letter to notify you when you have been added to the register.

3. What do we do with your personal data?

We use your information to:

  • register you for our Priority Services;
  • ensure that you are provided with the ongoing support you need in an emergency, bad weather and for planned supply interruptions (including providing you with updates and alerts) both onsite and through our customer contact centre;
  • liaise with your nominated contact (where provided);
  • periodically contact you to confirm that the details we hold for you are up to date;
  • provide you with information in Braille, via an audio CD or language other than English if you require it;
  • manage staff and third-party contractors;
  • Provide you with the most appropriate customer experience where you attend an Optimal Power Networks event;
  • provide you with a security password; and
  • Monitor, measure, improve and protect the content or our websites and services to provide enhanced and personal user experience for you.

Your special category or “sensitive” data (e.g. personal data concerning health) may also be used for the following reasons:

  • to protect your vital interests or the vital interests of another person (if you or they are incapable of providing consent);
  • during civil protection activities in the event of an emergency under the Civil Contingencies Act 2004; or
  • for the establishment, exercise or defence of legal claims.
4. Marketing Communications

Unless you’ve asked us not to, we may contact you in writing, by phone and (where you have consented) via email or SMS with information on products, services and rewards that we and occasionally our carefully selected partners identified at the time we collect your information, offer. We may also use third parties to send marketing communications.

Unless you have asked us not to, we may also use your personal data to show you digital advertisements via your social media newsfeed, on search engine results pages, or on other websites.

Unless you have asked us not to, we may profile your data to provide you with marketing and offers that are relevant to you. If you opt out of profiling, we will still run analysis that includes your data, but any decisions or marketing output that result from that analysis will not be used to market to you. You will be sent generic marketing that may not be relevant to you.

To opt out of receiving marketing messages, or to object to our use of profiling for direct marketing purposes, contact us at any time using the details in section 11.

5. Legal bases for processing, including legitimate interests

In order to process and use your personal data lawfully, we rely on the following legal bases:

  • Legal Obligation – to comply with our legal obligations to comply with our Electricity Distribution Licence;
  • Legitimate Interest – to communicate with customers connected to our networks in the case of supply interruptions; and/or
  • Substantial Public Interest – to process your sensitive personal data in order to facilitate the Priority Services Register.
6. Who do we share your personal data with?

We may share your personal information with the following categories of third parties:

  • welfare organisations, local authorities, and emergency services for those organisations to provide support and assistance to you in special circumstances or emergencies;
  • our sub-contractors to provide onsite support during planned supply interruptions, bad weather or emergencies;
  • Monitor, measure, improve and protect the content or our websites and services to provide enhanced and personal user experience for you; and
  • as an independent distribution network provider, we work closely with third parties, including your electricity supplier, sub-contractors, National Grid, Members of Parliament, local authorities, housing authorities, charities and the Office of Gas and Electricity Markets (“Ofgem”).
7. How long do we hold it for?

We will keep your information only for as long as is necessary depending on the purpose for which it was provided.

When determining the relevant retention periods, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • (potential) disputes; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

8. Your rights

You have the following rights regarding your information:

Right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we are providing you with the information in this privacy notice.

Right of access

You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this privacy notice). This is so you are aware and can check that we are using your personal data in accordance with data protection law(s).

Right to rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

Right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not an absolute right to erasure; there are exceptions.

Right to restrict processing

You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.

Right to data portability

You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

Right to object to processing

You have the right to object to your personal data being processed in certain circumstances. This includes where we are relying on legitimate interest and for direct marketing purposes (including profiling).

Right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for direct marketing.

9.   International data transfers – How is your personal data transferred outside of the European Economic Area (EEA) and the UK?

We, or a third party who we share personal data with, may transfer, host, store and/or handle your personal information outside of the EEA.  For example, where we and/or our service providers (including servers) are based outside of the EEA.

The EEA consists of countries in the European Union, Iceland, Liechtenstein and Norway and are all considered to have equivalent laws in data protection and privacy. The UK including Northern Ireland, are also considered to have equivalent laws in data protection and privacy.

We will only permit this to happen if adequate safeguards have been put in place to protect your personal data. For countries outside the UK, this means that we will:

  1. ensure that the country in which your personal data will be handled has been deemed “adequate” by the European Commission under Article 45 of the General Data Protection Regulation (GDPR); or
  2. include standard data protection clauses approved by the European Commission for transferring personal data outside the EEA and the UK into our contracts with those third parties (these are the clauses approved under Article 46.2 of the GDPR).
10. Changes to this notice

We may update our privacy notice from time to time. Any changes we make to our privacy notice in the future will be posted on the Optimal Power Networks and, where appropriate, notified to you by post or email.

For more information on your rights or if you would like to exercise any of your rights, you are welcome to contact us at the contact details set out below under “Contacting us”.

11. Contacting Us

If you would like to contact us in relation to your rights or if you are unhappy with how we have handled your information, you may do so using the following details:

Email: DEDataProtection@sse.com

Address: Optimal Power Networks Limited, Inveralmond House, 200 Dunkeld Road, Perth, PH1 3AQ

If you would like to contact our Data Protection Officer, you may do so using the following details:

Email: GroupDPO@sse.com

Address: Data Protection Officer, No. 1 Forbury Place, 43 Forbury Road, Reading, RG1 3JH

12.  ICO Complaints

If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:

Telephone Number: 0303 123 1113

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Website: www.ico.org.uk