Help and Contact
Hafren Dyfrdwy Customer and Visitor Privacy Promise
Last Updated: January 2023 Version: 3.0
We’re making it easier for you to find out how we handle your information
Hafren Dyfrdwy takes the security and use of personal data very seriously and is committed to complying with Data Protection Laws including the Data Protection Act 2018 and UK General Data Protection Regulation. This privacy notice makes it easier for you to find out how we use and protect your information within Hafren Dyfrdwy. The notice provides you with you details such as:
- Your rights in relation to the information we hold about you
- How we keep your personal information secure
- The types of personal information Hafren Dyfrdwy collects about you, and how we collect and use it
- The legal grounds for how we use your information
The Privacy Notice was effective from 25 May 2018, and updated as required, and you can view a copy below. You can ask us to post a copy to you.
We'll keep you up to date
If we make changes to any of these in the future, we’ll update the effective date and where possible notify you via email.
We're here to help
We are Hafren Dyfrdwy Cyfyngedig (referred to as Hafren Dyfrdwy in this notice) and we provide water and waste-water (sewage) services and access to recreational visitor sites in Wales. Hafren Dyfrdwy looks after and is responsible for your data (the Controller). Any reference to “we” or “us” in this notice means Hafren Dyfrdwy.
We use a number of external third parties who process your personal data on our behalf, these companies are referred to as ‘Processors’. Any Processors we use also have their own legal responsibility for handling your data.
If you have any questions, or want more details about how we use your personal information, you can ask us:
Name: Hafren Dyfrdwy Cyfyngedig (Company No: 03527628)
Address: Data Protection Officer, 2 St John’s Street, Coventry, CV1 2LZ
Phone Number: 03457 500 500 (+44 3457 500 500 from outside the UK).
Data Subject Access Requests (DSAR)
We collect the following types of personal data from any contact we have with you by telephone, letter, e-mail, whatsapp, facsimile, when visiting your home, Webchat service, Mobile Application, our Contact Us forms and via social media like Twitter and Facebook or even face to face at one of our sites. The table below shows the categories of personal data we are likely to collect about you.
|Category of personal data||Examples|
Name, Address, Email Address, Telephone Number, Other Contact Information e.g. social media handle (if you are contacting us via social media)
|Transaction Information||Contact information, date of birth, billing details, payment details (for customers paying by credit or debit card, please note we do not store the Credit Verification Value), any communications, complaints, income details, expenditure details, affordability information, credit rating, operational investigations, repairs, interruption to supply, planned maintenance, meter details (including meter
serial numbers and water usage), Vehicle registration for Automatic Number Plate Recognition (ANPR) systems on visitor sites.
|Legal information||Fraud checks or flags raised about your transactions, payment refusals, complaints, CCJs.|
|Preference Information||Your opt out preferences, your account settings including any default preferences, any preferences we have observed,
such as the types of services that interest you, or the areas of our website that you visit.
|Communications||Communications we may have with you, whether relating to a transaction or not. Please note that we record calls to our Contact Centre team.|
Any voluntary information you provide us with, such as responses to customer campaigns and surveys. If you are visiting one of our visitor sites, we may take your photo with your consent to use in our promotional material.
Details of your online browsing activities on our website, such as the pages or areas of our website that you visit, or which link has brought you to our website from our email communications or other websites. This information may be identifiable to you because you are logged in to your account, or because we have collected details of your IP address or the device that you have used to access the website. This will also collect the geographic region which your device reports to us that you are located in.
Consumption information i.e. how much water you use via your water meter and our wider network. We use this information to help us operate our network efficiently, to identify leaks and to potentially offer information and advice to you if you are a high user.
Clearly sign posted Closed Circuit Television CCTV recording if you visit one of our marked sites.
Call recordings to our contact centres.
|Special category information||
Specific medical information in the event of an incident (e.g. if you are on dialysis, haemo-dialysis) to ensure we can offer additional support and provide priority services when you need it. e.g. to ensure continuity of supply.
Any health conditions you may want to inform us of to help us manage your account (e.g. braille bills etc.) or where you suffer financial hardship as a result of an illness.
Some of the information we collect about you may include your special categories of personal data as defined in UK Data Protection law. Please refer to section 3 for more information.
We will only request special categories of personal data from you where we believe it will help us manage your account in the best way for you and to ensure that we can respond to your needs during an incident should one occur. Scenarios in which we may request your special category data are:
- you are unable to pay your bill due to illness to allow us to offer you financial assistance.
- We hold specific information in the event of an incident (e.g. if you are on dialysis, haemo-dialysis) to ensure we can offer additional support and provide services when you need it.
