Start Energy Limited is an Energy Consultant offering Business Energy to Business customers.
We are registered in England and Wales under reg number 07536260, our office is located at 3 Fern Court, Bracken Hill Business Park, Peterlee, SR8 2RR
Start Energy may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
For the purpose of applicable data protection law including the Data Protection Act 2018 and, from its entry into force on 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/679) (together, the “Data Protection Law”), the data controller is Start Energy, Unit 3 Fern Court,
Bracken Hill Business Park, Peterlee, County Durham, SR8 2RR. This policy is effective from 25th
May 2018, to be reviewed again by the Data Protection Officer by 25th
November 2018, at the latest.
- Why we use your personal information
- Why you receive marketing
- The right to object to marketing
- How we use your personal information
- How long we may keep your information
- Links to other websites
- Your rights under data protection legislation
- How to exercise your rights
- Contact details for our Data Protection Officer
- What personal information we collect
- The legal basis for processing
- Sharing personal information with third parties
- The Supervisory Authority
What we collect
We primarily collect personal data directly from you. You may provide us data for example by contacting us, submitting a website form, applying for a job, subscribing for marketing, or downloading or uploading material.
If we contact each other by telephone, we will record and keep a record of all inbound and outbound calls to and from Start Energy.
In order to provide the necessary service of helping you reduce business utilities consumption and cost, the personal data we collect from you and process is:
- your name and job title
- your contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers.
When you call a number displayed on the website, your phone number is collected and stored. More information on this can be found within the sharing information with third parties section.
Some of the information collected on the website relates to your business and not you as an individual so is not classed as personal data however, for sole traders and those working in partnership (i.e. not those employed by or directing limited companies) it will be considered to be about you and therefore constitutes personal data. This data is:
- utilities consumption cost and usage
If you are interested in joining the Start Energy team we ask you to provide your email address and CV via the website.
When you choose not to provide information, please note that we might not be able to carry out an action you have requested.
Why we use your personal information
The information collected from you will be used to provide you with the products and services we can offer you and to allow us to develop our business relationship with you.
We process your personal data for the following purposes:
- to understand your business needs and provide you with a better service
- to provide you with a response to your enquiry, including a request for a call back
- to provide you with the quote you have requested
- for the ongoing administration of any service we provide you and to carry out any ongoing obligations we owe to you
- for internal recording keeping to assess and maintain compliance and to meet our legal obligations
- to allow us to improve the products and services we offer to you and to notify you of any changes to products and services
- to develop, enhance and customise the website according to your interests
- to offer new products and services to you which are relevant and appropriate, and only to the extent that would be reasonably expected and in accordance with the marketing preferences you have indicated. You can change your marketing preferences at any time by contacting us on
- to progress your interest in a job vacancy
- to measure or understand the effectiveness of advertising we serve to you, and to deliver relevant advertising to you (with your consent where relevant)
- to ensure our records are accurate and up to date
- to administer our legitimate internal management analysis, audit, forecasts and business planning and transactions
- to establish, defend or exercise our legal rights
- to comply with our legal, regulatory and internal governance obligations
- to prevent or detect crime, for quality, training and security purposes; and
- market research and analysis and developing statistics.
The legal basis for processing
Under Data Protection Law, there are various grounds, which are considered a ‘legal basis for processing’. The legal basis for processing should be determined by the Data Controller.
Start Energy are the Data Controller for the information that is processed on the website and marketing you receive from us. The legal basis for processing the information is based on:
‘processing is necessary for the purposes of legitimate interests pursued by the controller’
It is in our legitimate business interest to keep our customers and contacts informed of our latest products and services and administer the service requested.
Start Energy is a business utility consultancy, and the information processed on the website allows us to offer services to help reduce businesses utilities consumption and costs. If you submit a form, call us or request a call back, this will be taken as agreement that Start Energy and our affiliate companies
have a legitimate purpose to contact you regarding the enquiry.
For those wanting to apply for a role at Start Energy or one of its affiliate companies the submission of your details will be taken as agreement that Start Energy has a legitimate purpose to contact you regarding your interest and shall enable them to include your CV within the recruitment and selection process.
We also process business contact details, to use for direct marketing purposes, as part of our legitimate interest. We believe this to be an appropriate lawful basis as individuals might reasonably expect to receive marketing in this context. It is a reasonable and proportionate method of processing to achieve commercial objectives whilst having a low impact on the privacy of the individual. Anyone receiving direct marketing has the opportunity to object to receiving marketing from us. More information about why you receive marketing from us is detailed below.
It should be noted that in some circumstances this legal basis may vary, however, we always operate in full compliance with Data Protection Law and will only process data with a fair and reasonable legal basis for doing so.
Why you receive marketing from us
We currently obtain business contact details from Data HQ, and use this information to undertake live calls and / or email marketing. We receive the following business data; Company name, address, telephone number, contact name, job title and email address.
We also communicate information about our products and services to existing customers and those who have opted in to receive such information.
We abide by the obligations provided for by The Privacy and Electronic Regulations 2003 and the General Data Protection Regulations 2016, in regards to business-to-business marketing.
Before making live calls we screen the numbers against the Telephone Preference Service (TPS), Corporate Telephone Preference Service (CTPS), or those that have previously objected to receive calls and marketing.
We include the option to Unsubscribe on our marketing emails, and endeavour to only send marketing emails to sole traders and partnerships if they have consented to such communication.
We respect anyone’s decision to object to marketing, information about how to do this is provided below.
The right to object to marketing
At any time, you have a right to object to the use of your information for marketing purposes.
