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Gasway Customer Privacy Notice

Gasway Customer Privacy Notice

Personal information
Gasway Services Limited are committed to the responsible handling and protection of your
personal information.
The Data Protection Act 2018 and UK General Data Protection Regulation (GDPR) defines
personal data as any information related to an individual that can be used to identify them
directly or indirectly. This includes physical attributes, location data, online identifiers
(including IP addresses), identification numbers, health information and economic, cultural,
or social identity of a person.

We process (collect, use, store, share) personal information where necessary to provide our
services and for our operational and business purposes as described in this Privacy Notice.
We want to be clear about our privacy practices so that you can make informed choices
about the use of your information, and we encourage you to contact us at any time with
questions or concerns.

How we use your information
This privacy notice tells you how we, Gasway Services, will collect and use your personal
information to enable us to provide our services to you. The information we process can be
collected directly from customers or from third-party organisations where we process
information on their behalf.

Why does Gasway Services need to collect and store personal information?


Gasway processes personal information for the following purposes:-
• Servicing, repair and installation of gas appliances and heating systems
• Management and support of customer contracts
• For the welfare of our customers
• For the protection of employees, customers, contractors, and sub-contractors
• For the prevention of fraud, crime, legal proceedings, and to comply with the
law
• Feedback from research and surveys on how we can provide better services
• Communication with our customers to provide updates relating to our
business and services
• For the management of financial services
• For general day to day corporate operations and due diligence

We are committed to ensuring that the information we collect, and use is appropriate for
these purposes and does not constitute an invasion of your privacy.

Special category personal data
Occasionally we may collect and process what is considered special category personal data
(sensitive personal information).
Sensitive personal information is a subset of personal data and is defined as any
information related to racial/ethnic origin, political opinions, religious beliefs, trade union
membership, physical or mental health information including biometric and genetic data,
or sexual life preferences.
We will only collect this information if it is necessary to support you whilst you are a
Gasway Services customer.
We will only share this information if we receive your explicit consent to do so, unless for
reasons of vital interest (emergency, life or death situation) or required by law.

Lawful processing
We must have a valid lawful basis to process your personal information. This ensures that
the processing is necessary for the purpose we collected it for.
We process (collect, use, store, share) your personal information for the following lawful
basis:-

Performance of a contract – where the processing is necessary for Gasway to deliver our
side of the contract to you as an individual. This includes the following activities:-


• Processing information for the servicing, repair, or installation of heating systems
• Processing of credit and debit cards
• Processing of Direct Debits
• Processing of communication with Gasway including calls into our Customer
Services Team, notes of discussions, Emails, texts, and Live Chat

Legitimate interest – We process personal information for certain legitimate interests
related to the business purposes listed above. “Legitimate Interest” means in the interest of
our company in conducting and in managing your contract with us. This includes:-


• Advice by phone, post, text, or email confirmation on rescheduling an
appointment
• Processing of Staff Security Alert (SSA) and Do Not Visit Alone (DNVA) information to
protect our employees, customers, contractors, and sub-contractors working in
properties
• CCTV surveillance for the protection of property and staff at our premises
• Text or email you to complete feedback surveys after you have received a service
from us and use the information you provide to improve our services
• Email or text customers with the promotion of our services
• Storing (3 months) voice recordings when you call into our Customer Services Team
for complaints resolution, training, and quality purposes
• Sharing personal information, lawfully and as necessary in association with a
national or global disaster such as the coronavirus
• Processing of Email address to signpost customers for feedback on Trustpilot

Legal Obligation – We process personal information for certain legal obligations. This
is where the processing is necessary to comply with legislation or the law.


• Sharing personal information with the police or local authority for the
prevention and detection of crime (case specific and relevant)
• Whistleblowing for the protection of staff
• Sharing CCTV images for insurance and legal purposes
• Investigating and reporting of personal data breaches in line with data protection law
• Processing of Subject Access Requests (request for personal information we hold
about you) and individual rights in line with data protection law
• Overall information security and maintenance operations to prevent unauthorised
access, intrusion, misuse of company systems, networks including prevention of
personal data breaches and cyber-attacks (where an unauthorised third-party
accesses personal data)

Consent -

We process personal information at your request and where you have a choice to
do so. You can opt out or withdraw your consent at any time by emailing
dataprotectionteam@flagship-group.co.uk.

Administration of Live Chat – You have a choice whether to communicate with us in this way
by using Live Chat on the Gasway Services website. We use Amazon Connect to handle
customer enquiries in real time. If you use the Live Chat service, we will collect your name,
Email address and the contents of your Live Chat session. This information is retained on
encrypted servers within our own network and in cloud services. Live Chat information is stored
for 1 month after which it is deleted from this platform. We may keep a record of this
conversation on our servicing management system.

Vital Interest – We process personal information where it is in the vital interest of our
customers.


• If we are made aware of a risk of potential gas and/or carbon monoxide issue we
will pass details to the Emergency Service Provider, Cadent
• In an emergency where the individual is incapable of giving consent, we will share
medical details with paramedics or other medical providers
• Any national or global disaster that may change the way we work, such as the
Coronavirus.


Will Gasway share my personal information with anyone else?