- By registering on our Priority Services Register you are confirming that you have a need for support either during an incident or to help you manage your account. If your data or circumstances change, please contact us. We will contact you and confirm your circumstances for any special category data we hold on you every two years. If you do not respond to our contact, we will assume your details remain unchanged. By registering with us you can be automatically added to the Priority Services Register of your energy network operator and supplier. We may also share your data with DEFRA or other relevant Government organisations for the purposes of incident management. The data we share will only be used to provide you with Priority Services.
- if you participate in customer surveys or research, we may on occasion ask you to voluntarily disclose details of medical conditions or disabilities you may have to ensure our analysis is reflective of all our customers.
- If you believe you have suffered ill health as a result of consuming our water, we will use this data as part of water quality investigations and our reporting obligations to the DWI.
- If you suffer accident or injury at one of our sites, this data may be required for insurance purposes or accident and health reporting.
We will process this data in line with UK GDPR under the lawful basis of ‘public task’ for personal data and necessary for reasons of either for 'employment, social security and social protection’ or ‘Substantial Public Interest’:
- Support for individuals with a particular disability or medical condition
- Safeguarding of economic well-being of certain individuals
- Equality of Treatment
- Insurance claims
- Legal Obligation
- Preventing or detecting unlawful acts
- Protecting the Public
- Regulatory Requirements
You can find more details on special category data transfers here.
We collect your personal data in a number of ways, for example:
- When you register with us and set up an account to receive our services;
- When you contact us through our websites, by telephone, post, email or through any other means;
- When you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- When you enter a competition or promotion;
- When you make payments to us, through this website or otherwise;
- When you set your preferences for receiving marketing communications from us;
- When you use our services;
- We may record calls to our contact centres, and may monitor calls in order to keep a record of the discussion, to provide you with the highest quality of service, for training, to ensure compliance with our policies and procedures, for security purposes and for any lawful purpose. Please note we hold call recordings for a period of 12 months.
- When we collect publicly available information about you.
- if you opt into using your social media credentials (Facebook, Google or Apple) to use with our web self service,personal data, your registration and profile information from your social media account will be shared with us as authorised by your privacy settings. Please note that if you withdraw your consent, we will no longer have access to your social media account but we will retain your account information as required (see section 8 for more detail).
- We may also access or request information about you that is available to us from organisations or third parties such as, credit reference agencies, fraud prevention organisations, land registries, local councils or other Government departments to ensure we can charge you for our services, offer you access to our financial assistance schemes or priority support services during an incident
- When we receive your personal data from third parties, for example Credit Reference Agencies or fraud prevention organisations; and
We use your information in various ways, such as to:
- Provide you with the services provided and deal with any queries or complaints you may raise;
- Administer your account, including;
- Letting you know of any work we may be conducting in your area;
- Seeking your views on any service we’ve provided;
- Dealing with any problems, enquiries, or complaints you may have; and
- Resolving unpaid bills.
- To encourage you to use our services in the best possible way in line with our statutory duties as a water and waste undertaker;
- To inform you about campaigns that you have consented to;
- Let you know about goods or services we feel would be beneficial to you via post;
- Prevent fraud;
- Trace and recover debts;
- Keep our records accurate and up to date;
- Create statistical information, market research, analysis and customer profiling to better manage and run our business; and
- Comply with any legal and regulatory obligations we may have.
The lawful basis for processing your data are included in the table below:
|Lawful basis and purpose||What personal data do we use?|
Complying with legal obligations:
To meet our obligations under:
Water Supply and Sewerage
Services (Customer Service Standards) Regulations 2008
Security and Emergency Measures (Water and Sewerage Undertakers and Water Supply Licensees) Direction 2022 (SEMD)
Data Protection Act 2018
Environmental Information Regulations 2004
Sludge Use in Agriculture Regulations (SUiAR) 1989
Health and Safety at Work etc Act 1974
Our statutory instrument of appointment (licence conditions)
To confirm your identity, to keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws.
To provide information to law enforcement agencies, other authorities or members of the public where we are required to do so by law.
To report key performance information and other data to our regulators (Ofwat, DWI and the EA) in line with our statutory licence conditions and/or the legislation noted above
For our Critical National Infrastructure (CNI) sites, which are vital for the country and daily life, the Centre for the Protection of National Infrastructure (CPNI) and DEFRA stipulate the use of Visual Security Systems.
To help us manage our network to meet customer demand in line with our statutory licence conditions.
To detect leaks on both our assets and homeowners. Where the leak is on your asset we will notify you as required by section 75 of the Water Industry Act 1991.
