We really appreciate that you are supporting us with this Trial which will provide important data on how we move to a low carbon future.
This Privacy Notice sets out details on how we will use your data, what data we process, why, how it is legal, your rights and more information about the organisations involved in the project.
This Privacy Notice is given by Energy Systems Catapult (“ESC”) and myenergi Ltd (“myenergi”) (collectively “we” or “us”) who are “controllers” for the purposes of the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (“Data Protection Laws”).
General information about the Trial can be found here [http://thefredtrial.co.uk/about-fred]. The terms and conditions of the Trial (“Trial T&C”) can be found here [http://thefredtrial.co.uk/terms-and-conditions-of-the-trial].
About the organisations involved in the Trial
This Trial is being run as a consortium between multiple organisations (each referred to as a “partner”) as listed below:
myenergi: An award-winning team of passionate people whose zappi, eddi and harvi products are already transforming living and working environments by increasing self-consumption of renewable energy.
Energy Systems Catapult: An independent not-for-profit research organisation with a mission to support innovators and help the transition to a clean, renewable energy system.
Evergreen Smart Power: The creators of the Smart Power platform. The software lets zappis and eddis to respond in real time to grid conditions and energy prices to use electricity in a more intelligent and environmentally-responsive way.
Specific (Part of Swansea University): At the forefront of developing tech for energy efficient living. Their “Active Office” and “Active Classroom” buildings showcase low carbon technologies from solar walls to heat pumps to energy storage solutions.
Tonik Energy: A challenger energy supplier whose ambition is to use renewable energy and smart home technologies to cut energy bills in half over the years ahead. They will be using data generated in the trial to demonstrate how flexibility technology can result in cost savings and lower bills.
The only partners that will have access to your personal data will be myenergi and Energy Systems Catapult. The other partners in the consortium (Evergreen Smart Power, SPECIFIC and Tonik Energy) will only have access to anonymised data (i.e. data which cannot personally identify you). The purpose of collecting this anonymised data is to research and understand how people use energy, to further develop the Virtual Power Plant (VPP) technology and to explore how the results of the Trial can be converted into a commercial offer. The VPP is Evergreen Smart Power’s proprietary software platform which communicates with devices capable of using electricity in a flexible manner and automatically manages them to optimise when and how energy is consumed – making sure that (for instance) electric vehicles charge when electricity is cheaper and cleaner, and preventing local grids from becoming overloaded.
We will not use your personal data for purposes not stated in this Privacy Notice without notifying you in advance and, where relevant, asking for your permission.
How to Contact Us
If you have any questions regarding the way we process your personal data or would like this Privacy Notice in another format (for example: audio, large print, braille) please contact us at the details below:
Partner Email Telephone
myenergi – Data Protection Officer – email@example.com 0333 300 1303
Energy Systems Catapult – Data Protection Officer – firstname.lastname@example.org 0121 203 3700
Changes to this Privacy Notice
Current version: March 2019
What personal data do we collect
The sections below set out the categories of personal data we collect. The reasons as to why we need each category of data are set out in the section ‘Why do we need your personal data’.
In order for us to determine whether your residential heating arrangements are suitable for the Trial we request that you carry out a survey (“FRED Recruitment”). We ask you for the following:
• Your contact details, including your name, address, e-mail address and telephone number
• Details of your energy usage in relation to heating and electric car charging
The FRED Recruitment contains pre-programmed algorithms and criteria so that, after submitting your response, it immediately notifies you as to your eligibility to participate in the Trial. We are permitted to carry out this form of automated decision making because the decision is necessary for entering into a contract with you (i.e. the Trial). Please see the section “Your Rights” below in relation to your rights under the Data Protection Laws regarding automated decision making.
As the criteria for determining the eligibility to participate in the Trial is jointly determined by us, we are joint controllers of the personal data processed for the FRED Recruitment. Each of us shall independently comply with the Data Protection Laws, in particular as regards the exercising of your rights under the Data Protection Laws (please see the section “Your Rights” for more information on these rights).
Once we confirm your eligibility to participate in the Trial after the FRED Recruitment, you will be provided with an option to join (1) the Tech Trial or (2) the Tech Trial with Consumer Insight.
Under the Tech Trial, only myenergi processes personal data related to the following information about you (“Tech Trial Data”)(ESC does not process Tech Trial Data):
• zappi & eddi device status information
o Modes (Eco, Eco+ and Fast)
o Energy usages
o Grid and local energy consumption (including aggregate household demand)
o Date and length of each electric vehicle charge
Our partner, Evergreen Smart Power remotely controls your heating and electric vehicle charge. However, it does not process Tech Trial Data because it does not have access to information that can identify who you are.
