This notice is intended to help you understand what Personal Data Irish Water collects about you, why we collect it, and what we do with it.
Irish Water (“we”, “us”, “our”) is a "Controller" under the General Data Protection Regulation ((EU) 2016/679) ("GDPR") in respect of certain Personal Data you furnish to us. Irish Water is the single national utility responsible for public water and wastewater services in Ireland and is tasked with operating, improving and investing in the water and wastewater systems in order to provide safe, reliable and high quality services to customers.
Irish Water is regulated by the Commission for Regulation of Utilities and the Environmental Protection Agency, and has its registered office at Colvill House, 24-26 Talbot Street, Dublin 1.
“Personal Data” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier such as a user IP addresses or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Categories of Personal Data;
"Special Categories of Personal Data" is any Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; genetic data or biometric data and data concerning health or sex life and sexual orientation.
We collect and process Personal Data relating to you in connection with our relationship with you. This Personal Data includes:
- your name and contact details, including your address, phone number and email address;
- customer service records, including complaints and claims;
- details related to your connection, including service requests, work orders and details;
- your account record, including meter readings, billing, payments and collections;
- landowner records where relevant to a right exercised by Irish Water, e.g. a right of way;
- any Freedom of Information or Subject Access Request details; and
- any other Personal Data relating to you that you provide to us or that we generate about you in connection with our relationship with you, including records of any consent you have given and your use of the Irish Water website.
We also collect Special Categories of Personal Data in relation to customers who require priority or special services. Information regarding the disability or difficulty requiring the priority or special services is collected in order to assist Irish Water to meet the needs of those customers.
When you visit the Irish Water website, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
We collect data from you and from other entities within the Ervia group. We previously collected data from other government agencies as part of a once off collection when Irish Water was originally established in order to compile our customer database. This was expressly permitted by by Section 26 of the Water Services (No. 1) Act 2013 and was carried out in consultation with the Office of the Data Protection Commissioner.
The Personal Data that is referred to above will be processed for the purposes of:
- performing our functions as a public authority, including operating and maintaining the national water and wastewater systems;
- complying with our legal obligations;
- providing customer service to you and contacting you if required to respond to any communications you might send to us;
- establishing, exercising or defending legal claims;
- sending you promotional and marketing materials; and
- improving the services we provide to you.
Our legal basis for collecting and using this information in accordance with the provisions of this Data Privacy Notice is:
- that it is necessary for the performance of a contract with you;
- that it is necessary for the performance of tasks that we carry out in the public interest or in the exercise of official authority vested in us by law (including the Water Services Acts 2007 to 2017 and the Safety, Health and Welfare at Work Act 2005);
- that it is necessary for compliance with a legal obligation that applies to us; or
- that you have provided consent to us for the use of your Personal Data.
Where you have provided consent for the use of your Personal Data, you can withdraw it at any time by informing firstname.lastname@example.org, however, this will not affect the lawfulness of processing which was carried out based on your consent prior to its withdrawal.
We disclose your Personal Data to various recipients in connection with the above purposes, including:
- to third parties who we engage to provide services to us, such as outsourced service providers, IT service providers, professional advisers and auditors;
- to any other members of the Ervia group of which Irish Water is part, for any of the purposes set out in this Privacy Notice;
- to other public authorities and bodies where required or permitted by law, such as An Garda Síochána or other law enforcement authorities for the purposes of prevention, investigation or detection of crime; and
- to comply with any applicable law or regulation, a summons, search warrant, court or regulatory order, or other statutory requirement.
In order for the purposes outlined above and particularly for technical support, from time to time, we might have to transfer your Personal Data outside the European Economic Area (EEA) to a country that has not been confirmed by the European Commission to provide an adequate level of protection for Personal Data.
If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a data processing agreement in respect of the transfer which contains the ‘standard contractual clauses’ approved by the European Commission, or in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework (or any replacement framework). Further details of the measures that we have taken in this regard are available on request from email@example.com.
What this means is that, where we do not have the assurance of the destination for your data having been subject to a review by the European Commission, we will use other approved controls to ensure we can protect your data adequately and to ensure that those third parties who may process your personal data on our behalf meet the highest standards of privacy practices and comply with applicable data protection law.
Where you communicate with us via the Irish Water website, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your Personal Data:
Right of access
- The right to access your Personal Data;
Right to rectification
- The right to request the rectification and/or erasure of your Personal Data in certain circumstances;
Right to erasure (‘right to be forgotten’)
- The right to be forgotten in certain circumstances;
Right to restriction of processing
- The right to restrict the use of your Personal Data in certain circumstances;
Right to object
- The right to object to the processing of your Personal Data;
Right to data portability
- The right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller, in certain circumstances.
In addition to these rights, you also have the right to lodge a complaint with the Irish Data Protection Commission (https://www.dataprotection.ie/docs/Contact-us/11.htm), and the right to pursue a remedy through the Courts if we fail to meet the required standards of data protection.
We will not hold your Personal Data for longer than is necessary. We retain your Personal Data for as long as we need it for the purposes described in this Privacy Notice (including but not limited to section 3 (Disclosure of your Personal Data to third parties)), or to comply with any applicable statutory requirement.
We reserve the right to make changes to this Privacy Notice at any time without prior consultation. Any changes to this Privacy Notice will be posted on the Irish Water website so that you are always aware of what Personal Data we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail.
If you have any questions regarding this Privacy Notice, you can contact us using the information below:
Data Protection Officer
24-26 Talbot Street
You have the right to lodge a complaint with the Irish Data Protection Commission.