Irish Water was established under the Water Services (No. 1) Act 2013 for the purposes of providing water services functions, which include the provision of water and collection, treatment and disposal of wastewater from domestic and non-domestic customers. The Water Services (No. 2) Act 2013 obliges Irish Water to charge customers for the provision by it of water services. This Data Protection Notice sets out Irish Water’s procedures for the fair collection and processing of personal data required for Irish Water to perform its statutory functions.
Collection of Customer Personal Data
In order for Irish Water to provide the customer with water services, and to enable Irish Water to establish and manage the relationship with that customer, Irish Water needs to collect and use data relating to the customer. Irish Water collects information when its customers contact us (such as by phone, e-mail or letter), for example, to open or transfer an account, or to make a complaint. Irish Water may collect information from local authorities, who were responsible for water services in Ireland before 1 January 2014, and who now provide water services on Irish Water’s behalf.
This data is used to manage and administer the customer account and for operational reasons, to include
- determining who is the customer account holder for each address;
- determining whether a customer is an owner or a tenant so that Irish Water can revert the customer account to the owner if a tenant moves out;
- utilising information on water and wastewater services to determine who is a customer;
- calculating the correct tariffs and caps, and billing the customer;
- complying with Code of Practice requirements, for example, if a customer is a vulnerable customer;
- responding to and managing operational issues, for example, issues with drinking water quality, pipes or meters;
- carrying out assessments, statistical analysis or research and development processes, so that we can review, develop and improve appropriate tariffs, services and conservation measures.
The provision of contact details (other than name and address) is optional, and will be used for outbound communication to customers including outage notification and general account management. Information may also be processed to assess a customer’s ability to pay in the event of arrears on an account, so that Irish Water can treat those having genuine difficulty in making payment sympathetically.
In addition, data provided by the customer may be used for marketing purposes, and this is explained further below.
Verifying Customer Information
Following the Government decision of 19 November 2014, PPS Numbers are no longer required as part of customer applications; Irish Water’s arrangements are based on self-declaration and appropriate audit.
On occasion, for example where a customer’s water usage varies significantly from that which is typical for their occupancy configuration, Irish Water may ask customers to provide evidence in support of the occupancy declaration they made in the application process. Proof may be sought, for example, to ensure that children are still under 18 years old and so eligible for the Children’s Water Allowance.
Customers may provide such evidence in a number of different forms. Any evidence provided by customers in those circumstances will be retained only for as long as it takes for Irish Water to verify the customer’s account details.
All PPS Numbers provided prior to 19 November 2014 have been removed from Irish Water’s systems.
Sensitive Personal Data – Special Services and Priority Services
Customers may provide sensitive medical information to Irish Water if they wish to register on Irish Water’s Special Services Register and/or Priority Services Register. Customers may provide information such as whether they are elderly, deaf or hard of hearing, blind or visually impaired, mobility impaired, suffering from mental illness, have an intellectual disability or have an illness that requires a higher than normal water supply requirement. This information will be used to provide bills and communications in alternative formats, and to contact those customers at particular times, for example, when there is a supply interruption, to adjust the customer’s bill appropriately or to offer alternative water supplies. Sensitive personal data provided by a customer may also be used to put in place special arrangements for a customer, for example, during site works or in relation to a drinking water incident. Irish Water has put in place procedures to minimise the amount of sensitive personal data being recorded by it.
Irish Water may keep the customer's data for a reasonable period after the customer ceases to be supplied with water services but will not keep it for any longer than is necessary and/or as required by law, whether under the Data Protection Acts 1988 and 2003 or otherwise.
Irish Water may share the customer's data with authorised agents or third parties who act on behalf of Irish Water, including local authorities, in connection with the activities referred to above, pursuant to a contractual relationship. Irish Water continues to be the Data Controller for this data and these authorised agents act as Data Processors on our behalf. Such agents or third parties are only permitted to use the customer's data as instructed by Irish Water. They are also required to keep the customer's data safe and secure.