To manage shareholder transactions.
Legal information, Transaction information,
Our legitimate interests:
To manage customer accounts and our network assets, including keeping customer records, customer care, debt related activity, and other interactions including compensation, for our internal business administration, and to protect customers and our business from fraud to minimise the risk of false details being used, and abuse by fraudsters. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions.
Preference information, Contact Information, Observed Information
|To provide you with operational and service requirements based on health circumstances or financial circumstances, where applicable.||
Contact information, Transaction information,
To manage any customer service surveys
To contact you regarding service related information
To send you direct marketing for water related products and services.
|To provide you with the highest quality of service through the use of call recordings etc. for training purposes, to ensure compliance with our policies and procedures, for security purposes and for any lawful purpose.||Communications, Observed information|
|To promote efficient use of water, encourage customers to dispose of waste appropriately and prevent damage to our network, we may send you information leaflets or emails or make you aware of products that help with this on behalf of our partners, HomeServe, who have been carefully selected to provide access to affinity insurance products for our customers, which can help in the event of water related problems.||Contact information, Preference information|
For performing public functions in the Public Interest for personal data, and necessary for reasons of Substantial Public Interest (SPI) for special categories of data (health data)
To provide you with operational and service requirements based on health circumstances or financial circumstances, where applicable.
To provide you services related information for example: water efficiency information or waste ‘fats, oils and greases’ campaign information in line with our duties as a statutory water and waste undertaker
To help us manage our network efficiently.
Contact information, Voluntary information, Observed Information, Communications, Special category information
Performance of Contract
To provide you with services under contract with you e.g. car park permits and mobility scooters at our visitors sites or any work you ask Hafren Dyfrdwy to undertake on a private asset such as a new connection into our network or a lead pipe replacement
Contact information, Transaction information,
As part of promotional material for our visitor sites we may ask to use your image.
To contact you about specific projects or campaigns that you have consented to e.g. our river pledges campaign.
To use your social media credentials to log into your Web Self Serve account. If you opt into using your social media credentials (Facebook, Google or Apple) to use with our web self service,
Voluntary Information Contact information,
As part of normal operations, we engage third party contractors to provide us with services, for example, if you call us to inform us about a leak or a blocked sewer, we may use contractors to investigate the issue. Where we use third party contactors, we may need to give your personal data to them, for example, to investigate the issue and inform you of the outcome.
We may also share your personal data with other third parties because we are under a legal, statutory or other obligation to do so or because we believe that sharing your personal data will help us to manage your account in the best way possible for you.
We may share your personal data with the following parties:
- our employees, agents and/or professional advisors;
- other companies within the Hafren Dyfrdwy Plc Group, and with successors-in-title to our business;
- other third party contractors who provide services to us which require the processing of personal data;
- third party payment providers who process payments made over our website;
- third party payment companies to help you manage your account.
- relevant authorities and third parties including Department for Food, the Environment and Rural Affairs (Defra), and the Drinking Water Inspectorate (DWI)
- the water industry regulator, Ofwat; as part of our statutory requirements as a water and sewerage undertaker. From time to time, Ofwat, or a third party acting on their behalf, may contact you directly to take part in a customer experience survey, which helps us measure and improve our service to you.
- relevant authorities in order to prevent fraud and other criminal offences;
- social services, charities and other third parties in order help manage your account in the best way for you and help you get any support you might need;
- credit reference agencies (to find out more see section 8 below);
- external agencies like the police, fire service, or local councils in the event of an emergency situation or in preparation for an incident, as noted under the Civil Contingencies Act 2004; and
- carefully selected partners, to introduce you to water related news, goods and services (by post,) that we think you'll find interesting,
- our affinity insurance partner, HomeServe Membership Limited, who have been carefully selected to provide access to affinity insurance products for our customers, which can help in the event of water related problems.
You may be asked if you wish to speak to HomeServe after we have assisted you with a telephone enquiry. If you don't wish to be contacted for this purpose, please let us know by contacting us. If you decide to engage with or purchase a product or service from one of our partners, including HomeServe, the way in which they use your personal data is their responsibility only, and details will be set out in their own privacy notice.
We will only send your data outside of the United Kingdom to:
- Follow your instructions.
- Comply with a legal duty.
- Work with our agents and advisers who we use to help run your accounts and services.
If we do transfer information to our agents or advisers outside of the UK, we will make sure that it is protected in the same way as if it was being used in the UK. We’ll use one of these safeguards:
- Transfer it to an EEA country, which is considered adequate under UK GDPR.
