Access For All Privacy Policy

Energy Ombudsman takes your privacy seriously. We know that there is a lot of information so use the quick links to read different sections of our policy.

Energy Ombudsman Limited is the controller responsible for your personal data. We are an independent organisation that helps consumers and energy suppliers resolve disputes. As explained by British Gas Trading Limited, we have launched the “Access For All” project (“AFA Pilot”) which aims to make it easier for consumers to reach out to us so we can support individual energy consumers and for us to gain insight into, and or improve, the process involved in consumer access to the services provided by us. British Gas Trading will share your complaint and account information (including personal data) with us for the purposes of the AFA Pilot (including opening a case file for you).

This privacy notice provides information on how we collect and process your personal data for the purposes of the AFA Pilot only.

Our website privacy policy contains more detailed information about our data processing (including about data security, data retention and lawful processing bases) and you should read that in conjunction with this privacy notice. See Privacy Policy | Energy Ombudsman. Alternatively, if you do not have access to the internet, you can ask us to send you a hard copy by contacting the Data Protection Officer below.

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data includes first name, last name, username or similar identifier (e.g. complaint reference), title, deceased or living status.

• Contact Data includes postal address, email address and telephone numbers.

• Account Data includes energy supplier, service type, data cut date, consumer type, complaint date, account number.

• Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access the AFA portal.

• Profile Data includes your username, your preferences, feedback responses.

• Usage Data includes information about how you interact with and use the AFA Portal and services (including website and app traffic data (for example user and session statistics, device and browser information, and user location)).

• Communications Data includes your communication preferences.

We use different methods to collect data about you, which are explained in our website privacy policy Privacy Policy | Energy Ombudsman. Specifically in relation to the AFA Pilot:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services by the submission of your case;

• create an account; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with the AFA Portal for the purposes of the AFA Pilot, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy Cookie settings | Energy Ombudsman for further details

Third parties. We will receive personal data about you from various third parties as set out below:

• Technical Data is collected from analytics providers such as Google, which may be based outside the United Kingdom;

• Identity, Contact and Account Data is collected from energy suppliers such as British Gas Trading Limited based inside the United Kingdom.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with the AFA Portal and services to help improve the AFA Portal and our service offering.

We will only use your personal data for the purpose for which we collected it, which includes to register your complaint as a case with us, to manage your relationship with us, to improve the AFA Portal, our services and or consumer relationships.

The law requires us to have a legal basis for collecting and using your personal data. For the purposes of the AFA Pilot, we rely on one or more of the following legal bases:

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).

• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Purpose/Use	Type of data	Legal basis and retention period
To pre-populate a case file prior to full submission	(a) Identity (b) Contact (c) Account	Necessary for our legitimate interests [in the AFA Pilot] We will retain this data for a period of 30 days where the relevant consumer does not submit the case.
To register you as a new consumer	(a) Identity (b) Contact (c) Account	Necessary for our legitimate interests in providing dispute resolution services and based on consumer consent to engage with the Energy Ombudsman service We will retain this data for a period of 6 years.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Account (d) Profile	(a) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) We will retain this data for a period of 6 years.
To administer and protect our organisation and the AFA Portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Account (d) Technical	(a) Necessary for our 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) (b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we provide to you	(a) Identity (b) Contact (c) Account (d) Profile (e) Usage (f) Communications (g) Technical	Necessary for our legitimate interests (to study how consumers use our services and to develop them)
To use data analytics to improve the AFA Portal, services, consumer relationships and experiences and to measure the effectiveness of our communications	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of consumers for our services, to keep the AFA Portal updated and relevant, to develop our business and to inform our future commercial strategy)

Where not specified above, we apply the following retention periods to your personal data:

Website information Internal domain IP address Browser software Date and time accessed site Further website info	6 months
Telephone recordings	12 months
Social media contacts	6 months (or longer if relevant to a complaint – see below)
Paper documents, disks or USBs	One month unless explicitly requested to be returned during this time. Please note that we may retain such materials for longer if they are not readable in a digital format.
Complaint file	6 years
Unsubmitted complaint file	2 years
Survey	All our survey results are anonymised.
Unsuccessful candidates for job applications	12 months

We will only use your personal data for the purpose for which we collected it, which includes the following:

• To register you as a new consumer.

• To process your case.

• To manage your relationship with us.

• To enable you to complete a survey.

• To improve the AFA Portal, services or consumer relationships.

• To recommend services which may be of interest to you.

We may share your personal data within the Trust Alliance Group (including group companies) and with external third parties, including:

Service providers acting as processors or controllers (based in the United Kingdom) who provide IT, technical, data and system administration services (including TAG Support Services Limited (based in the United Kingdom) and Lumin Tech Limited (based in the United Kingdom).

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

More detail can be found in our website privacy policy Privacy Policy | Energy Ombudsman

For the purposes of the AFA Pilot, we do not transfer your personal data outside the United Kingdom except where we work with Google for analytics services. In such circumstances, we may transfer, store and process your personal data outside the United Kingdom subject always to an appropriate safeguard or contract being in place (to the extent any Google operations are outside the EEA). More detail can be found in our website privacy policy Privacy Policy | Energy Ombudsman.

You have a number of 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 "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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Privacy Policy | Energy Ombudsman for details of how to object to receiving direct marketing communications).

• 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 (see above for details of when we rely on your consent as the legal basis for using your 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.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

1. If you want us to establish the data's accuracy;

• Where our use of the data is unlawful, but you do not want us to erase it;

1. 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

• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact our data protection officer (DPO) using the details below.

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 could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

We have appointed a data protection officer. If you have any questions about this privacy notice or our data protection practices, please contact the Data Protection Officer. Our contact details are Data Protection Officer at DPO@energyombudsman.org or Data Protection Officer, 3300 Daresbury Park, Daresbury, WA4 4HS.

We keep this privacy policy under regular review.

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, for example a new address or email address