We are Scottish and Southern Electricity Networks Transmission (“SSENT”), which is the trading name of Scottish Hydro Electric Transmission Plc (“SHET”), registered address at Inveralmond House, 200 Dunkeld Road, Perth, Perthshire PH1 3AQ, is committed to respecting your privacy and complying with applicable data protection and privacy laws. SHET is subject to the laws of Scotland.
We use your information as further explained in this Privacy Notice. SSENT will be the “Data Controller” of the information you provide to us. “We”, “we’ll”, “our”, “us” etc. when used in this Privacy Notice will be interpreted as relating to SSENT as the Data Controller.
We will only collect, store and use your personal data for defined purposes. We use your information to support and enhance our relationship with you e.g., provide services and support, share products and company news with you. We do not sell your personal information.
This Privacy Notice covers the following processing activities of SSENT:
- Land & Wayleaves (land rights);
- Stakeholder Engagement;
- Customer Complaints;
- Asset Management & Operations; and
- Safety, Health & Wellbeing
What information do we need?
We may collect basic personal data about you (name, address, telephone number and email address);
- We may also collect your bank and card details in certain circumstances for processing payments or refunds;
- When using our website, we may collect your IP address, location information and browsing information;
- We will collect your preferences for communications e.g., by telephone, SMS, email or post;
- Details of your participation in surveys;
- Interactions with us via social media;
- We may receive special category data (health and medical information/history) in certain circumstances such as: an “energy not supplied” event, emergency or a health & safety incident, or from third party contractors in delivering projects;
- CCTV footage when you visit our sites or offices;
- For our asset refurbishment, replacement and delivery projects, we may collect personal data from our suppliers, such as CVs and emergency contact details; and
- If you contact us, or we contact you by telephone, we may record the call for training and service improvement purposes and make notes in relation to your call.
How do we collect your personal data?
For the most part, we collect personal data directly from you. As a transmission operator, we work closely with third parties, including other SSE group companies, IT & survey providers, sub-contractors, National Grid ESO, Members of Parliament, local authorities, the Office of Gas and Electricity Markets (“Ofgem”) and other regulatory bodies, and we may also collect your personal data from these third parties.
Legal bases for processing
In order to process and use your personal data lawfully, we rely on the following legal bases:
- For the performance of a contract with you or to take steps at your request prior to entering into such a contract;
- To comply with our legal obligations;
- For the performance of a public task in the public interest or in the exercise of official authority vested in us;
- For our legitimate interests in ensuring effective business development, operational management and internal administration, document retention/storage, compliance with regulatory guidance, exercise or defence of legal claims, product/service improvement and communicating with you; and
- With your consent, to maintain and develop our relationship with you, including marketing our products and services and for market research purposes. You may withdraw your consent at any time.
What do we do with it?
We may need to know your personal data to be able to maintain and operate the electricity transmission network for which we are responsible.
The personal data we process is used to:
- Perform our obligations under any contract we have with you;
- Help you with any enquiries, complaints or obtain feedback on how we can improve our services;
- Provide you with any information that we are required to send you in accordance with our regulatory or legal obligations;
- Detect, prevent, investigate, or remediate crime, illegal or prohibited activities or to otherwise protect our legal rights, including liaison with regulators and law enforcement agencies;
- Communicate with you by telephone, mail, email or other electronic means;
- Monitor, measure, improve and protect the content of our websites and services to provide enhanced and personal user experience for you;
- Investigate health & safety incidents or emergencies;
- Improve delivery of our obligations as a transmission operator including infrastructure delivery and maintenance, and assess the services we provide to our customers pre- and post connection;
- Contact you in the event of an “energy not supplied” incident where a compensatory payment may be required;
- Conduct enquiries into land ownership and occupation (including land value/compensation and conducting land surveys);
- Communicate with landowners and occupiers in regards to developments;
- To communicate with you in connection with development consultations (including report generation); and
- Process applications, make funding decisions and manage grant awards as part of our community benefit grant funding process.
For additional information on what we do with your personal data for: Connections, Land & Wayleaves, Stakeholder Engagement, Innovations, Customer Complaints, Asset Management & Operations or Safety, Health & Wellbeing, please see sections below.
Who do we share it with?