- Transfer it to a non-EEA country with privacy laws that give the same protection as the UK. Learn more on the ICO’s website
- Put in place a contract with appropriate contractual clauses with the recipient that means they must protect it to the same standards as the UK. Read more on the ICO’s website.
Sometimes we will need to share your personal data with third party data processors in countries that are outside of the United Kingdom that do not have an adequacy decision, for example: we have a Third Party supplier that is based in India and South Africa. We put adequate safeguards including appropriate training, regular auditing, security checks and commercial terms in place to ensure that your data receives the same level of protection as if it were being processed inside the UK. More detail about transfers and our processors outside of the UK can be found here.
We will take appropriate technical and organisational measures to prevent unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to personal data:
- All customer personal data is held in secure systems with controlled access and subject to cyber security measures.
- We apply strict physical security at all our sites.
- All employees receive cyber security and data protection training.
- We ensure that the personal information that you provide us via this website is held on secure servers.
- Where we transfer information to third parties to enable them to process it on our behalf, we ensure that the providers meet or exceed the relevant legal or regulatory requirements for transferring data and keeping it secure.
We will keep your personal information for as long as you are a customer of Hafren Dyfrdwy. After you stop being a customer or if you visited one of our sites, we may keep your data for up to 7 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
We may keep your data for longer than 7 years where required for legal or regulatory purposes. We may also keep it for research or statistical purposes e.g. your water consumption to help us manage our network efficiently. If we do, we will make sure that your privacy is protected and only use it for those purposes.
Like many other utilities companies, we share your personal data with, and receive your personal data from, Credit Reference Agencies (CRAs). This helps us maintain up-to-date customer records, prevent fraud and identify customers at risk of falling into debt. This makes it easier for us to find and help customers who need financial assistance. This helps us manage debt levels and, in turn, keep prices lower for all customers. If you pay your bill on time, us sharing your data with the CRAs will also positively impact your credit rating.
We will share your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time.
The CRAs may give this information to other organisations that want to check credit status. If you tell us that you have a spouse or financial associate living at the same property, we will link your records together.
CRAs will also link your records together and these links will remain on your file and theirs until either you or your partner successfully applies for a disassociation with the CRAs to break that link.
You can find out more about the CRAs on their websites, in their Credit Reference Agency Information Notice. This includes details about:
- Who they are
- Their role as fraud prevention agencies
- The data they hold and how they use it
- How they share personal information
- How long they can keep data
- Your data protection rights
Information notices (CRAIN) for the two Credit Reference Agencies we use:
As part of our green recovery efforts to transform our business and the wider water industry, we want to give you the most up to date information about your water usage through the use of smart meters. It will also us to help you use water more efficiently through identifying leaks more quickly and trial new ways of managing peak demand.
We are currently rolling out smart meters on a trial basis incertain geographic areas.. If you apply for a free meter installation or are due to have a meter replaced in one of these areas, a smart meter will be fitted at your home. Your installer will inform you that a smart meter is being installed at your appointment.
What is a ‘smart’ meter?
We use Advanced Metering Infrastructure (AMI) meters, which gives us the ability to collect granular data about your usage without the need to send out a meter reader to your property. Meter reads can be taken on a quarter-hourly basis that are then automatically sent to ourselves once every hour.
What smart meter information do we collect?
- Your meter serial number
- The type of meter you have installed
- Meter readings that will tell us how much water you’ve used.
How often do we take smart meter reads?
Our smart meters take a reading every hour and you can see this usage through the My Smart Tracker web page, which is part of our online ‘My Account’ service. <link>.
What do we use the smart meter readings for?
Every six months we will use your meter readings to bill you for the water you’ve used.
In addition, we will use hourly readings for a number of different activities:
· Spotting leaks – if we notice your consumption is increasing faster than normal it may indicate that there is a problem with your supply. We’ll be able to contact you either through My Smart Tracker or directly to let you know there’s an issue as soon as we spot it.
· Water usage analysis – we will use this information to drive water efficiency projects across our geographical area and help us manage periods of peak demand.
· Compare your property’s water usage with similar properties
What is our legal basis for processing your smart meter data?
To charge you for your water consumption.
To help us manage our network to meet customer water supply demand in line with our statutory licence conditions.
To detect leaks on both our assets and homeowners. Where the leak is detected on your asset we will notify you as required by section 75 of the Water Industry Act 1991.
To keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws.
To report key performance information or other data to our regulators (Ofwat, DWI and the EA) in line with our statutory licence conditions and/or other water industry legislation.
|Legitimate Interests||To manage customer accounts, including keeping customer records, customer care, for our internal business administration and to improve the service we provide to you.|
For performing public functions in the Public Interest i.e. promoting water efficiency in line with our duties as a statutory water and waste undertaker.