Tech Trial with Consumer Insight
This section applies to those who signed up for the Tech Trial with Consumer Insight. Under this option, ESC separately collects the following additional information (“Consumer Insight Data”) (myenergi does not process Consumer Insight Data):
• Your experience of receiving and installing the myenergi hub through telephone interviews and video content recorded on the Indeemo app; and
• Questions about your experience of the Tech Trial through telephone interviews and online questionnaires.
Why do we process your personal data
We use your personal data for the following purposes listed in this section. We are allowed to do so on certain legal bases (please see section ‘How is processing your data lawful’ for further detail).
Categories of data Purpose Relevant controller Legal Basis
FRED Recruitment To determine whether your residential heating arrangements are suitable for the Trial ESC
myenergi Legitimate Interests
Tech Trial Data To review and control your energy usage in a way that maximises cost efficiency
To contact you if there are technical issues with the hardware (such as the myenergi Hub, zappi and eddi) myenergi Contract
Consumer Insight Data To better understand your experience during the Trial ESC Legitimate Interests
General enquiries To answer any questions you may have about us and the Trial ESC + myenergi Legitimate Interests
How is processing your data lawful?
We are allowed to process your personal data for the following reasons and on the following legal bases:
• Legitimate Interests
We are permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in our interest. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. The table in the section “Why do we process your personal data” explains the personal data processed on this basis.
You can object to processing that we carry out on the grounds of legitimate interests. See the section headed “Your Rights” to find out how.
It is necessary for our performance of the contract you have agreed to enter with us (i.e. the Trial T&C). If you do not provide your personal data to us, we will not be able to carry out our obligations under the Trial T&C. For example, we require your personal data to remotely control your energy usage in a way that is most cost efficient.
Organisations that we work with
We have listed some of our service providers that act as our processors as defined in the Data Protection Laws. We use other processors to support our IT systems and other ad hoc services. If you would like to know the names of our other service providers (e.g. training providers), please contact us using the details in the section “How to contact us”
• Indeemo – (ESC’s processor) Provider of the Indeemo app through which you share with us your Consumer Insight Data
• Smart Surveys – (ESC and myenergi’s processor) Online survey service provider for the FRED Recruitment
International transfer of data
We do not do process or transfer your personal data outside the UK or the European Economic Area.
How we keep your personal data secure
We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.
If you have any particular concerns about your information, please contact us (see ‘How to contact us?’ above).
How long we will keep your personal data for
We do not keep personal data for longer than we need it. In that regard, we will keep your personal data collected and processed for the Trial until March 2021.
As a data subject, you have the following rights under the Data Protection Laws:
• the right to object to processing of your personal data;
• the right of access to personal data relating to you;
• the right to correct any mistakes in your information;
• rights in relation to automated decision making;
• the right to prevent your personal data being processed;
• the right to have your personal data ported to another controller (e.g. if you decide to contract with a different service provider); and
• the right to erasure.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about the use of your personal data by us, please contact us (please refer to section “How to contact us”).
We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.
Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.
• Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.
If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed “How is processing your personal data lawful”.
• Right to access personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
o a copy;
o details of the purpose for which it is being or is to be processed;
o details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
o the period for which it is held (or the criteria we use to determine how long it is held);
o any information available about the source of that data; and
o whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
• Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please let us know the information that is incorrect and what it should be replaced with.
• Rights in relation to automated decision making
We carry out automated decision making in relation to the FRED Recruitment (please see the section “FRED Recruitment”). You have the right to challenge the decision made, request human intervention and request a review of the decision.
• Right to restrict processing of personal data
You may request that we stop processing your personal data temporarily if:
o you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
o the processing is unlawful but you do not want us to erase your data;
o we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
o you have objected to processing because you believe that your interests should override our legitimate interests.
• Copies of your personal data (data portability)
You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
• Right to erasure
You can ask us to erase your personal data where:
o you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;
o if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
o you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
o your data has been processed unlawfully or have not been erased when it should have been.
What will happen if your rights are breached?
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
Complaints to the regulator
It is important that you ensure you have read this Privacy Notice. If you do not think that we have processed your data in accordance with this Privacy Notice you should let us know as soon as possible. Similarly, you may complain to the ICO. Information about how to do this is available on its website at www.ico.org.uk.