Irish Water’s data centres are located in Ireland. On occasions, mainly to resolve system issues, Irish Water may require technical support from outside the European Economic Area (EEA). While this does not involve storing data outside the EEA, it may involve technical support accessing Irish Water’s system remotely from outside the EEA, with a possibility that it may view customer data while trying to resolve the issue. Technically, under data protection law, this is deemed to be a “transfer of data” as the data can now (temporarily) be viewed outside the EEA. In all cases, any such activity is supported by a contract which includes data protection clauses which are binding on the technical support agent. Irish Water has included reference to this activity in its customer information for reasons of transparency.
Irish Water may also disclose customer data if it is under a duty to disclose or share customer data in order to comply with any legal obligation, or in order to protect the rights, property, or safety of Irish Water, its customers or others. Irish Water will also disclose customer data if it is required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other valid legal process.
From time to time the customer may speak to employees of Irish Water (or agents acting on its behalf) by telephone. To ensure that Irish Water provides a quality service, the telephone conversations may be recorded. Irish Water will treat the recorded information as confidential and will only use it for staff training/quality control purposes, and for confirming details of the conversations with Irish Water.
If the customer requests that Irish Water communicates with him/her by email, the customer is solely responsible for the security and integrity of the customer's own email account. Unfortunately, the transmission of information via the internet is not completely secure. Consequently, while Irish Water will take all reasonable security measures, Irish Water cannot guarantee the privacy or confidentiality of information relating to the customer being passed via the Internet; any transmission is entirely at the customer's own risk.
For further information on data collected on our website, please see our Privacy Statement.
From September 2014, Irish Water mailed all households in Ireland with an application pack, using names and addresses based on information received from multiple sources. As there is no one central list of all households in Ireland that are connected to the public water main and/or public sewer, Irish Water was unable to refine its mailing to Irish Water customers only. Therefore, Irish Water asked all recipients of application packs to respond to confirm whether they are or are not a customer of Irish Water. If someone declares themselves not to be a customer, certain information is required in order to confirm that this declaration is correct, and to verify that that person is not in fact using water services provided by Irish Water. Such information will be held until Irish Water has validated that that person is not a customer. The information required in those circumstances is as follows:
- Supply Address
- Whether that person is a Tenant or Owner
- Type of water supply
- Type of wastewater service
Any person who is declaring themselves as not being a customer will not have to submit the following details to Irish Water:
- Number of occupants in the household
- Contact information
- Vulnerable services requests
- Direct Debit details
The customer, or other person whose data is held by Irish Water, has a right to ask for a copy of that person’s data, which is held by Irish Water (under legislation Irish Water is entitled to charge a nominal administration fee for this). If the customer or other person wishes to avail of this right, a request must be submitted in writing to: Irish Water, Data Protection Officer, PO Box 860, South City Delivery Office, Cork City. In order to protect privacy, the person making the request may be asked to provide suitable proof of identification. If any of the details are incorrect that person is entitled to notify Irish Water to amend such details. If data held by Irish Water relating to a person is incorrect that person is entitled to notify Irish Water to amend such details. You can download an Access Request form here.
Irish Water and/or authorised agents acting on behalf of Irish Water may wish to contact the customer by text message, email, post, landline or in person about water related products or services which may be of interest to the customer ("Marketing Purpose"). For the avoidance of doubt, Irish Water will not sell or provide personal data to third parties for marketing use. Irish Water will not use personal data to market non-water or wastewater related products or services.
If the customer does not wish to be contacted for Marketing Purposes as set out above, the customer may exercise a right of opt-out by either writing to Irish Water at FREEPOST, Irish Water, Data Protection Opt-out, PO Box 860, South City Delivery Office, Cork City or by calling Irish Water on LoCall 1850 448 448. The customer may opt out at the time when Irish Water collects their data or at any time thereafter.
Where a customer (or non-customer) has any queries in respect of personal data he/she should contact Irish Water on LoCall 1850 448 448.