Our Power Privacy Notice
Our Power respects your privacy and is committed to protecting your personal data.
This Privacy Notice informs you about how we use and look after your personal data, including any data you may provide through our website, when you request information about our products or services, when you communicate with us, when we provide products and services to you, and when personal data is provided to us in relation to our business.
This Notice also informs you about your rights and how the law protects you.
This Notice applies to customers, prospective customers and previous customers.
Who is Our Power?
‘Our Power’ is a group of companies that is organised under the Holding Company that is called ‘Our Power Community Benefit Society Limited’.
For the purposes of this Notice ‘Our Power’ means the Holding Company and:
• Our Power Energy Supply Limited
We may update this list as our group of companies changes.
You may contact any Our Power company in the following ways:
• By writing to us at 4 Hay Avenue, Edinburgh, EH16 4AQ
• By calling us on 0808 168 4534
• By emailing us at email@example.com
For questions about data protection issues, please address all correspondence to the Data Protection Coordinator.
What is Personal Data?
Personal data is data that relates to an identifiable living individual.
The personal data we collect regarding you can include your name, address, email address and telephone number. It can also include data such as IP addresses of computers you use, and also data about the amount of energy you consume as recorded by your electricity and gas meters.
Your personal data can also be the data that is not immediately obvious as being personal (such as how much energy you use) but may become personal data when processed alongside other data (such as your energy consumption being linked to your meter number which in turn can be linked to your address).
How is my personal data protected in law?
The General Data Protection Regulation (GDPR) is an EU regulation that took effect on 25 May 2018.
The GDPR makes it clear that personal data belongs to the individual and whilst we need to collect personal data about you to provide you with a service and for other reasons, it remains your data and we must handle it with care. We adhere to the principles relating to processing of personal data set out in the GDPR which require personal data to be:
1. Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
2. Collected only for specified, explicit and legitimate purposes (The Purpose Limitation).
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (Data Minimisation).
4. Accurate and where necessary kept up to date (Accuracy).
5. Not kept in a form which permits identification of Data Subjects (you) for longer than is necessary for the purposes for which the data is processed (Storage Limitation).
6. Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).
7. Not transferred to another country without appropriate safeguards being in place (The Transfer Limitation).
8. Made available to Data Subjects when requested, and in certain circumstances to have that data rectified, blocked, erased or destroyed and data subjects allowed to exercise certain rights in relation to (The Data Subject's Rights).
We are responsible for and must be able to demonstrate that we comply with the data protection principles listed above.
There are a limited number of specific legal reasons we can process your personal data. They are laid out in The GDPR and each one is called a ‘Lawful Basis’. We must tell you which lawful basis we are using to process your data in each instance.
There are six (6) Lawful Bases defined in The GDPR. They are:
• Consent – this is where you consent to us using your data. You do not have to give it, and if you do give it you can withdraw it at any point in the future.
• Contract – this is where there is a contract between us and we need to have certain personal data from you to carry out that contract, for example the contract between you and us for the supply of energy.
• Legal Obligation – this is where we are required by other laws and regulations to collect and process certain personal data about you.
• Vital Interests – this is where it is necessary to process personal data for the protection of somebody’s life.
• Public Task – this is where processing of personal data is required for the general public interest.
• Legitimate Interests – this is where we have a genuine commercial reason to process your personal data in a certain way that you might reasonably expect us to do because of the business we are in, for example to inform you of new services that we provide that might be of benefit to you.
The Lawful Bases we rely upon to process your personal data depend on what data it is and for what purpose we are processing it for. We describe this in the section ‘How we process your personal data’.
Data we collect about you
Personal data we collect and process about you may include:
• Name • Date of Birth
• Phone Numbers
• Email addresses
• Electricity and Gas meter serial numbers
• Electricity and Gas meter MPAN numbers
• Electricity and Gas consumption and generation data
• Recorded phone calls
• Bank sort code and account numbers
• Details of any special requirements, vulnerabilities, illnesses, infirmities, financial or social difficulties
We may add to this list in the future, and if we do this page will be amended.
How we collect your personal data
You may give us your personal data by filling in forms on our website or by phone, e-mail, in person or in any other way. This includes the data you provide when you register to use our website, sign up to our services, search for a product, obtain a quotation, place an order with us, participate in discussion boards or other social media functions on our website or other social media websites or apps, enter a competition, promotion or survey, and/or when you report a problem with our site or our services or our other interaction with you.