To object, tell the member of the team who contacts you, or email your objection. Include your name, business name, contact details and that you object to your information being used for marketing purposes.
We will keep a record of your request to ensure we no longer market products and services to you.
If it is just email marketing you wish not to receive, you have the option to click the ‘unsubscribe’ link at the bottom of the marketing email.
How we use your personal information
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and store.
The access to information provided is given to those employees who require the information to carry out the required services. A couple of examples have been provided below.
If you are interested in our products and services, the inbound and outbound sales team will have your information to make the initial contact. Where you decide to engage us to provide you with the services and products, this will be progressed by the sales support team and then transferred to customer care. When it gets close to your contract coming to the end, a member of the renewal team will contact you. We do have a compliance and legal team who will have access to the information as and when required.
The data team manages the data for the marketing campaigns including details of those that have objected to marketing; with the marketing team having access to certain information that will help inform the marketing strategy.
If you are interested in joining the team, your information will be accessed by the People Operations team and those involved in the recruitment and selection process.
Sharing personal information with third parties
We will not
sell your data to third parties. Should you decide to engage us to provide services or products to you, we may be required to share information with various third parties to provide you with services or products, including but not limited to Utility Suppliers. Where this is the case, you will be informed.
We do use third parties to help us manage the website, provide you with the relevant services and inform our marketing strategy. Such service providers are only allowed to process your personal data to the extent necessary for them to provide the service we have requested from them. They are not allowed to use your personal data for the benefit of their own business. In order to protect your privacy, we require that our service providers keep the personal data they process on our behalf confidential and adequately secure. They are required to abide by data protection legislation.
We may share your personal data to comply with any legal and regulatory obligations, or in order to enforce our apply our terms and conditions and other agreements.
We may also share your personal data with regulatory authorities, courts and governmental agencies to comply with legal orders, legal or regulatory requirements, government requests and other lawful requests. We may also share your personal data with our legal and other professional advisors.
We may share your personal data in the event that we sell any or all of our business or assets, or sell any companies in our group, in which case we may disclose your personal data to the buyer or to the prospective buyer(s) os such business or assets or companies in our group.
How long we may keep your personal information
We store personal data for as long as is necessary to deliver and manage the requested service and business relationship, to comply with legal, compliance and audit obligations, resolves disputes and enforce agreements, and then securely delete the information.
We keep your personal data for marketing purposes for as long as you want to receive marketing from us. If you decide to opt-out or where we rely on consent for processing, withdraw your consent to our marketing, we will no longer use it for this purpose. If the data is not needed for some other purpose, (e.g. to maintain details of a business transaction such as a transfer of your utilities) we will delete the majority of data without undue delay. Certain details are retained to ensure that your request is adhered to.
Our Data Protection Officer is working with relevant sections to determine specific retention periods that will be published in the future.
How we use your personal data
In this Section we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
We may process data about your use of our website and services (“website usage data”). The usage data may include:
- your IP address;
- geographical location;
- browser type and version;
- operating system;
- referral source;
- length of visit;
- page views and;
- website navigation paths
As well as information about the timing, frequency and pattern of your service use.
This website usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website experience and services.
We use Google Analytics to measure website performance. This is a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate use of those services and compile a report for us. We use Performance cookies across our website for internal purposes to help us to provide you with a better user experience.
Information supplied by cookies helps us to understand how our visitors use our website so that we can improve how we present our content to you.
You can find out more about cookies and how to, manage or disable them at http://www.aboutcookies.org/default.aspx
Links to other websites
Our website may contain links to other 3rd party websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Your rights under data protection legislation
In regard to the information collected and used by you can object or where the processing is based on consent withdraw your consent to the use of your personal data at any time. Though in some cases we may not be able to provide your requested service (e.g. provide a quote and work with energy suppliers to help you reduce your business utilities consumption and cost) where the information processing is an integral part of the service. We will tell you if this is likely to be the case.
You have the right to:
- request a copy of the personal information we hold about you;
- to have any inaccuracies corrected;
- to have your personal data erased*;
- to place a restriction on our processing of your data*;
- to object to processing*, including the right to object to marketing; and
- to request your data to be provided to you in a structured, commonly used and machine readable format suitable for transferring to another controller (data portability)*.
*Please be aware that not all of these rights are absolute, and are only applicable in certain circumstances, so in accordance with the law there will be occasions where a refusal notice is issued or exemption applied.
To learn more about the rights and when they apply, please see the ICO website
How you can exercise your rights
You can contact the Data Protection Officer with regard to any issues related to the processing of your personal information, including exercising any of your rights or making a complaint.
We encourage people to bring to our attention any instances where they think our collection, or use of, information is unfair, misleading or inappropriate.
Contact details for our Data Protection Officer
You can exercise your other rights by completing our Rights form and emailing it to firstname.lastname@example.org
Alternatively, you can contact the Data Protection Officer by:
Data Protection Officer
3 Fern Court,
Bracken Hill Business Park
Peterlee, County Durham, SR8 2RR
Please state clearly that your request concerns a data protection matter, and provide a clear description of your requirements.
Note: We may need to request additional information to verify your identity before we action your request.
The Supervisory Authority
The Information Commissioner’s Office (ICO) is the UK’s independent body set up to uphold information rights. You have a right to lodge complaints with them, including when you are dissatisfied with our response to you.
To find out more about them, visit https://ico.org.uk/about-the-ico/who-we-are/
. To contact them, either visit their website, dial 03003 123 1113 or write to them at:
Information Commissioner’s Office