We may share your information with:
- Regulatory authorities for the purposes of demonstrating compliance with applicable law and regulations;
- Our corporate auditors for the purposes of demonstrating compliance with financial and regulatory frameworks;
- Our sub-contractors for the purposes of carrying out work on our behalf;
- Our service providers for the purposes of providing services to us;
- Other SSE group companies for the purposes of account administration, payment management and strategy development;
- Debt collection agencies for the purposes of debt management;
- The Planning Inspectorate or any other relevant planning authority in order for us to comply with applicable laws in regard to land developments;
- We may share certain information on our social media sites, for example photographs or videos of you participating in one of our stakeholder engagement events, or those individuals funded by our community benefit grant funding process.
- We may share certain information with the Police or other criminal or fraud detection agencies in order to detect, prevent, investigate, or remediate crime, illegal or prohibited activities.
Products, Services and Marketing
Where we have a legal basis to do so, we may contact you in writing, by phone, via email or SMS with information on products, services, and rewards that we or other companies within the SSE group offer. With your consent we may use third parties to send marketing communications.
To opt out of receiving direct marketing messages, please contact us at any time verbally, by email or in writing using the details in the Contacting us section below. You can also unsubscribe at any time by clicking the “Unsubscribe” link in any of our emails or by emailing: firstname.lastname@example.org
How long will we keep it?
We will keep your information only for as long as necessary depending on the purpose for which it was provided.
When determining the relevant retention periods, we will take into account factors including:
- Our contractual obligations and rights in relation to the information collected;
- Legal obligation(s) under applicable law or licence conditions set by Ofgem to retain data for a certain period of time;
- Potential disputes; and
- Guidelines issued by relevant data protection authorities.
We will securely destroy and permanently delete your information once it is no longer needed.
Details of retention periods for different categories of your personal data are available in our data retention policy, which you can request by contacting us using the details below in the Contacting us section.
International Data Transfers – How is your personal data transferred outside of the European Economic Area (EEA)?
Your personal data may be transferred to or processed in a country which is outside your resident country (this includes outside of the United Kingdom and European Economic Area (“EEA”). This may include transfers to other companies within the SSE group, and to third parties.
We will take organisational, contractual, and legal measures to ensure that adequate levels of protection have been implemented to safeguard your personal data such as:
- Where the country has been granted an adequacy decision by the European Commission and/or the Information Commissioner in the UK. This means that the destination country provides an adequate level of protection which is equivalent to the UK, and the EEA; or
- Put in place a contract with the third party receiving the personal data, which incorporates the Standard Contractual Clauses (“SCCs”) which has been issued by the European Commission (in relation to transfers of European residents’ personal data) and the UK addendum to the SCCs which has been issued by the ICO (in relation to transfers of UK residents’ personal data), that means the third party who receives the personal data must protect it to the same standards set out in the GDPR; or
- Where an appropriate derogation as set out in Article 49 of the GDPR applies; or
- Where the EU-US Data Privacy Framework and/or the UK Extension to the EU-US Data Privacy Framework arrangements apply.
You have the following rights regarding your information:
What does this mean?
|1. Right to be informed||
You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Notice.
|2. Right of access||
You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Notice). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
|3. Right to rectification||
You are entitled to have your personal data corrected if it is inaccurate or incomplete.
|4. Right to erasure||
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not a general right to erasure; there are exceptions.
|5. Right to restrict processing||
You have rights to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.
|6. Right to data portability||
You have the right to obtain and reuse your personal data in a structured, commonly used, and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
|7. Right to object to processing||
You have the right to object to certain types of processing in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests or on public interest grounds; the right to object to processing for direct marketing purposes (including profiling); the right to object to the use of your personal data for scientific or historical research purposes or statistical purposes in certain circumstances.
|8. Right to withdraw consent||
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for direct marketing.
For more information on your rights or if you would like to exercise any of your rights, you are welcome to get in touch using the details in the Contacting us section below.
We may use your information to:
- Process your application and provide you with designs and quotations for a new connection to our electricity network;
- Provide feasibility and budget estimates;
- Manage applications for disconnection from our electricity network;
- Manage generation applications, which is reportable to our regulator Ofgem;
- Provide our operational teams with the necessary information to carry out the connection works onsite;
- Share your contact details where you are the primary generator with a flexible connection to assist other applicants who are interested in shared capacity connections; and
- Contact you to invite you to take part in connections engagement activities (including third party providers conducting surveys and research on our behalf), to provide comment/feedback on changes in policy and improvements to systems comply with legislation associated with the provision of electrical connections.