To provide you with operational and service requirements based on water usage, health circumstances or financial circumstances, where applicable.
For research and analytics purposes for example using aggregated consumption data to compare your water usage and monitor our network.
To give you access to ‘My Smart Tracker’ web page, which allows you to monitor your hourly water consumption and to proactively send you monthly reports of your usage.
Do you share my smart meter data with anyone?
If you opt in to use our online service, my smart tracker, a third party provider, Advizzo who provides us the web page platform. The personalised water use tracker allows you to:
- See how much water you’re using – monthly, daily and hourly
- Compare your household’s water usage with similar households in your area
- Spot leaks quickly so you can fix them before they become a big problem
- Access to monthly water usage reports and advice to help you save water
We will also use your consumption data to identify a potential problem with your supply such as a leak. As a result, we may ask a third party contractor to visit your property to investigate. Please see section 6 for further detail on who we may share your personal data with.
Who can I contact if I have an issue or want to object to processing?
If you did not wish to receive your monthly consumption report then please call us on 03457 500 500.
You have a choice about how smart meter data is used apart from where we require it to bill you for our services or for any other legal or regulatory purpose. We can access your daily data unless you let us to know that you wish to opt out of this type of processing. You can contact using the details noted in section 13.
Under data protection law, you have rights, which in some circumstances may be subject to exceptions including:
Your right of access - You have the right to ask us for copies of your personal information. You can request a copy of the information we hold about you. There is no charge for this. You can do this via our online form or by completing this Subject access request PDF form (opens in a new window). You can also write to: SAR Officer, Hafren Dyfrdwy, 2 St John’s Street, Coventry, CV1 2LZ
Email us: customerSAR@severntrent.co.uk
Our process of compiling a subject access request does not include a review of any ongoing issues, and does not form part of Hafren Dyfrdwycomplaints process.
Hafren Dyfrdwy Water is not covered by the Freedom of Information Act 2000 however, you can request certain types of information under Environmental Information Regulations 2004. For further details please see our EIR page.
Your right to rectification - You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
Your right to erasure - You can request the deletion or removal of personal data where there is no reason for its continued processing. This right is also known as the “Right to be Forgotten”.
Your right to be informed - You can ask for details of how we process your personal data, as covered by this Privacy Notice
Your right to object to processing - You can request that your personal data is not processed for specific purposes such as direct marketing.
As a statutory undertaker we have a duty to promote efficient use of water and encourage customers to dispose of waste appropriately. We may send you information leaflets or emails or make you aware of products that help with this.
To help us to do this, we may share your information with carefully selected partners who offer services or products that we think you may be interested in.
If you don’t want to receive such offers at all, please let us know – you can email or call us on 03457 500 500 or via post using the contact details in section 13.
Your right to restriction of processing - You can request that no further processing of the personal data we have previously collected occurs.
Your right to data portability - In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.
You are not required to pay any charge for exercising your rights although we reserve the right to charge where UK GDPR allows us to do so. If you make a request, we have one month to respond to you unless an exception under UK GDPR applies.
Please be aware that there may be circumstances when we are unable to complete your request, most likely because we could not provide you with water, waste water or billing services. If this is ever the case, we will inform you of the reason and provide details of how you can register a complaint with the Information Commissioner's Office (please see section 12 below) if you believe we have got this wrong.
Automated decision making and profiling – please note we do not currently conduct any automated decision making, including profiling, as defined by UK Data Protection laws.
For business customers, the market opened on 1 April 2017 for water supplies to business users, enabling businesses to switch providers and is run by Market Operator Services Limited (“MOSL”). In order to facilitate this, we may share details of contacts at our business customers with MOSL and third party service providers where required. Find out more information on MOSL.
In addition to the rights above, non-household customers have the right to ‘data portability’ between retailers.
Your right to data portability - You have the right to request that we transfer your data when you switch retailers.
Data Subject Rights Request (DSRR)
If you are a non-household/business customer, you have the right to request your data through either your wholesaler or retailer. If you wish to make a request to us as your wholesaler then please email WMU@Severntrent.co.uk.
If you have any further questions about the way we manage your data you can email or call us on 03457 500 500.
Please let us know if you are unhappy with how we have used your personal information. You can contact our Data Protection Officer at email@example.com or write at:
2 St John’s Street
If you have any concerns about how we use your information, you can contact us directly using the details above. You can also complain to the ICO if you are still unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk