Privacy Policy

Welcome to the Smart Meter Device Assurance Scheme’s (SMDA) privacy notice.

For clarity, “we” refers to Smart Meter Device Assurance Company Ltd (SMDA Co), as will “our”, “business”, “company” and “us”. “You” and “your” are the person, firm, business, representative, or organisation reading this notice.

This privacy notice will provide you with an overview as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. At this point it is important for you to know that we are governed by the UKs Information Commissioners Office (ICO) and they have in-depth information about the GDPR and how it applies to business within the United Kingdom. Detailed guidance on your obligations can be found on the ICOs website (www.ico.org.uk).

This privacy notice is split into sections for ease of review.  Please also use the Glossary at the bottom of the page as this will be a useful resource to help you understand the meaning of some of the terms used in this privacy notice.

1. SMDA Co – Important Information

SMDA Co is committed to safeguarding your privacy; this privacy notice aims to give you information on how SMDA Co collects, processes and treats your personal data through your use of this website and our services.

We should make it clear that this is a business website and is not designed, nor intended, for children. Therefore, we do not knowingly collect data relating to children.

This privacy notice supplements the other notices and is not intended to override them.

2. Your Legal Rights

SMDA Co would like to make you aware of your legal rights, so that as you are reading the rest of this notice you are aware of any rights you have under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please Contact Us via DataPrivacy@gemserv.com or use the details of our dedicated Data Protection Officer in Section 3.

Under certain circumstances you have the following rights under data protection laws:

  1. Request access to your personal data.
  2. Request correction or completion of your personal data.
  3. Request erasure of your personal data.
  4. Object to processing of your personal data.
  5. Request restriction of processing your personal data.
  6. Request transfer of your personal data.
  7. Withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we would be required to refuse to comply whereby we would have a legal ability to do so. SMDA Co will never refuse any request without first reviewing the request and considering the circumstance.

We try to respond to all legitimate requests within one month.

You also have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do Contact Us in the first instance.

3. SMDA Co – Data Controller & Contacting Us

For the purpose of the applicable national data protection legislation and to abide by GDPR requirements, you should be aware that the data controller responsible for your personal data is:

SMDA Co, headquartered at 8 Fenchurch Place, London, EC3M 4AJ.

SMDA Co is incorporated under the Laws of England and Wales bearing the company number 09327524.

SMDA Co provides a testing facility to offer assurance that smart meters are interoperable with the DCC and interchangeable (i.e. that they will work as intended in the Smart environment).

In order to deliver this service, we manage a governance structure (Board and Management Panel), secretariat function, design and carry out the testing and manage changes to the testing.

SMDA Co employ Gemserv Ltd to administer the service on their behalf.

Gemserv Ltd is regarded as the data processor who process your personal data under the written instructions of SMDA Co.

Gemserv Ltd is incorporated under the Laws of England and Wales with registration number 044 198 78 and is based at 8 Fenchurch Place, London, EC3M 4AJ.

SMDA has designated a Data Protection Officer (referred to as a DPO) for the purpose of conducting our business and associated activities. The DPO is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

DataPrivacy@gemserv.com

8 Fenchurch Place, London, EC3M 4AJ

020 7090 1000

4. Changes to the Privacy Notice and Your Duty to Inform us of Changes

This privacy policy applies from 31 July 2018 until such time it is updated again.

We may revise this privacy notice from time to time. Any revision will be brought to your attention by posting changes on the website.  Where appropriate, the changes will be notified to you directly.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5. Third Party Links, or Links Away from SMDA website

The SMDA website may also include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

6. The Data SMDA Co Collects About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may process different kinds of personal data about you such as:

  • Identity Data – this includes first name, last name, title.
  • Contact Data – this includes company address, email address and telephone number.
  • User Account Data includes username and password for SMDA website.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, and the devices you use to access this website (such as smart phones, laptops or desktops).
  • Usage Data – this includes information about how you use or navigate our website, products and services.

SMDA Co does not, and will not, collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) nor do we collect any information about criminal convictions and offences.

If you are approached by someone pertaining to be from SMDA Co, or, if a webpage that appears to be SMDA Co marked, asks for Special Categories of Personal Data or information relating to criminal convictions and offences, we ask that you contact us via DataProtection@gemserv.com immediately.