We may use your information to:
- Agree rights in land;
- Manage existing land rights;
- Carry out administrative duties relating to rights agreed inclusive of payments;
- Carry out other land liaison duties such as notification of project work, operations and maintenance;
- Process wayleaves payments; and
- Facilitate access to install, monitor, maintain and remove apparatus lawfully situated on your land.
We may share your information with any legal or professional representative you have appointed to liaise with us on your behalf.
We may also share your information with contractors, consultants, surveyors and legal representatives undertaking the development of projects, delivery of maintenance and management of assets on our behalf.
We may use your information to:
- Fulfil and evidence regulatory stakeholder engagement targets and obligations;
- Record your consent and marketing preferences;
- Invite you to future stakeholder activities and events that may be of interest to you;
- Record your attendance at events and any feedback you have provided; and
- Provide you with updates and relevant information on SSENT activities, including progress of initiatives, forthcoming developments, and opportunities to engage and consult.
We may share your information with:
- SSE group companies (including teams such as IT, Legal, Auditors, Finance);
- Ofgem, or any other regulatory authority for the purposes of demonstrating compliance with applicable law, regulations or enforcement action;
- Third parties such as National Grid ESO and sub-contractors for the purposes of carrying out work on our electricity transmission network; and
- Our service providers for the purposes of supplying services to us (including third party providers carrying out surveys, consumer research, engagement activities or energy not supplied events on our behalf).
We may photograph our events and these photographs may be published on our website, social media or provided as evidence of an engagement taking place. If you do not wish to be photographed, stakeholders are invited to remove themselves from shot or contact the event organiser.
Our virtual engagement events (webinars) may be recorded and published on our website, emailed to interested stakeholders and published on our social media channels.
Innovations - Supplementary Information
If you register an interest in being kept up to date with any new innovations’ projects undertaken by SSENT, or sign-up to be part of a particular project, we use your information to:
- Send you newsletter communications with updates about our ongoing or new innovations projects. This may also include information on wider industry events such as those organised by other Transmission Network Operators or the Energy Networks Association;
- Design projects to trial innovative technologies to help manage the SSENT network;
- Effectively deliver innovations projects; and
- Verify any analysis carried out on those projects.
We may collect specific information about you from third parties working in association or partnership to deliver projects e.g., Joint Ventures with third-parties.
In some cases, we may deliver innovation projects with external partners, and we may need to share your information with them to ensure that we can deliver the project successfully.
We may use your information to:
- Record your complaint for monitoring and reporting purposes;
- Investigate complaints received to reach a resolution; and
- Analyse the causes of complaints or feedback received to improve our processes and service.
We may use your information to:
- Respond to requests for safety information, for activities carried out in proximity to our assets;
- Respond to requests for network data;
- Respond with contact details for other relevant departments within SSENT;
- Respond to general enquiries regarding our assets and operations; and
- Capture information to assist stakeholders with planned works near our transmission assets, this may include location information and photographs of assets provided by third-parties, maps or drawings to ensure public safety and prevent network damage.
- Appropriate regulators, e.g., Health & Safety Executive (HSE); and
- Our Insurers.
In the event that an incident is reported by a member of the public we may record personal data about the individual making the record. In the event that an incident has occurred that may impact a member of the public we may record personal data about the individual making the report and individuals affected.
Such personal data may include: name, contact details, their connection to the incident being reported and details of an injury.
This information will normally be obtained from you or will arise from your interactions with SSENT.
Such personal data will be processed to investigate, and to help us reduce or prevent similar, accidents/incidents relating to the safe conduct of our activities and/or to comply with legislative obligations in relation to health and safety incident reporting requirements.
Address: SSEN Transmission Risk & Assurance, 1st Floor, Grampian House, Dunkeld Road, Perth PH1 3AQ
If you would like to contact our Data Protection Officer, you may do so by contacting them at:
Address: Data Protection Officer, No. 1 Forbury Place, 43 Forbury Road, Reading, RG1 3JH
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113
This Privacy Notice was last updated on 17 November 2023.