This policy was last updated on 4th May 2018.
Flow Energy Ltd is owned by Midcounties Co-operative and is committed to ensuring that any information we hold about you is used responsibly and carefully and is held securely. When you visit our website and sign up for gas, electricity or dual fuel we will need to collect information from you so that we:
- understand when you are using your gas and electricity and how you pay for these;
- can provide the services that you have asked for, administer your account and notify you of changes;
- can carry out risk assessments and prevent fraud;
- can offer other products and services that we think might be of interest to you where you give us explicit permission to do so; and
- can help to train our staff.
This document describes how we collect the information, how we store it securely and what we will do with it. We will ask for your permission to send information to you on other products or services that we offer, usually by asking you to tick a box with a number of options. You can always change your mind by reversing this process, changing your preferences via your online account https://my.flowenergy.uk.com/ or by emailing us at: firstname.lastname@example.org and withdrawing your permission.
1. How long we keep it
We will retain data you have provided to us for as long as you are a customer. The time period for which we keep information after that varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Some account information will be held for seven years from the end of your contract with us.
Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which those personal data were collected or for which it is to be further processed.
Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information or for up to 12 months after you leave supply with Flow.
How we use your personal information
We and our agents may use your information to help identify and provide you with the information, products and services you have requested. These can be changed at any time by logging into your on-line account.
- tell you about accounts, services and products from us or our partners;
- contact you about improving the way we operate any accounts, services and products we provide;
- carry out market research, create statistics, test systems, analyse customer information, create profiles and create marketing opportunities;
- help carry out risk assessment, credit referencing, fraud prevention and debt recovery;
- assist us to manage and train our staff and monitor our services; and
- contact you in ways that you have requested, about products and services we and our partners are offering.
We may also monitor and record any communications we have with you, including phone conversations and emails. This is to ensure the quality of service we are providing and that we are meeting our regulatory and legal responsibilities including carrying out our obligations under any contract with you and allowing us to enforce our rights or the rights of any third party in the detection and prevention of fraud.
Where we get your information
We collect the information requested by any of our web forms that you complete together with any comments you send to us. We also use information provided from Price Comparison Websites (PWCs) where you have shown a preference to switch to Flow Energy as your energy provider. We will also collect information about how people use our website. When we contact you, we may use any information we hold about you to do so. We may contact you by email, phone, text message or other forms of electronic communications (such as using smart meters) or by visiting you. If we are contacting you to tell you about any offers, as far as possible, we will do so in line with how you have told us you would prefer to receive marketing information (your recorded marketing preferences). You can ask us not to send you any information on our offers at any time by using your online customer account – My Flow or contacting us and giving us your account details.
Disclosing personal information
We may allow other people and organisations to use information we hold about you. Reasons for this include:
- to provide services you have asked for, which may include providing information to members of your family or household, anyone acting on your behalf or other people who may be interested (such as landlords or letting agents);
- as part of the process of selling all or nearly all our business and assets;
- to help to prevent and detect debt, fraud, or loss;
- if you do not pay your debt, we may transfer your debt to another organisation and give them details about you and that debt;
- if we are required to provide information for legal or regulatory purposes;
- as part of current or future legal action;
- as part of government data-sharing initiatives, for example, those designed to help stop fuel poverty; and/or
- to help manage any bonus or incentive schemes.
Disclosing information outside the EU
Sometimes these organisations or people may be outside the European Economic Area (EEA).
As a rule, transfers of personal data to these countries may take place if these countries are deemed to ensure an adequate level of data protection.
Flow Energy uses contact centres in South Africa and their Data Protection Law is covered by the Protection of Personal Information Act 2013. We also procure some of our software and its development from New Zealand which is covered by the New Zealand Privacy Act 1993. When we, our agents or our service providers do transfer data, we’ll always make sure that these organisations secure your personal information in a correct manner.