We may also gather your personal data from various sources as well as directly from you, including your landlord, our partners, and other organisations involved in your energy service such as network operators or community organisations, or from publicly available information sources. We may match it with the personal data we already have.
We may also receive your personal data from an energy supplier from which you wish to move in order to help ensure the move happens smoothly.
We will never collect any unnecessary personal data regarding you and do not process your information in any way, other than as specified in this notice
How we process your personal data
We process personal data for the following purposes:
• To register you as a customer
• To manage your account
• To manage our relationship with you
• To record meter readings and consumption data
• To provide you with bills and statements that are additional to those we must supply by law
• To send you communications as agreed in our contract with you, such as changes to our terms and conditions, notification of price changes and tariff information
• To enable you to access any self service online or app based portal that we may offer or require you to use as part of our contract with you
• To collect payments from you for energy consumed
• To make appointments to read, check, repair or install your meter(s)
• To keep a historic record of our correspondence with you and your account conduct to help resolve disputes with you
• To provide you with bills and statements for your account
• To keep you informed of any changes to this Privacy Notice or any other information we may are required to tell you under law
• To ensure that you can exercise your rights under law when dealing with us
• To identify that you are who you claim to be (the account holder, for example) so that we can protect your personal data, and to meet other legal obligations such as those to prevent fraud and money laundering
• To monitor all account and correspondence activity and cross reference it with any other data we hold in order to detect, prevent and address fraud or energy theft
• To comply with regulatory and legal obligations that we are subject to and to cooperate with regulators and law enforcement bodies
• To comply with orders given by a court or other competent authority in Scotland, England or Wales, or elsewhere
• To analyse consumption data to ensure that when we are required we can tell you about relevant tariffs or products that may suit you now or in the future
• To notify you of products or services available where it is not discretionary but where we are required by law or regulation to do so; for example towards the end of a fixed tariff
• To inform you of new services that we provide that might be of benefit to you, based upon your interaction and arrangements with us.
• By recording telephone calls with us, so that we can continually monitor our service levels and standards and resolve any disputes as they may arise
• To process your meter data, supply location, demographics and building data to analyse trends, anomalies and correlations in order to develop new products and services
• To personalise our service for you
• To respond to enquires, requests for quotes to provide energy and other communications we may receive from you
• To ask you to participate in, and to enable your participation in, any pilots or trials we may run to test new technologies, products or services
• To use data analytics to improve our website, products or services, marketing customer relationships and experiences
• To undertake checks for the purposes of security and preventing fraud
• To use your account as a case study, only ever internally, as part of the ongoing training and development of our staff to help us maintain high standards
• To help us in any legal action we may take against you, or anyone who may have committed any crime against you Vital Interests
• Even if you are not registered on our Priority Services Register and we have reason to believe that you or others may be put at risk through the normal actions or undertakings of ourselves, any of our agents or other parties that operate or impact upon the energy supply infrastructure then we may process and/or share the minimum amount of your personal data necessary to manage the perceived risk and keep you and others safe.
• For marketing purposes where we contact you to let you know about services or products that you might be interested in, that are not related to the services that you receive.
• To contact you with newsletters, updates and announcements not related to your services, where we are not legally required to do so.
• To ask you to participate in surveys, offers or other such similar activities
• For collecting and processing any sensitive personal data that may fall into the GDPR definition of ‘special category data’, such as data about any vulnerability, infirmity, health issue, financial hardship, or social difficulties, where this doesn't form part of the data that we collect under contract, and is required pursuant to our legitimate interests, for example.
• To allow us to talk to another party on your behalf where they are giving you assistance to manage your account with us.
As noted above we use some data on the basis of your consent.
If you give us your consent to do this then we will also ask you how you would like to be contacted by us for these purposes, whether by phone, e-mail, letter or some other means.
If you give us your consent then it is your right to change your mind and withdraw your consent at any time.
Please note, though, there are times when we are legally required by our regulator to let you know about your choices in relation to what you buy from us and so we do this whether we have your consent or not. We will get your express consent before we share your personal data with any company outside Our Power for their marketing purposes.
We use various Social Media platforms to help us engage with the public, customers and prospective customers. It is part of our marketing activities as well as part of our wider engagement programme, enabling us to understand customer satisfaction and deliver customer care, and also provide other outreach activities.
