What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Occupation
- Date of birth
- Third party information (such as family members or other relevant parties)
- Payment details (including card or bank information for transfers and direct debits)
- Financial data (including income and expenditure)
- Transaction data (including details about payments to and from you and details of products and services you have purchased)
- Usage data (including information about how you interact with and use our website, products and services)
- Credit history and credit reference information
- Information relating to compliments or complaints
- Account access information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Account information, including registration details
We collect or use the following personal information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Client account information
- Any other personal information required to comply with legal obligations
We collect or use the following personal information to protect client welfare:
- Names and contact information
- Client account information
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Addresses
- Payment details
- Account information
- Video recordings of public areas
- Customer or client accounts and records
- Financial transaction information
- Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We have a legitimate interest in collecting and using personal information to provide and improve our services, including energy procurement, contract renewals, new connections, meter installations, billing, site works, and dispute resolution. Processing this information is necessary to deliver accurate, efficient, and reliable services to our clients. The benefits to clients, such as tailored solutions, prompt resolution of issues, and compliance, are greater than any potential risks, and we take all reasonable steps to protect their data.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We have a legitimate interest in using personal information to manage our clients’ accounts. This includes keeping accurate records of contracts, billing, meter readings, and communications. It allows us to provide reliable service and quickly resolve any account issues, while keeping clients’ information safe and secure.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We process personal information to comply with legal obligations, including maintaining financial and audit records, meeting regulatory requirements, and fulfilling our taxation responsibilities. This ensures we operate in accordance with the law and maintain accurate records for compliance purposes.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to protect client welfare are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We process personal information to protect the welfare of our clients. This includes using data to resolve billing, metering, or contract issues, to contact suppliers, DNOs, or other professionals on behalf of clients, and to ensure accurate and timely delivery of services. Processing this information helps us act in our clients’ best interests and prevent potential problems or risks.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We process personal information to handle client queries, complaints, or claims effectively. This includes using data to investigate issues, communicate with relevant suppliers or professionals, and resolve matters promptly. Processing this information is necessary to ensure a fair, accurate, and timely response while protecting our clients’ interests.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
- Debt collection agencies
- Publicly available sources
- Credit reference agencies
- Suppliers and service providers
- Third parties:
- We may receive personal information from third parties, such as other brokers, aggregators, or professional advisers who refer clients to us or provide information on their behalf. This helps us manage client accounts, provide services, and ensure accurate and timely energy solutions.
How long we keep information
We retain customer data for three years after the end of the contract. Enquiries or leads are kept for up to one year unless a contract is initiated. Once the data is no longer required, it is securely deleted or destroyed using appropriate methods, such as shredding for physical documents or secure digital deletion for electronic records.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
We use service providers such as Microsoft OneDrive, Dropbox Sign, Gmail, and energy supplier portals to securely store and manage client data. All processors are based in the UK or EU and comply with data protection regulations.
This data processor does the following activities for us: They securely store and manage client data, handle e-signatures for contracts, manage email communications, and provide access to energy supplier portals for account management.
Others we share personal information with
- Debt collection agencies
- Other financial or fraud investigation authorities
- Insurance companies, brokers or other intermediaries
- Professional or legal advisors
- Organisations we’re legally obliged to share personal information with
- Suppliers and service providers
- Professional consultants
- Third parties:
- We share client information with energy suppliers, DNOs, and other professionals to manage accounts, site works, billing, and disputes, all in line with data protection rules.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
