About us

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. We are committed to respecting your privacy and complying with applicable data protection and privacy laws. SHET is subject to the laws of Scotland.

For the specific business areas outlined below, any associated Joint Venture companies will also be controllers of your personal information:

  • Eastern Green Link 2 (EGL2) of No. 1 Forbury Place, 43 Forbury Road, Reading, United Kingdom,
    RG1 3JH.
  • Eastern Green Link 3 (EGL3) of No. 1 Forbury Place, 43 Forbury Road, Reading, United Kingdom,
    RG1 3JH.

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.

Who this Privacy Notice applies to

This Privacy Notice covers the processing of individuals personal data by SSEN Transmission. SSEN Transmission is an independent Data Controller of the processing activities set out in this Privacy Notice.

The type of personal data we collect

When you engage with SSEN Transmission, personal data about you is collected, stored and processed. This has been grouped together as:

Table 1.1

Category

Non-Exhaustive Examples Describing the Types of Personal Data Included within the Category

Identity Data

Information which can identify an individual, including but not limited to first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, gender, national insurance number, PPS Number or other tax payer ID, social security number, passport, driving licence, photographs, voice/call recordings, images, video footage (including from dashcams or body worn cameras), CCTV footage (which may include smart sensor technology); vehicle registration.

Contact Data

Address, phone number, email address, billing address, social media handle and profile.

Financial Data

Bank account, payment card details, credit history, grant application details, tax status, payroll records.

Transaction Data

Details about payments to and from data subjects, details of products and services data subjects have purchased, information about other third-party supplier’s electricity and/or gas accounts.

Technical Data

Internet protocol (IP) address, login data (username and passwords), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices used to access websites and/or apps, approximate geo location.

Profile Data

Username and password, purchases or orders; interests, preferences, feedback and survey responses.

Usage Data

Information about interaction with and usage of SSEN Transmission website, products and services.

Marketing and Communications Data

Preferences/permissions for receiving marketing from SSEN Transmission and/or related/selected third parties and the data subject’s communication preferences; details of CV.

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.

Criminal Offence Data

Convictions, fines, driving offences, details of incidents, records, any investigation carried out in relation to an allegation or suspicion; any breaches of regulation or law, judgments against you, and enforcement investigations and actions against you.

Family Data

Next of kin, dependants and emergency contact information.

How personal data is used and the lawful basis for using it

Personal data is processed for the following purposes:

Table 1.2

Purpose

Category of Personal Data

Lawful Basis

Perform our obligations under any contract we have with you

Identity Data

Contact Data

Contractual obligation

Help you with any enquiries, complaints or obtain feedback on how we can improve our services

Identity Data

Contact Data

Legitimate interests

Provide you with any information that we are required to send you in accordance with our regulatory or legal obligations

Identity Data

Contact Data

Legal obligation – To meet our Ofgem license requirements.

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

Identity Data

Contact Data

Criminal Offence Data

Legitimate interests

Article 10 /DPA paragraph 10 to Part 2 of Schedule 1 and paragraph 33 to Part 3 of Schedule 1.

Legal obligation where compliance with a court order is required.

Communicate with you by telephone, mail, email or other electronic means

Identity Data

Contact Data

Legitimate interests

Monitor, measure, improve and protect the content of our websites and services to provide enhanced and personal user experience for you

Technical Data

Marketing and Communications Data

Legitimate interests

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

Identity Data

Contact Data

Legitimate interests

Contractual obligation

Contact you in the event of an “energy not supplied” incident where a compensatory payment may be required

Identity Data

Contact Data

Contractual obligation

Conduct enquiries into land ownership and occupation (including land value/compensation and conducting land surveys)

Identity Data

Contact Data

Financial Data

Legitimate interests

Contractual obligation

Communicate with landowners and occupiers in regard to developments

Identity Data

Contact Data

Legitimate interests

To communicate with you in connection with development consultations (including report generation)

Identity Data

Contact Data

Legitimate interests

Process applications, make funding decisions and manage grant awards as part of our community benefit grant funding process

Identity Data

Contact Data

Financial Data

Legitimate interests

Capture the social value generated by our projects—such as creating apprenticeship opportunities, supporting local communities through volunteering, and strengthening the local supply chain and SMEs

Identity Data

Contact Data

Legitimate interests

Connections - supplementary information

Table 1.3

Purpose

Category of Personal Data

Lawful Basis

Process your application and provide you with designs and quotations for a new connection to our electricity network

Identity Data

Contact Data

Legitimate interests

Contractual obligation

Provide feasibility and budget estimate

Identity Data

Contact Data

Legitimate interests

Manage applications for disconnection from our electricity network

Identity Data

Contact Data

Legitimate interests

Manage generation applications, which is reportable to our regulator Ofgem

Identity Data

Contact Data

Legal obligation – To meet our Ofgem License requirements

Provide our operational teams with the necessary information to carry out the connection works onsite

Identity Data

Contact Data

Legitimate interests

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

Identity Data

Contact Data

Legitimate interests

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

Identity Data

Contact Data

Legitimate interests

Land & Wayleaves - supplementary information

Table 1.4

Purpose

Category of Personal Data

Lawful Basis

Agree rights in land

Identity Data

Contact Data

Legitimate interests

Manage existing land rights

Identity Data

Contact Data

Legitimate interests

Carry out administrative duties relating to rights agreed inclusive of payments

Identity Data

Contact Data

Financial Data

Legitimate interests

Contractual obligation

Carry out other land liaison duties such as notification of project work, operations and maintenance

Identity Data

Contact Data

Legitimate interests

Process wayleaves payments

Identity Data

Contact Data

Financial Data

Legitimate interests

Facilitate access to install, monitor, maintain and remove apparatus lawfully situated on your land