We may use tools based on personal data legitimately collected by Social Media companies to reach prospective customers whom we wish to advertise to. This does not require us to identify a lawful basis like some other marketing activities we may undertake as we are not processing personal data that you have shared with us to carry it out. But please be careful to check the terms and conditions of those platforms, and manner in which those platforms use, personal data. We do not have any control over how Social Media companies use the personal data you share with them.
We will not share any individual’s personal data on any social media platform and any individual’s personal data we receive via a social media platform we shall treat in accordance with this privacy notice.
Sharing your Data
To be able to deliver our services to you, we hold contracts with various third parties to perform certain tasks on our behalf. For example: companies who may come and read your meter, or who might visit you to install or repair your meter. This is normal in the Energy Industry.
To ensure that we can deliver a full and high quality service to you we must share some personal data with these persons, when necessary.
We will always make sure that the personal data we share with them is only the minimum they need to ensure they can do their job, and we require them to treat your personal data as carefully as we do.
They are only allowed to process your personal data for specific purposes and in accordance with our instructions to them.
We have Data Sharing Agreements in place with such third parties. We keep their activities under regular review.
Third parties we might share your personal data with are:
• Agents appointed by us to implement our contract with you, such as Meter Operators
• Network operators, so they can keep you informed about reconnecting your energy if there's a loss of supply or an emergency
• Organisations that supervise or distribute data between smart meters, energy suppliers and other organisations that enable suppliers like us to bill customers for energy used and which help customers to switch between suppliers
• Other energy suppliers, landlords, housing associations or the Theft Risk Assessment Service if we or another organisation suspects you or the property is connected with fraud
• Another supplier you want to switch to
• Other people, such as members of your household, where you have authorised us to, or where they are named on your account
• Debt collection agencies and other organisations involved with debt collection (for example, bailiffs, law courts, private investigators)
• Organisations doing research for us, in which instances only anonymised data will be shared
• Regulators such as OFGEM and consumer protection organisations such as the Energy Ombudsman
• Organisations for the detection, investigation and prevention of crime, or for current or future legal action
• Commissioning and installation contractors for installations such as Solar Panels and insulation, where these are to be provided to you
• Financial organisations for purposes such as payment processing, finance plans and refunds
• Energy market administrators i.e. Xoserve and the Meter Point Administration Service, to enable them to manage the energy supply network
• If you apply for Affordable Warmth funder measures, the Energy Saving Trust and Department for Work and Pensions to confirm whether you're entitled to the assistance
• Other FiT licensees if you want to transfer your generation unit(s) under the FiT scheme
• Organisations to which we are by law obliged to provide your information
• 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.
Transferring your personal data
The GDPR allows us to transfer personal data to organisations in countries within the European Economic Area (EEA) as all of those countries are signed up to the same laws and have to have the same controls and safeguards in place to protect your data.
Occasionally we, or a company with which we share your data as described in this Privacy Notice, may need to transfer your personal data to a country outside the EEA, in which case we will only do so (or allow such companies to do so) where the European Commission has declared that the receiving country has an adequate level of protection, or there is a contract in place which includes appropriate data protection clauses requiring that your data is handled to the same standards as we have to uphold.
How long we store your personal data
If you are one of our customers then we will retain your personal data for as long as it is necessary to do so following the end of our relationship with you, which might be after you have switched to another energy supplier and we have issued your final bill.
There may be circumstances when we need to keep it for longer – for if we still need to bring your account up to date with readings, payments or anything else after you have moved to a different supplier - but we will delete it as soon as we've no need to keep it further.
If we hold your personal data for any other reason, we will delete it as soon as we no longer have a valid reason to retain it.
How we protect your personal data
We take your privacy seriously and take reasonable measures and precautions to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.
We have an Information Security Management Policy which is an internal document we use to ensure all parts of our organisation know how to look after your personal data. We also have many other practical measures to protect your information, such as:
• Limiting access to systems to only those staff who need to access the systems
• Providing training for staff to make them aware of how to handle your personal data safely and in accordance with the data protection legislation
• Having clear policies and guidance for staff who take special data out of the building and a clear working at home guidance for all staff to follow
• Encryption of sensitive electronic communications such as e-mails as well as encryption of disks and memory sticks (as well as keeping their use to a minimum). Encryption is a means of ensuring that data can only be accessed by authorised users. This means that the information is hidden, and cannot be read without a password
• Regular testing of our IT equipment and keeping up to date with regular security updates
• When you log in to your online account or ask us for a quote, our pages are secure, which means all the personal details you type in are encrypted before they are sent to us
• When you get in touch with us, we will ask you a number of security questions before we share any personal details, just to check it's you
The GDPR makes it clear that your personal data belongs to you. It is your data and you have specific rights that you can exert over the collection, accuracy, retention and use of it.
