The Data Protection Act 1998 controls how personal information is used by organisations, businesses or the government.
Everyone who is responsible for using data has to follow strict rules called ‘data protection principles’. They must make sure the information is:
- used fairly and lawfully
- used for limited, specifically stated purposes
- used in a way that is adequate, relevant and not excessive
- kept for no longer than is absolutely necessary
- handled according to people’s data protection rights
- kept safe and secure
- not transferred outside the UK without adequate protection
We must be able to satisfy one or more of the ‘Conditions for Processing’ before we are able to process such data:
- The individual who the personal data is about has consented to the processing
- The processing is necessary:
– in relation to a contract which the individual has entered into; or
– because the individual has asked for something to be done so they can enter into a contract
- The processing is necessary because of a legal obligation that applies to you (except an obligation imposed by a contract)
- The processing is necessary to protect the individual’s “vital interests”. This condition only applies in cases of life or death, such as where an individual’s medical history is disclosed to a hospital’s A&E department treating them after a serious road accident
- The processing is necessary for administering justice, or for exercising statutory, governmental, or other public functions
- The processing is in accordance with the “legitimate interests” condition
This data protection policy ensures Orme Energy Ltd:
- Complies with data protection law and follows good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
This policy applies to:
- The head office of Orme Energy Ltd
- All branches of Orme Energy Ltd
- All staff and volunteers of Orme Energy Ltd
- All contractors, suppliers and other people working on behalf of Orme Energy Ltd
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect Orme Energy Ltd from some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked drawer or filing cabinet.
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
- Personal data is of no value to Orme Energy Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Orme Energy Ltd to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort Orme Energy Ltd should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Orme Energy Ltd will make it easy for data subjects to update the information Orme Energy Ltd holds about them. For instance, via the company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
Subject Access Requests
All individuals who are the subject of personal data held by Orme Energy Ltd are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at [email address]. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
It is the policy of OrmeEnergy.com Ltd to provide a high quality service to everyone we deal with. In order to do this we need you to give us any comments about our service, and to tell us when we get things wrong.
We want to help you resolve your complaint as quickly as possible. We treat as a complaint any expression of dissatisfaction with our service which calls for a response. We listen to your complaints, treat them seriously, and learn from them so that we can continuously improve our service.
What is a complaint?
- A complaint is an expression of dissatisfaction, whether justified or not. Our policy covers complaints about:
- the standard of service we provide
- the behaviour of our staff, and
- any action or lack of action by staff affecting an individual or group
Our complaints policy does not cover
- comments about our policies or policy decisions
- dissatisfaction with our policies or decisions about individual cases
- matters that have already been fully investigated through this complaints procedure
- anonymous complaints
Our standards for handling complaints
- We treat all complaints seriously, whether they are made by telephone, by letter, or by email.
- Customers will be treated with courtesy and fairness at all times
- We will treat all complaints in confidence within the company
- We will deal with customer complaints promptly:
- We will acknowledge receipt of a complaint within seven working days (and inform the customer of our Complaint Handling Procedure and any additional procedures)
- We will send you a full reply within eight weeks of receipt
- If we cannot send a full reply within eight weeks of receipt we will tell you the reason why and let you know when we will be able to reply in full
- We will not treat customers less favourably than anyone else because of their:
- sex or marital status: this includes family status, responsibility for dependants, and gender (including gender reassignment, whether proposed, commenced or completed)
- sexual orientation
- colour or race: this includes ethnic or national origin or nationality
- religious or political beliefs, or trade union affiliation, or
- other unjustifiable factors, for example language difficulties or age
Third Party Reporting
- Complainants may wish to have a third party act on their behalf
- A third party is any person or organisation acting on behalf of or making enquiries for the complainant.
- Representatives may include:
- advice organisations
- professionals such as social workers, community psychiatric nurses or doctors, solicitors, family members or friends
- MPs and elected members of the Council – customers’ own MPs and elected members are assumed to have consent to act and information can be disclosed in response to their enquiries,
- attorneys are legally empowered to act on behalf of the complainant and consent to disclose information is not required.
- Where a third party is helping a complainant with a particular complaint and written authority is held to that effect, if the representative asks to be kept informed of progress on the complaint all possible steps will be taken to ensure that this happens
All complaints received will be dealt with confidentially and in accordance with the requirements of the Data Protection Act 1998.
Our complaints policy does not impair your statutory rights.
- We will take account of the needs of vulnerable customers, those with additional needs or special access requirements, when handling a complaint.
- Dealing with Vulnerable Customers:
- Choice and access – complaints can be raised verbally on the phone or in writing via the post or email. A customer can also visit us in Penrhyn Bay to discuss their complaint if they wish
- Recognising vulnerability – when a complaint is raised we will make every effort to establish if the customer is vulnerable, and adjust our process accordingly
- Advice and support – take extra time to ensure the customer understands what they are applying for and how ECO works. If needs be, offer to talk the plan through with a third party with their permission
How to Complain
- You can make a complaint in a number of ways:
- By telephone
- By email
- In writing or letter
- Complaints can be verbal or in writing
- If it is a customer of OrmeEnergy.com our contact details are:
- Post – Glan-Y-Mor Rd, Penrhyn Bay, Llandudno, Conwy, LL30 3NL
- Phone – 01492 588282
- eMail – enquiries@OrmeEnergy.com
- Customers should contact the energy company who has provided the funding or Ombudsman Services: Energy if their complaint has not been resolved within 8 weeks, or if they are not happy with our response
- Ombudsman Services:Energy
You can call them on 0330 440 1624
Or visit their website: www.ombudsman-services.org/energy.html
Within 7 working days of receipt of the complaint
- Notify the complainant in writing that the complaint has been received
- Notify the complainant in writing of our complaint handling procedure
- Notify the complainant in writing of the Ombudsman Services: Energy
- Notify the complainant in writing of any additional complaint handling procedures
- Within 8 weeks
- Make reasonable endeavours to investigate and resolve the complaint
- Notify the customer of our decision in writing, giving reasons
- Where the complaint is made against one of our Installers or Assessors, we will obtain all necessary information from them and notify in writing their Certification Body
- Ensure the Installer or Assessor co-operate in the investigation
- Notify the customer in writing as soon as practicable if we believe the complaint should be handled by another Green Deal Organisation
- Provide the customer with details of the Ombudsman Services: Energy or Certification Body
- If you are not satisfied with our decision, you may refer the complaint to the Green Deal Ombudsman service, and we will assist you to do so, including referring the complaint to that ombudsman if the customer requests
Extending time limits
- We aim to complete all complaints within the timescales above; however, if a complaint is very complex it may occasionally be necessary to extend the time limit. If this is the case we will keep the complainant informed of progress with the investigation, the reasons for the delay, and inform them of the new deadline.