Let's make things transparent

We want you to know exactly what we do with data that we receive from you or from 3rd parties about you, after all it is your data! To make things simpler-er we've compiled this Privacy Notice which sets out how we process, retain and pass on data about you. This privacy notice will inform you as to how we look after your personal data when you visit our website (Regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Everflow is made up of the following entities: Everflow Limited; Everflow Holdings Limited; Everflow Operations Limited; Everflow Project 1 Limited and Everflow Tech Limited. Everflow Limited is the ultimate controller for personal data processed when contacting any Everflow company.

As part of Everflow's business, we offer different types of services, being

  1. Water Supply Services
  2. Waste Disposal Services
  3. Telecommunications Services
  4. Energy Services
  5. Environmental and Sustainability Services
  6. Professional Services
  7. Insurance Services

(Each a Service, together the Services).

  • Water Supply Services include the supply of water to our customers and water waste services (Known as Water Supply Customers).
  • Waste Disposal Services include the disposal of domestic waste for our customers (Known as Waste Disposal Customers).
  • Energy Services include the supply of Gas and or Electricity (Together referenced as 'Energy') to our customers (Known as Energy Supply Customers).
  • Telecommunication Services include the supply of Fixed Line, Mobile\Cellular, Broadband, PoS and Virtual Telephony to our customers (Known as Telecoms Customers).
  • Environmental Services include installation of PV Panels, Electric Charging Points, Provision of Energy or Water saving equipment. (Known as Environmental Services Customers).
  • Professional Services includes Technical Advice, Project or Technical Management of implementation, delivery of products provided as part of Everflow's suite of services. (Known as Professional Service Customers).
  • Insurance Services includes insurance products provided as part of Everflow's suite of services by Everflow or underwritten by its partners using the Everflow brand. (Known as Insurance Service Customers).

1. Controller

Everflow Limited is the ultimate controller for all the Everflow companies listed above and responsible for your personal data for each Service (Collectively referred to as "we", "us" or "our" in this privacy notice). All information obtained as part of any of our Services will be managed by us as the data controller.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (as set out below), please contact the data privacy manager using the details set out below.

2. Contact details

Our full details are:

Full name of legal entity: Everflow Limited
Name of data privacy manager: Jim Garrett
Email address: privacy@everflowutilities.com
Postal address: 2, Traynor Way, Peterlee, SR8 2RU
Telephone number: 0330 6600 137

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Changes to the privacy notice and your duty to inform us of changes

This version was last updated in January of 2023.

We keep our privacy policy under regular review, any changes we may make in the future will be posted on this page and, where appropriate, notified to customers by email. Please check back frequently to see any updates or changes to our privacy policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. Third Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

5. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide when you sign up as a customer to either of the Services we provide. This website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

6. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (Anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, residential address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, services purchased by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

7. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a Service). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

8. How is your personal data collected?

We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply to use any of our Services;
  • Create an account on our website (if applicable);
  • Submit meter readings through our website;
  • Request copy invoices through our website;
  • Fill in a 'contact us' form on our website;
  • Subscribe to our Services or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for more details on the cookies we use.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • Analytics providers;
  • Advertising networks; and search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Utility brokers and other Third Party Intermediaries;
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly available sources.

9. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of a Contract. Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Legitimate Interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Legal or regulatory obligation. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. For example, we may use third parties such as (but not limited to) Experian, Equifax, TransUnion, Crediva, Lexis Nexis, Identec, or GBG.
  • In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as details of your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you (if applicable). You have the right to withdraw consent to marketing at any time by contacting us.

10. Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below


To register you as a new customer of an Everflow company for any of our Services

Type of Data

  1. Identity
  2. Contact

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests
  2. Performance of a contract with you


To process and deliver our Services, including:

  1. Manage payments, fees and charges
  2. Collect and recover money owed to us

Type of Data

  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests (to recover debts due to us)
  2. Performance of a contract with you


To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey

Type of Data

  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications

Lawful Basis for Processing, Including Basis Of

  1. Performance of a contract with you
  2. Compliance with a legal obligation
  3. Legitimate interests (To keep our records updated and to study how customers use our Services)


To enable you to partake in a prize draw, competition or complete a survey (if any)

Type of Data

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications

Lawful Basis for Processing, Including Basis Of

  1. Performance of a contract with you
  2. Legitimate interests (To study how customers use our Services, to develop them and grow our business)


To administer and protect our business and this website (Including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data

  1. Identity
  2. Contact
  3. Technical

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests (For running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Compliance with a legal obligation


To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of Data

  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests (To study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)


To use data analytics to improve our website, Service, marketing, customer relationships and experiences

Type of Data

  1. Technical
  2. Usage

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)


To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data

  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile

Lawful Basis for Processing, Including Basis Of

  1. Legitimate interests (To develop our Services and grow our business)

11. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

12. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased a Service from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.


13. Third-Party Data Processors

We will get your express opt-in consent before we share your personal data with any company outside the Everflow Limited's group of companies for marketing purposes. To enhance our services and provide you with a better experience, we engage with trusted third-party service providers who assist us in various aspects of our business operations. Two such partners we utilize are Lead Forensics and Aquirz.

Lead Forensics:

We utilise Lead Forensics to gather data regarding visitor activity on our website. Lead Forensics is a tool that provides us with information about the businesses that visit our site, including but not limited to, their IP addresses, company names, and website usage. This data helps us understand the needs and interests of our website visitors, allowing us to improve our services and tailor our marketing efforts accordingly. Please note that Lead Forensics does not provide us with any personally identifiable information about individual visitors unless they have voluntarily provided such information through other means.


Aquirz is an email lead generation partner that we engage with through our service provider Everflow. Aquirz helps us collect and analyze data related to email marketing campaigns, including but not limited to, email opens, clicks, and conversions. By working with Aquirz, we aim to improve the effectiveness and relevance of our email communications to better serve our subscribers and customers. Please be assured that any data shared with Aquirz is handled in accordance with our privacy policy and applicable data protection laws.

We ensure that these third-party partners adhere to the same strict privacy standards and obligations that we uphold. They are contractually bound to only process your data in accordance with our instructions and for the purposes outlined in this privacy notice. Additionally, they are required to implement appropriate security measures to protect your personal data.

14. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website (if applicable) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a Service purchase, Service experience or other transaction. Please allow 6 up to weeks for the cessation of this activity from the date that you opt out.

15. Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

16. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External third parties

  • Such as service providers acting as processors based in the UK who provide:
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; for example finance partners, warranty providers, and utility, interior or maintenance suppliers;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you; and
  • HM Revenue & Customs, The Environment Agency and Ofwat regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

17. International transfers

We do not transfer your personal data or account data outside of the EU.

If you contact us through our webchat service, your chat and session data will be routed outside of the UK in accordance with our 3rd party provider.  This data is temporarily retained outside the UK for no longer than 72 hours, and is returned and stored in full back in the UK, this data will not be passed on to any other party.  More details about data processing for this service can be found at  https://www.livechat.com/legal/data-processing-addendum/#4-sub-processors

18. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

19. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will, for example, keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested from us at any time by contacting us.

Please contact us by email at customer.services@everflowutilities.com or by telephone on 0330 6600 137.

20. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us via either of the following contact:

customer.services@everflowutilities.com or by telephone on 0330 6600 137.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.




Notice of processing of personal data – non-household retail water market privacy notice


Who processes your personal data?

 Your personal data will be processed by the listed organisations defined as follows:

 Trading Parties, which are the wholesalers and retailers providing water and sewerage services.

 Market Operator Services Limited, a company incorporated in England and Wales under company number 09276929 whose registered office is at White Building, 1-4 Cumberland Place, Southampton, England, SO15 2NP ("MOSL”). MOSL is owned by all the water companies, both wholesalers and retailers, who trade in the competitive market. You can contact MOSL using the details set out in section 'Contact and Complaints' below.