Sometimes our rights to process your data may outweigh your right to request that we stop or change how we are processing it.
The specific rights you have under The GDPR are 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that 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.
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular data we hold on you.
We ask that you contact us to update or correct your personal data if it changes or if the personal data we hold about you is inaccurate.
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.
We usually have to respond to legitimate requests within a 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.
Changes to this notice
Our Power encourages you periodically to visit its web site to review this notice and to be informed of how Our Power is protecting your personal data.
Our Power will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law.
When such changes occur, we will revise the date on this notice to reflect the date of publication of the latest version.
This privacy notice forms part of our overall terms and conditions for the supply of services to you. Accordingly, if there are substantial or significant changes to this notice or in how Our Power will use your personal data, we will contact you directly to inform you of those changes, as is provided for within the general terms and conditions.
How to complain
If you have a complaint relating to our use of your personal data, please contact the Data Protection Coordinator any of the ways outlined in the section ‘Who is Our Power?’
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, prefer to deal with your concerns before you approach the ICO so please contact us in the first instance.
Between April 2017 and March 2018, Our Power supplied our customers with 29% deep green electricity. Deep green electricity is electricity we’ve received directly from source, rather than purchasing through the wholesale markets. This electricity was mainly sourced from run of river hydro in Scotland and a wind farm in East Lothian. We also sourced electricity from 2 solar farms in South West England.
A breakdown of the generation is shown below:
Our Power fuel mix
1st April to 31st March 2018 (%)
Run of River Hydro
Our Power sourced the remaining 71% electricity from the wholesale markets. The generation technologies for this electricity were solar, wind and hydro. To reassure you all the generation is renewable, when purchasing this we obtain certificates to verify the source. This has resulted in us being able to supply 100% renewable electricity to our customers. What’s more our Carbon impact is 0g/kWh!
See below to see how this compares to the rest of the UK:
UK fuel mix for comparison
Revised 31 August 2018 (%)
Guaranteed Standards of Performance
To ensure we meet the high standards of service that you expect, we have standards set to us that we must adhere to.
If you believe that your meter is not working correctly we will provide an explanation of the probable cause within 5 working days. Inside of these 5 days, if a visit is required by one of our engineers, we will attend to fix or replace the meter if you are available for an appointment within this period.
Failure to meet these standards we will pay you £30.
Faulty prepayment meter
If you report to us that a prepayment meter is not working correctly, i.e. the meter is not taking the correct amount for debt or the credit you have bought does not transfer to meter, we will send an engineer to your property within 3 hours of notifying us if between 9am and 5pm on a weekday
Failure to meet these standards we will pay you £30.
NB: If you let us know outside of the above time period, the 3 hours to attend your property will begin at the start of the next working day.
Making and keeping appointments
If you request an appointment or we need to visit your home we will offer you morning appointment up until 1pm or afternoon appointment after 12pm.
Failure to meet these standards and we will pay you £30.
If we have disconnected your gas or electric supply to your property due to unpaid gas or electric charges but these have now been paid or an reasonable amount agreed with and any security deposits if requested by us, we can reconnect the relevant supply.
Within 24 hours of the above happening, we will reconnect your gas and/or electric supply to the property. If the events happen outside of working hours, the 24 hour period will begin at the start of the next period of working hours.
Failure to do the above and we will pay you £30.
If we receive a payment to be forwarded onto you the customer, this must be paid to you within 10 working days of us receiving the payment.
Failure to do this and we will pay you £30.
Suppliers Payment Obligations
If we fail to meet any individual standards of performance, we must for each failure, make a payment of £30 to you the customer, within 10 working days. If we fail to make the payment we must for each payment, pay you a further £30 pounds within 10 working days.
This also applies to failure to make the above distributed payments.
Guaranteed standard exemptions
Sometimes things are just out of our control, including:
Customer out when we visit
Customer cancels appointments
Strikes or third party actions outside our control
Priority Services Register (PSR)
We are dedicated to providing extra help to our most vulnerable customers to make managing their account with us that much simpler.
You may be eligible to join our Priority Services Register (PSR) if you, or a member of your household are:
• Over 65 years
• Chronically sick
This confidential service allows us to see which of our customers require specific services to help manage their account and remain on supply.