7. How SMDA Co Collects Your Personal Data

We use different methods to collect data from and about you, including the following:

  • You may provide use with your personal, business and contact information by filling in forms. This includes personal data you provide when you:
    1. Apply for our services through our SMDA member form;
    2. Send an enquiry to us through our Contact Us form;
    3. Provide information via a survey;
    4. Register a User Account on our website
  • When you interact with our website, we may automatically collect Technical and Usage Data. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
  • We may also receive personal data about you from various third parties and public sources as set out below:
    1. Technical and Usage data from Analytics providers such as Google;
    2. Identity and Contact Data from publicly available sources such as Companies House;
    3. Identity and Contact Data from Government departments and bodies such as BEIS, Ofgem, Ofwat etc.
    4. Identity and Contact Data from our testing houses.

8. How SMDA Co Uses Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to perform contractual obligations and where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Below we have listed the ways describing reasons we use your personal data for and the legal basis we rely on to do so.

Please note that we may process your personal data for more than one lawful basis depending on the specific purposes for which we are using your data.

Purpose Type of Data Lawful Basis for Processing
  • To process your applications to become SMDA members;
  • To facilitate your participation in our meetings and to provide our services to you;
  • To process invoices;
  • To manage our relationship with you, including notification about changes to our privacy policy and services, manage any concerns or requests that you raise to us;
  • To process your application for device testing
  • Identity and Contact Data
  • Performance of contractual obligations set forth in the SMDA Membership Joining Pack;
  • Necessary for our legitimate interests allowing us to provide our customers with requested information and services
  • To complete a survey for purely research and statistical purposes
  • Identity and Contact Data
  • Necessary for our legitimate interests allowing us to study how customers use our services and to help us to develop it
  • To use data analytics to improve our website, services, customer relationships and experiences, and to secure our website
  • Technical and Usage Data
  • Necessary for our legitimate interest to keep our website updated and relevant to customers

9. Cookie Policy

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. Cookies allow us to store your preferences to correctly present content, options or functions throughout our website. They also enable us to see information like how many people use our website and what pages they tend to visit.

Overall, cookies help us to provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you would like more information about this practice, including how to prevent it, please visit www.aboutcookies.orgwww.allaboutcookies.org or optout.networkadvertising.org

The following is a list of the cookies set by our website, and what each is used for:

  • Google Analytics (_ga) – used to understand how users navigate through our website; the service is provided by Google Inc.;
  • Google Maps – Google may set cookies to store information and preferences about maps or other associated Google services on pages where Google maps are embedded;
  • WordPress (WordPress_sec, wordpress_logged_in, PHPSESSID, euCookie, wpfuuid) – these cookies are required by our website software and store no personal information;
  • Security software cookies (wfvt_, wordfence_verifiedHuman) – used by our security software to protect the Website against malicious attacks.

We then use the information gathered to compile reports to improve the functionality and user experience of our website. All information collected is anonymous.

10. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your information for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and where there is no confliction with the requirements of the GDPR or Data Protection Legislation.

11. Disclosure of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in in Section 8. This could include:

  1. Designated Test Houses.
  2. External service providers, including data storage, website hosting and website service providers.
  3. Companies House when we have to provide mandatory information in relation to SMDA governance.
  4. Third parties that we may choose to sell, transfer, or merge parts of our business or our assets with.
  5. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners can only use your personal data in the same way as set out in this privacy notice.

We require, and demand, that all third parties respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. International Transfers

SMDA Co does not transfer your personal data outside of the European Economic Area (EEA). Should this situation change then we will always ensure you are made aware prior to the commencement of international transfers.

13. Data Security

Gemserv is accredited to the Information Security Management Systems standard ISO27001:2015. This means we have a robust framework of policies and procedures that includes all legal, physical and technical controls involved in an organisation’s information risk management processes.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting Us.

15. Glossary

As mentioned at the start of this notice the following will provide useful definitions to help you better understand some of the legal terms associated with data protection and our responsibilities in protecting your data

Lawful Basis

  1. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
  2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  3. Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your Legal Rights

As previously mentioned, you can find further information about your legal rights. For a more detailed information please visit the ICO’s webpage.

  1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data for certain scenarios.
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
  7. Withdraw consent at any time where we are relying on consent to process your personal data. This would be possible in a situation whereby we are processing your data based upon us gaining your consent.

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