 CGI IT UK Limited, a company incorporated in England and Wales under company number 947968 whose registered office is at 14th Floor, 20 Fenchurch Street, London, EC3M 3BY ("CGI"). CGI is acting in the capacity as a 'processor’ and will comply with MOSL’s instructions.

 Third Party data processors, these being other organisations that process data on behalf of MOSL or the Trading Parties, or with whom data is shared, as outlined in section 8 of this privacy notice.

Scope of this notice and definitions

Market Personal Data is personal data collected by Trading Parties and MOSL, for the purposes of providing the services and fulfilling our obligations under the Market Codes, which is stored in the MO Systems and/or shared between parties in accordance with the Market Codes. This does not include any personal data a Trading Party may collect for purposes outside of this scope, such as for their own marketing. For this please see the individual Trading Parties’ privacy notice. Personal data is that

relating to ‘an identified or identifiable living individual’. As such, much of the market data is not personal data, as defined under Data Protection Legislation.

We may process personal data about non-household water customers (“NHH customers”) where these are sole traders or unincorporated partnerships, or relating to the individual employees of NHH customers, as well as the personal data of developers, and the representatives and employees of Trading Parties registered, or which may become registered, to eligible water and sewerage supply points in the non-household retail water market (as defined in the Water Act 2014 and Market codes).

MO System(s) is the central Market operating system, such as settlement, myMOSL, supplier point and the bilaterals market hub, where Market personal data is processed and stored, in addition to Trading Parties’ own systems. Elements of the MO System are maintained and supported by CGI IT UK Limited.

 Data Protection Legislation is the UK-GDPR, the Data Protection Act 2018, and any other relevant UK legislation.

References to ‘we’, ‘us’ or ‘our’ refer both to Trading Parties in the Market and MOSL.

This Privacy Notice is the general Market Privacy Notice (as prescribed in the Market Arrangements Code) which relates to all Trading Parties and MOSL, in their use of Market Personal Data. However, each Trading Party also maintains its own privacy notice, that relates to their specific processing and aligns to this Privacy Notice, which can be found on their website or by contacting your retailer or wholesaler. In addition, MOSL, as the market operator, also maintains its own Privacy Notice, which relates to its processing of personal data related to Trading Parties. The Market Operator Privacy Notice for Trading Parties can be found here.

This notice applies to the treatment of any information that could be used to identify an individual and which is collected by MOSL or the Trading Parties, via direct interactions with you and including through their use of the MO Systems and the MO Systems helpdesk. The protection of personal data is very important to us, and we understand our responsibilities to handle personal data with care, to keep it secure and to comply with legal requirements.

This notice is not intended to override the terms of any contract that NHH customers have with any Trading Party (or any rights they might have available under applicable data protection laws).

MOSL may make changes to this notice from time to time, for example to keep it up to date or to comply with legal requirements or changes in the way MOSL, or Trading Parties operate our businesses. MOSL will notify Trading Parties about significant changes in accordance with our obligations set out in the Market Codes and keep NHH customers and other relevant data subjects informed of changes by prominently posting a notice on MOSL’s website (https://www.mosl.co.uk/info/gdpr).

We encourage you to regularly check back and review this notice so that you will always know what information we collect, how we use it, and who we share it with. We will review this notice at least annually.

What personal data do we collect?

 The personal data we process for the provision of water and sewerage services, including, as applicable, for managing NHH customer accounts, and the general operation of the Market in compliance with the Market Codes (including via MO Systems, and the MO Systems Helpdesk), includes the following:

  • contact and communication details, including full names, email address, address, telephone number, job title, the organisation/business that a person works for, log-in details, records of any communications whether written or spoken; and
  • billing information, including billing contact, email address, billing address, contact number and information relating to credit ratings or credit scores; and
  • account details and supply point details, including customer classifications including unique identifiers, meter information or Market consumption data.

The information we hold is described in detail in the Market data catalogue (Code Subsidiary Document 0301) and the Bilateral Data Catalogue (Code Subsidiary Document 0601).