We will share customer contact details with our internal tradespeople and operatives,
and we may pass your personal information on to:-


• third-party service providers, external contractors, sub-contractors, and suppliers
contracted to provide services on our behalf
• local authorities
• the police
• utility companies
• banks and other financial institutions to collect payments


Any third parties that we may share your information with are obliged to keep your details
securely, and to use them only to fulfil the services they provide on our behalf. When they
no longer need your information to fulfil this service, they will dispose of the details in line
with our procedures. If we wish to pass your sensitive personal information onto a third-
party, we will only do so once we have obtained your consent unless we are legally required
to do otherwise. If you require further details on who we share your personal information
with, please contact the dataprotectionteam@flagship-group.co.uk.

Special circumstances


To provide a duty of care to employees, customers, contractors, and sub-contractors we will
process and share relevant personal information for their protection. This will be an alert
on our servicing management system to visit in pairs (Staff Safety Alert).

How will Gasway use the personal information it collects about me?

Gasway will process the information you provide in a manner compatible with the Data
Protection Act 2018 and UK GDPR. We will endeavour to keep your information accurate
and up to date, and not keep it for longer than is necessary. However, we are required to
retain information in accordance with the law, such as information needed for financial,
legal and audit purposes. How long certain kinds of personal information should be kept
may also be governed by specific business-sector requirements, agreed practices and on
individual business needs.

Under what circumstances will Gasway Services contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary
questions. We may contact you to arrange visits if we receive instruction to undertake works
at your property. We may sometimes contact you for feedback by doing research or asking
you to take part in a survey, this enables us to make changes and improvements to our
services. We may also communicate with you when we have updates or changes to our
business. If you have provided us your Email and/or mobile number, we will contact you in
this way to communicate. We consider this communication to be within our legitimate
interest of lawful processing.

How do we secure personal information?


Gasway Services take data security seriously, and we use appropriate technologies and
procedures to protect your personal information. Our information security policies and
procedures are closely aligned with widely accepted standards and are reviewed regularly
and updated as necessary to meet our business needs, changes in technology, and
regulatory requirements.

Policies and procedures

We have measures in place to protect against accidental loss and unauthorised access, use,
destruction, or disclosure of data including the following:-


• We have a Business Continuity Plan and IT Disaster Recovery procedure that is
designed to safeguard the continuity of our service to our customers and to protect
our people and assets
• We place appropriate restrictions on access to personal information
• We implement appropriate measures and controls, including monitoring and
physical measures, to store and transfer data securely
• We conduct Data Privacy Impact Assessments in accordance with legal
requirements and our business policies
• We conduct Data Protection training for all employees who have access to personal
information and other sensitive data
• We take steps to ensure that our employees and contractors operate in accordance
with our information security policies and procedures and any applicable contractual
conditions
• We require third party contractors or sub-contractors to have appropriate
agreements in place to ensure personal information is processed in line with
legislation

Can I find out the personal information that Gasway holds about me?
We, at your request, will provide you with a copy of the personal information we hold about
you. This is referred to as your right of access (subject access request). You are entitled to
receive any information that identifies you as an individual, including the following
information:-


• The lawful conditions applicable to the processing of your personal information
• If the processing is based on a legitimate interest (this is necessary for the operation
of our business and you will expect your data to be used in this way)
• The categories of personal information processed
• Recipients(s) or categories of recipients that the data is/will be disclosed to
• If we intend to transfer personal information to a third country or international
organisation
• How long the information will be stored
• The source of personal information if it was not collected directly from you
• Any details and information associated to automated decision making or profiling

Your rights as a data subject (customers of Gasway Services)

At any point while we are in possession of or processing your personal data, you, the data
subject, have the following rights:


• Right of Access – at your request we will provide you with a copy of the personal
data we hold about you. This is referred to as your right of access (subject access
request). You are entitled to receive any information that identifies you as an
individual.
• Right of rectification – you have a right to ask us to update personal information if
you have a reason to believe that it is inaccurate or incomplete.
• Right to be forgotten – you have the right in certain circumstances to ask for the data
we hold about you to be erased from our records. Especially if you think we are
processing your personal information where it is no longer necessary or where you
believe it is unlawful.
• Right to restriction of processing – You have the right to ask us to temporarily stop
processing your personal information if you have concerns over the accuracy of the
information in some way.
• Right of portability – you have the right to have the data we hold about you
transferred to another organisation.
• Right to object – you have the right to object to the way we process your personal
information if you consider Gasway are being unlawful.
• Right to object to automated decision making, including profiling – you have the
right to object to decisions made about you from automated processing/profiling.
Privacy Notice changes


We will regularly review and make necessary changes to the services and information
handling processes when you, the law, or the Information Commissioners Office (ICO)
request such changes.
We process (collect, use, store, share) personal information where necessary to provide our
services and for our operational and business purposes as described in this and future
Privacy Notices.


This privacy notice was last updated on 31/01/2024


How to contact us?

If you would like to make a request to obtain the personal information we hold about you or
access any of your rights as explained in this privacy notice you can do so in the following
ways:-

Write to us at:-
Data Protection Officer
Flagship Group
31 King Street
Norwich
NR1 1PD

Email – Data Protection Officer DataProtectionTeam@flagship-group.co.uk

Phone – 0800 074 3030

If you have any concerns regarding how Gasway Services has handled your rights request, you
have the right to complain to the Information Commissioner’s Office (ICO) at:-

Information Commissioner's Office
Wycliffe House
Water Lane Wilmslow Cheshire
SK9 5AF

Tel : 0303 123 1113

 

You can download, a PDF of this notice here.