Once on this register, we can:
• Nominate a friend of family member to act on your behalf
• Arrange for someone to attend your property to read your meters free of charge
• Arrange for your meter to be moved for ease of access, if your meter is in an inaccessible location
• Supply large print or braille correspondence if you have sight problems
• Contact you if we see your supply has gone off and you require a constant supply due to a medical condition - *Please note in order for this service to be applicable you will need to have a smart meter installed within your home*
To find out more about the PSR and how you can be included, please contact one of our team based in Scotland on 0808 168 4534.
Please be aware, your water supplier might also have this type of register. For more information, please contact them directly.
Need more advice?
Action on hearing loss - www.actiononhearingloss.org.uk
Age UK - www.ageuk.org.uk
Scope UK - www.scope.org.uk
Sense – www.sense.org.uk
Citizens Advice - www.citizensadvice.org.uk
Disability Rights UK - disabilityrightsuk.org
The Home Heat Helpline - www.homeheathelpline.org.uk
Back Billing Principle
If your supplier is at fault, it will not seek additional payment for unbilled energy used more than 6 months prior to the error being detected and a corrected bill being issued.
The back-billing principle may not apply if you:
Have been using the gas or electricity supply but have made no attempt to contact the supplier to arrange payment. This includes moving into a property and making no attempt to let a supplier know you are the new tenant or homeowner;
Have wilfully avoided payment;
Have not co-operated with attempts to obtain meter readings or resolve queries requested by the supplier. This includes failing to allow access to the property or failing to respond to requests for meter details or meter readings.
If you are not sure if back-billing would apply in your situation
Energy UK has developed a more detailed list of example scenarios where the back-billing principle may apply as part of its Code of Practice for Accurate Bills. The scenarios are available here: www.energy-uk.org.uk/backbilling.html The Code is regularly reviewed and updates are made to incorporate new scenarios to ensure that consumers are treated fairly.
Which suppliers are members of the Energy UK Code?
Members of the Code include: British Gas (including Scottish Gas), EDF Energy, E.ON, npower and ScottishPower.
What about suppliers who are not members of the Energy UK Code?
Whilst the Energy UK Code does not apply to all suppliers, the back-billing principle applies to all suppliers. Suppliers that are not formal members of the Energy UK Code of Practice for Accurate Bills may use the Code and its scenarios for guidance when deciding whether the back-billing principle should be applied.
What if my supplier isn’t applying the back- billing principle?
If your supplier has said that the back-billing principle or the Energy UK Code does not apply, and you are unhappy with their decision, the next step is to contact your supplier and follow their complaints process. All suppliers have a complaint handling procedure designed to assist their customers.
Need more advice?
Citizens Advice consumer service
If you need independent help and advice about back-billing issues or any other energy issues you can contact the government-funded helpline Citizens Advice consumer service on 08454 040 506 or visit their website: www.adviceguide.org.uk
The Ombudsman Services: Energy
If you are not satisfied with the supplier’s efforts to resolve your complaint after eight weeks, or if the supplier confirms it has reached a final position on your concern, you can ask the Ombudsman Service: Energy to investigate.
The Ombudsman Services: Energy is an independent body which has been set up to resolve disputes between energy companies and their customers. The Ombudsman will consider whether your supplier must take any action to put things right for you. Its decisions are binding on the energy company.
The Ombudsman Services: Energy, PO Box 966, Warrington, WA4 9D
Call - 03304 401 624 or 01925 530 263
Fax - 03304 401 625 or 01925 530 264
Call - 03304 401 600 or 01925 430 886
Email - firstname.lastname@example.org
Website - www.ombudsman-services.org/energy.html
Know your Rights
As a consumer in an ever-changing energy market it’s important to know your rights. Our Power aims to make our service fully transparent so our customers always know what information and free independent advice is available to them. This includes making a complaint, getting advice about the quality of gas and electricity supply, or help and advice if you think you’ll have difficulty paying your energy bills.
Information on energy related issues is also available from Citizens Advice (Scotland) and can be found by viewing CAB-Know-your-rights.pdf.
Warm Home Discount Scheme
Our Power are part of the Warm Home Discount Scheme for the Core Group.
As we aim to eradicate fuel poverty and help make energy prices fairer for everyone, we have opted into the scheme voluntarily before we reached the mandatory 250,000-member threshold. For more information click here.