We comply with the data minimisation principles of data protection laws and we will not collect any personal data that we do not need in order to provide the Market services, including updating the MO Systems and using the MO Systems helpdesk

Special categories of personal data

We do not typically collect any special categories of personal data, such as details relating to health, in the general course of providing services in connection with the Market, unless essential and only when we have an appropriate legal basis to do so. Occasionally, we may hold information indicating that, due to their health needs, a NHH customer is a priority for re-connection if there is an interruption to the water supply.

When do we collect your personal data?

Trading Parties will collect information from NHH Customers via direct interactions with you, including correspondence such as telephone calls, emails, webforms or letters. Market Personal Data is stored in the MO Systems where it can be shared by Trading Parties and MOSL, and Trading Parties may also collect information which is stored in accordance with their own privacy notices. To the extent permitted by law, we may also monitor and record telephone calls for training and quality assurance purposes.

MOSL may also collect information about NHH customers indirectly from other sources, for example public registers, where we believe this is necessary to help ensure the security of the MO Systems and the MO Systems helpdesk.

What purposes do we use your data for?

We process contact and communication, account/billing and supply point details in order to:

  • to provide new and ongoing water and sewerage services, such as meter reading or repairs;
  • to administer the billing and provision of these services, including switching retailers and the provision of billing contact information to MOSL in case of a retailer failure; and
  • to comply with the requirements of the Market Arrangements Code or the Wholesale-Retail Code, to which we are a party and any additional regulatory requirements of regulators (such as Ofwat) to which we are subject.

We have to establish a lawful basis to use personal data, so we will make sure that we only use personal data for the purposes set out above, where we are satisfied that:

  • our use of personal data is necessary to perform a contract with that individual or take steps to enter into a contract with that individual;
  • our use of personal data is necessary to support ‘Legitimate Interests’ that we, as a Trading Party or MOSL, which is responsible for the provision of water and sewerage services and the general operation of the Market, are required under the Market codes and our licence to undertake, including the billing and administration of these. For MOSL, as market operator of the water retail market, this may include:
    • to help delivery and performance of the services provided by Trading Parties to NHH customers who are part of the water retail market in accordance with our obligations under the Market codes;
    • to improve our service;
    • to provide help or support in connection with the MO Systems and the MO Systems helpdesk;
    • to ensure that they operate efficiently and securely; and
    • to carry out analytics across our datasets, including to enrich, improve or can further insight into such datasets;

      where that this is not outweighed by the rights of the individual;

  • our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we are subject to (e.g. to comply with Ofwat, Defra or the Information Commissioner’s Office (“ICO”) requirements);
  • before collecting and/or using any special categories of personal data we will establish an additional lawful basis to those set out above which will allow us to use that information. This additional exemption will typically be:
    • for the establishment, exercise or defence by us or third parties of legal claims; or
    • where there is a specific exemption provided under Data Protection Legislation, such as substantial public interest; or
    • where we have explicit consent from a data subject, although Trading Parties will typically rely on the other lawful bases.


We will not usually rely on consent as a lawful basis, however, where we do rely on consent as a lawful basis for processing personal data, NHH customers may withdraw their consent to such processing at any time. In this instance, Trading Parties will also make NHH customers aware that if they choose to do so, we may be unable to continue to provide certain services to you. If they choose to withdraw their consent, we will tell you more about the possible consequences. The withdrawal of their consent in this circumstance shall not affect the lawfulness of the processing based on consent before the withdrawal. Withdrawal of consent will not necessarily result in processing being stopped where consent was not the lawful basis for the processing.


Who is your personal data shared with?

We will share personal data with third parties, to help manage our business and deliver services, as outlined below:

  • service providers who help manage our IT and back office systems, including, but not limited to, CGI;
  • third Party data processors outside the EEA for providing back-office support services; 
  • other Trading Parties and MOSL;
    • our regulators, including Ofwat, government departments, such as the Environment Agency, the Drinking Water Inspectorate and Natural Resources Wales, as well as law enforcement agencies in the United Kingdom and EU where applicable, to enable the operation of the competitive retail market;
  • solicitors and other professional services firms (including our auditors);
    • service providers who enable us to communicate important information regarding the services across the non-household water retail market;
    • third parties, such as brokers, for the purposes of their providing services to you for switching purposes;
    • other third parties, where authorised by law, such for the prevention of fraud, or with law enforcement or taxation authorities.
  • the Consumer Council for Water (CCWater);
    • Third party data processors, such as consultancies, technology companies, and other data providers who can provide analytics and data enrichment across our datasets; and
  • where it forms part of an audit trail on system use; and
    • so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings.

      Where your personal data is no longer required, we will ensure it is securely deleted in a way which means it will no longer be used by the business.

Where is your personal data stored?

All the personal data we process is processed by our staff, and/or by selected third party service providers, such as for the provision of IT services. As such it will be stored on our systems (including the MO Systems), and in some cases at our premises, including those of our third-party service/data providers. Personal data may be stored using cloud based services.

We take all reasonable steps to ensure that personal data is processed securely. Where data is shared with third parties a data processing or data sharing agreement will be agreed between us and the third party.

We will not share personal data outside the EEA unless (a) it is a transfer to a country or organisation which is recognised by Data Protection Legislation as providing an adequate level of legal protection for your information, or (b) we have put in place appropriate contractual arrangements with the organisation with

whom we are sharing your information on terms recognised under Data Protection Legislation as offering an adequate level of protection for your information. In those cases, you will have the right to ask us for more information about the safeguards we have put in place as mentioned above (e.g. to request a copy where the safeguard is documented, which may be redacted to ensure confidentiality).

How long do we keep it?

We will retain Market Personal Data in line with our data retention policy, and for no longer than is necessary for the purposes listed in this notice or as otherwise stated in the relevant Trading Party’s privacy notice.

In some circumstances we may retain personal data for longer periods of time where we are required to do so to meet legal, regulatory, tax or accounting requirements, in particular:

What are your rights?

Individuals have a number of rights in relation to their Market Personal Data. In summary, they have the right to request access to their data, rectification of any mistakes in our files, erasure of records where no longer required, restriction on the processing of their data, objection to the processing of their data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. They also have the right to complain to their supervisory authority (further details of which are set out section 'Contact and Complaints'). These are defined in more detail as follows:


Individuals also have various rights in relation to any automated decision making and profiling, however we do not carry out these activities in connection with the MO Systems.

In relation to Market Personal Data, these rights can be exercised by contacting us as set out below, and MOSL will coordinate with your retailer and wholesaler, as required. Alternatively, you may also wish to contact your retailer or wholesaler directly. Please note the following if you do wish to exercise these rights:

  • Identity. We take the confidentiality of all records containing personal data seriously and reserve the right to ask you for proof of your identity if you make a request;
  • Fees. We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount in the circumstances;
  • Timescales. We aim to respond to any valid requests as soon as possible after receipt and within one calendar month. If we need longer to respond to your request, we will notify of you of this within a month of your request, explaining the reasons for the delay. We will not extend the timeframe for our response for any more than an additional two months. We might ask you if you can help by telling us what exactly you want to receive or are concerned about. This will help us to action your request more quickly;
  • Exemptions. Local laws, including in the United Kingdom, provide for additional exemptions, in particular to the right of access, whereby personal data can be withheld from you in certain circumstances, for example, where it is subject to legal privilege.


Contact and complaints

 The primary point of contact for all queries arising from this notice, including exercising data subject rights, is MOSL’s Data Protection Officer. The Data Protection Officer can be contacted in the following ways:

Email: dataprotection@mosl.co.uk


FAO Data Protection Officer, Market Operator Services Limited, 4th floor,

White Building,

1 - 4 Cumberland Place, Southampton,

SO15 2NP

If you have a complaint or concern about how we use your Market Personal Data, please contact MOSL, or your retailer or wholesaler as applicable, in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time. In the UK, the supervisory authority for data protection is the ICO (http://ico.org.uk/). We do ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time