Fraud and theft of energy
If we suspect someone has committed fraud or stolen energy by tampering with the meter or diverting the energy supply, we will record these details on your account record and may share this information with Ofgem and other people who are interested (for example other energy suppliers, landlords or housing associations). We may use this information to make decisions about you, your character, how likely we think you are to pay for your gas, electricity (or both) and future energy services. This may include recording sensitive personal information such as criminal offences you have been accused of. Also, if the gas or electricity supply to your property has previously been tampered with or if gas or electricity has been stolen, or we suspect it has been stolen, we may take this into account when we decide what products or services and terms and conditions we can offer you. You agree that we can ask your previous supplier for information that will allow us to take over your supply, such as information about meter readings and equipment or charges you owe your previous supplier. You agree that we can provide information we hold about you (such as information about meter readings, equipment or money you owe us) if you change supplier so they can begin supplying your gas and electricity.
Protecting the vulnerable
Where we believe that you (or a member of your household) need extra care due to factors such as age, health, disability or financial insecurity, we may record this information. We will use this information so that we do not stop your supply.
In this situation, we may share your information with:
- social services, charities, healthcare and other support organisations, when we believe they may be able to help you, or the other members of your household, by making sure there is a gas or electricity supply to your home;
- other energy suppliers if we believe you are considering changing supplier (we assess which customers need extra care and record and share this information in line with the Energy Retail Association ‘safety net procedures’); and
- the relevant gas transporter, metering agents and/or electricity network operator.
We may check your details with one or more credit-reference and fraud-prevention agencies to help us make decisions about your ability to make payments and the goods and services we can offer you. In clause 10 of our standard terms and conditions for supplying gas and/or electricity we have given more detail about how we, the credit-reference and fraud-prevention agencies will use your information.
If you give us information on behalf of someone else, you confirm you have given them the information set out in this document, and that they have given permission for us to use their personal information in the way we have described. If you give us sensitive information about yourself or other people (such as health details and you agree (and confirm) that the person, the information is about has agreed) that we can use this information in the way set out in this document.
You are entitled to have a copy of the information we hold on you and to have any inaccurate information corrected, this is called a Subject Access Request (SAR) Under the GDPR, Flow Energy Ltd must respond to SARs within one month of receipt. We would be able to extend the period of compliance by a further two months where requests are complex or numerous. If this is the case, we will inform you within one month of the receipt of the request and explain why the extension is necessary.
Under the GDPR, a request for personal information is free unless the request is ‘manifestly unfounded or excessive’. Flow Energy Ltd can charge a ‘reasonable fee’ for multiple requests.
For more information about this please contact us at Flow Energy, Felaw Maltings, 48 Felaw Street, Ipswich, IP2 8PN; call us on 0800 092 02 02 or email us at email@example.com .
2. Protecting your information
We have strict security measures to protect personal information. This includes following certain procedures (for example, checking your identity when you phone us or when we contact you and encrypting (encoding) data on our websites).
3. What are your rights?
If at any point you believe the information we process on you is incorrect you can request to see this information and even have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Team who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
The GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
The following link will provide a fuller explanation on your individual rights: –
Our Data Protection Team can be contacted at firstname.lastname@example.org
or please write to us at Flow Energy, Felaw Maltings, 48 Felaw Street, Ipswich, IP2 8PN; call us on 0800 092 02 02.
4. The Internet and Cookies
If you have given us permission to do so, we may occasionally email you about our services and products. When you first give us personal information through our website, we will normally give you the opportunity to say whether you would prefer us not to contact you by email. However, you can always use your online customer account – My Flow or you can send us an email (at the address set out below) at any time if you change your mind.
Please remember that communications over the Internet, such as emails and webmail’s (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through several countries before they are delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We use ‘cookies’ to monitor how people use our site and to distinguish you from other users of our website. This helps us to understand how our customers and potential customers use our website, so we can develop and improve the design, layout and function of the sites. A cookie is a piece of information that is stored on your computer’s hard drive which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit. You can normally alter the settings of your browser to prevent it from accepting cookies.
6. Further Information