Identity Data

Contact Data

Legitimate interests

Stakeholder Engagement - Supplementary Information

Table 1.5

Purpose

Category of Personal Data

Lawful Basis

Fulfil and evidence regulatory stakeholder engagement targets and obligations

Identity Data

Contact Data

Legal obligation – To meet our Ofgem License requirements

Record your consent and marketing preferences

Identity Data

Technical Data

Legitimate interests

Invite you to future stakeholder activities and events that may be of interest to you

Identity Data

Contact Data

Legitimate interests

Record your attendance at events and any feedback you have provided

Identity Data

Contact Data

Legitimate interests

Provide you with updates and relevant information on SSENT activities, including progress of initiatives, forthcoming developments, and opportunities to engage and consult

Identity Data

Contact Data

Legitimate interests

Social Media

Table 1.6

Purpose

Category of Personal Data

Lawful Basis

Track and analyse publicly available discussions about SSEN Transmission, our projects, and industry-related topics

Technical Data

Legitimate interests

Support Grants and Compensation Events

Table 1.7

Purpose

Category of Personal Data

Lawful Basis

Process applications, assess eligibility, coordinate with third-party consultants and contractors, and issue payments related to various schemes and grants

Identity Data

Contact Data

Financial Data

Legitimate interests

Contractual obligation

Innovations - supplementary information

Table 1.8

Purpose

Category of Personal Data

Lawful Basis

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

Identity Data

Contact Data

Legitimate interests

Design projects to trial innovative technologies to help manage the SSEN Transmission network

Technical Data

Legitimate interests

Effectively deliver innovations projects with Joint Venture partners

Identity Data

Contact Data

Legitimate interests

Customer Complaints – supplementary information

Table 1.9

Purpose

Category of Personal Data

Lawful Basis

Record your complaint for monitoring and reporting purposes

Identity Data

Contact Data

Legitimate interests

Investigate complaints received to reach a resolution

All Data Types

Legitimate interests

Analyse the causes of complaints or feedback received to improve our processes and service

Identity Data

Contact Data

Legitimate interests

Asset Management & Operations– supplementary information

Table 1.10

Purpose

Category of Personal Data

Lawful Basis

Respond to requests for safety information, for activities carried out in proximity to our assets

Identity Data

Contact Data

Special Category Data

Legitimate interests

Legal obligation under the Health and Safety at Work etc. Act 1974

Article 9(2)(a) explicit consent

Article 9(2)(f) – processing is necessary for the establishment, exercise of defence of legal claims

Article 9(2)(g) – processing is necessary for reasons of substantial public interest, on the basis of member state law. 

Supplementary basis under the UK Data Protection Act 2018 for the processing of Special Category Data Paragraph 1 to Part 1 of Schedule 1 – Employment, social security and social protection

Respond to requests for network data

Identity Data

Contact Data

Legal Obligation - Ofgem Licence requirements

Respond with contact details for other relevant departments within SSEN Transmission

Identity Data

Contact Data

Legitimate interests

Respond to general enquiries regarding our assets and operations

Identity Data

Contact Data

Legitimate interests

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

Identity Data

Contact Data

Technical Data

Legitimate interests

Safety, Health & Wellbeing – supplementary information

Table 1.11

Purpose

Category of Personal Data

Lawful Basis

Appropriate regulators, e.g., Health & Safety Executive (HSE)

Identity Data

Contact Data

Legitimate interests

Legal obligation under the Health and Safety at Work etc. Act 1974

Investigate health & safety incidents or emergencies

Identity Data

Contact Data

Special Category Data

Legitimate interests

Legal obligation under the Health and Safety at Work etc. Act 1974.

Article 9(2)(b) UK GDPR/DPA 2018 Paragraph 1 to Part 1 Schedule 1.

Community Benefit Fund

Table 1.12

Purpose

Category of Personal Data

Lawful Basis

Contact you about your application and the fund

Identity Data

Contact Data

Financial Data

Legitimate interests

To check and verify bank account details

Financial Data

Legitimate interests

To assess the suitability of your application and to comply with our legal requirements

Identity Data

Contact Data

Financial Data

Legitimate interests

Promote the fund, in articles, reports, social media posts

Technical Data

Legitimate interests

Some of the above purposes for processing may overlap and there may be several purposes which justify our use of your personal data.

Less commonly, we may process Special Category Data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public e.g. where the personal data is a matter of public record, credit reference agencies or through public social media.

Receiving 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 Energy System Operator (NESO)
  • 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.

Sharing your Personal Data

We may share your personal data with:

  • Regulatory authorities (e.g. Ofgem, the Planning Inspectorate) 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;
  • External third parties including but not limited to contractors (and their sub-contractors), consultants, surveyors, legal representatives and service providers providing services to us or on our behalf; or undertaking the development of projects, delivery of maintenance and management of assets on our behalf;
  • Other SSE group companies for the purposes of account administration, payment management and strategy development or where a SSE group company provides a service to us;
  • Any legal or professional representative you have appointed to liaise with us on your behalf;
  • Debt collection agencies for the purposes of debt management;
  • 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.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

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 outside of the UK and/or 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.

Your rights

You have the following rights regarding your information:

Table 1.13

Rights

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.

Contact us

If you would like to contact us in relation to your rights, or if you are unhappy with how we’ve handled your information, you may contact us as follows: 

Address: SSEN Transmission Risk & Assurance, 1st Floor, Grampian House, Dunkeld Road, Perth
PH1 3AQ 

Email:  TransmissionDataProtection@sse.com

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

Email: GroupDPO@sse.com

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