Privacy Notice
Last updated: 10 February 2024.
1. English Water and Your Personal Data
For English Water’s water infrastructure and related services, the data controller is English Water, which is part of the Vanguard Group.
This Privacy Notice explains how we collect, use, store, and protect your personal data, as well as your statutory rights under data protection law. It describes the processing activities carried out by English Water and any authorised contractors acting on our behalf, the purposes for which those activities are undertaken, and the legal bases relied upon.
This notice applies to personal data we hold about individuals, including homeowners, tenants, landlords, sole traders, partners, company directors, and contacts on business accounts. It does not apply to information relating solely to companies or other legal entities.
We may update this Privacy Notice from time to time to ensure it remains accurate and compliant. Any updates will be published on this page.
You can contact English Water’s Data Protection Officer by writing to:
The Data Protection Officer
English Water
The Mille
1000 Great West Road
London
TW8 9DW
Email: privacy@englishwater.co.uk
2. Personal Data We Process
We may process the following categories of personal data:
- Contact details: Name, postal address, email address, telephone number, and property address.
- Service and job information: Details of enquiries, quotations, services requested, appointment dates, pricing, invoicing, and payment information.
- Audio, video, and written records: Call recordings, site visit notes, photographs, webchat transcripts, and operational records created by our engineers and customer service teams.
- Exercise of statutory rights: Records of any data protection rights you exercise and how we respond.
- Marketing and communications data: Information about how you interact with marketing communications, including opt-in and opt-out preferences.
- Information relating to other Vanguard Group services: Where relevant, details of related services obtained from other Vanguard Group companies.
- Vulnerability information: Information required to identify whether you are in a vulnerable situation or may require additional support, including limited health or disability-related information where necessary.
- Website usage data: Information collected through tools such as Microsoft Clarity and analytics platforms, including pages visited, interactions, clicks, and navigation behaviour.
You are not legally required to provide personal data. However, failure to do so may prevent us from providing certain services.
3. How and Why We Use Your Personal Data
A. Processing Necessary to Perform a Contract
We process personal data where necessary to enter into and fulfil a contract with you, including to:
- Provide water infrastructure and related services
- Arrange site visits and appointments
- Issue quotations and invoices
- Process payments
- Respond to enquiries or complaints
- Provide appropriate support to vulnerable customers
Legal basis: Article 6(1)(b) UK GDPR (contract).
B. Processing Required by Law
We process personal data where required to comply with legal obligations, including:
- Assisting law enforcement agencies and regulators
- Meeting health, safety, and regulatory requirements
- Supporting customers registered on priority or vulnerability schemes
Legal basis: Article 6(1)(c) UK GDPR (legal obligation). Where vulnerability data is processed, this is done in accordance with the Data Protection Act 2018.
C. Processing Based on Legitimate Interests
We process personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights. This includes:
- Improving our services and operational efficiency
- Staff training and quality assurance
- Fraud prevention, misuse investigation, and debt recovery
- Business management and record keeping
- Developing new services and solutions
- Protecting our staff, customers, and property
- Establishing, exercising, or defending legal claims
- Supporting business transfers, mergers, or acquisitions
Legal basis: Article 6(1)(f) UK GDPR (legitimate interests).
D. Processing Based on Consent
Where required, we process personal data based on your consent, including:
- Direct marketing communications
- Certain vulnerability-related support services
You may withdraw your consent at any time.
Legal basis: Article 6(1)(a) UK GDPR (consent).
E. Anonymised and Aggregated Data
We may anonymise and aggregate personal data so it can no longer identify you. This information may be used for analytics, research, system testing, and service improvement.
4. Sources of Personal Data
We collect personal data from:
- You directly (calls, emails, forms, website submissions)
- Our website and analytics tools
- Other Vanguard Group companies
- Lead generation partners (where you have given permission)
- Regulators and ombudsmen
- Social media platforms
- Business customers acting on behalf of end users
5. Data Sharing Within the Vanguard Group
We may share personal data within the Vanguard Group to:
- Provide a consistent and joined-up customer experience
- Improve services and operational processes
- Support product development and marketing insights
6. Who We Share Personal Data With Outside the Vanguard Group
We may share personal data with:
- Authorised contractors and service partners
- IT, hosting, and analytics providers (e.g. website analytics tools)
- Customer feedback and review platforms
- Data and credit reference agencies (where lawful)
- Law enforcement agencies and public authorities
- Professional advisers (legal, financial, or regulatory)
- Potential purchasers or acquirers of part or all of our business
All third parties are required to handle personal data securely and lawfully.
7. Direct Marketing
We may contact you by email, SMS, post, or telephone about services we believe may be relevant to you. We respect your marketing preferences and applicable legal restrictions.
You can opt out of marketing communications at any time by emailing privacy@englishwater.co.uk or using the unsubscribe links provided in our messages.
8. Advertising on Other Websites and Apps
We work with advertising and social media partners to display relevant adverts on third-party websites and platforms. This may involve the use of cookies or similar technologies.
In some cases, we may use hashed or encrypted identifiers (such as a scrambled version of your email address) to ensure adverts are relevant without sharing your actual contact details.
Further information is available in our Cookie Policy.
9. International Transfers of Personal Data
Some service providers may be located outside the UK or European Economic Area. Where personal data is transferred internationally, appropriate safeguards are used, including approved contractual protections, to ensure lawful and secure processing.
10. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes.
11. Your Rights
Under data protection law, you may have the right to:
- Be informed about how your data is used
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion or restriction of processing
- Request data portability
- Object to processing in certain circumstances
- Withdraw consent where processing is based on consent
The availability of these rights depends on the legal basis for processing. We may require proof of identity before responding to requests.
12. Contact and Complaints
If you have any questions, concerns, or requests relating to this Privacy Notice or your personal data, please contact:
Data Protection Officer
English Water
The Mille
1000 Great West Road
London
TW8 9DW
Email: privacy@englishwater.co.uk
If you are dissatisfied with how your personal data is handled, you have the right to complain to the UK Information Commissioner’s Office (ICO). We encourage you to contact us first so we can address your concerns promptly.