Effective Date: 5 October 2023
We, meaning National Grid Electricity System Operator Limited (“ESO”), who can be contacted at Warwick Technology Park, Gallows Hill, Warwick CV34 6DA, are committed to respecting your privacy and complying with applicable data protection laws. This notice outlines how “we” collect and use your information.
When may we collect personal information about you?
We may also collect information about you from public sources, for example from the Land Registry, or receive it from other National Grid Group companies, joint venture partners, third parties, or service providers contracted to carry out work on our behalf.
What personal information may we collect about you and how will we use it?
We may be required by law to collect certain information to perform a contract, or prior to entering into a contact with you; or use it for our legitimate business interests where these do not override your rights or interest; and where appropriate, with your consent.
The following sections explain the different ways we may use your personal information and our legal basis for doing so.
Where we have a Legal Obligation
We are required under the Planning Act 2008 to request your views on planning proposals for large scale infrastructure development projects if they are likely to have an effect on you. For smaller projects where we are not under obligation to consult, we may still seek your views on proposed developments to help inform our decisions.
You may choose whether to respond to such requests. If you do respond we will use your name and home or business contact details – including postal address, email address, and landline or mobile number – to contact and update you on progress of the project.
We will also keep a record of your contact details and consultation feedback as required by laws governing the planning application process.
If you are a landowner and we are unable to negotiate a voluntary agreement regarding land rights for the construction, access to and maintenance of our infrastructure then we may exercise our powers under the Electricity Act 1989 in order to obtain either a ‘necessary way leave’, or obtain land rights by compulsory acquisition.
This will involve processing of your contact details - including postal address, email address, and landline or mobile number – along with details of your land ownership or occupation.
If you hold shares in National Grid plc, we have obligations under the Companies Act 2006 to collect and use personal information to keep a register of members, provide you with share certificates or other evidence of your shareholding, and contact you regarding your rights to attend and/or vote at the Annual General Meeting. For more information about what we use and why see our Shareholder Privacy Notice.
If you are contracted by one of our suppliers and service providers to carry out work at a site where high pressure gas is stored or transmitted, we will keep records of your job title and the results of any training, qualifications, certificates, professional licences or memberships that demonstrate your competence to work on site and/or to restricted access to areas of a particular site, for example by issuing you with an access card. Competency records are kept in electronic and hard copy format and may in some cases include voice recordings of assessments. This information is used to demonstrate compliance with the Control of Major Accident Hazards (CoMAH) regulations, our obligations under Health & Safety at Work legislation, and our Operating Licences.
Where it is Contractually Necessary
If you are a landowner or tenant and a project that affects your land has received planning permission then we will attempt to reach an agreement with you regarding access to construct, assess the condition of, maintain, repair, or replace our assets. In order to reach such a voluntary wayleave or easement agreement it will be necessary to process your contact details - including postal address, email address, and landline or mobile number – along with details of your land ownership or occupation.
If you are a landowner or tenant and one of our construction projects results in loss of or damage to your land – for example loss of crop yield, grazing land, or damage to drainage or access roads – you may be entitled to claim compensation from us. In order to process your claim we require details of the land you hold interest in and evidence to support your claim – for example photographs and financial statements / forecasts.
If your claim is successful, we will need to process your bank details to make compensation payments. We will also keep records of amounts paid.
In the event you have applied for a job at the ESO, we use the personal information you submit to process your application.
If you are a customer, supplier or service provider we need to process certain data items, such as your name, postal address, phone number, email address and bank account details in order to provide goods and services to you and receive payment, or receive goods or services from you and pay you for them.
Where we have a Legitimate Business Interest
If you contact us with a query or complaint about any of our activities, we will record the details of your request, and if we are unable to immediately resolve the matter, we will ask you to provide contact details of your choice - such as a telephone number, email, or postal address - which we will use to contact you with updates when we have investigated the matter further.
We provide a helpline where you can contact us if you have any questions regarding the effects of Electromagnetic Fields (EMFs) and noise resulting from the operation of the electricity network. We use the preferred contact details you provide us (your email address, home or personal mobile number, or postal address) to respond to your queries and provide advice. Where you choose to provide it, we also process information about any actual or perceived physical health effects resulting from EMFs, and, if your enquiry relates to effects on children, details of the number and ages of children in your household.
We use aggregated data, based on the information you provide to us, for scientific research and statistical purpose with regard to the effects of EMFs and ways of mitigating them. We share this aggregated data with the Energy Networks Association. We do not share any personal information for this purpose.
When you visit one of our sites you will be asked to provide your name and contact details in order to be issued a visitor access card. These cards record the dates and times you enter and leave a particular site or part of a site. If you have requested a parking space on one of our sites, we will also record your vehicle registration number.
We use CCTV cameras to monitor the interior of, entrances to, and perimeter of our sites to enable us to respond to security incidents. Footage from some cameras is monitored remotely in real time to facilitate responses to security or safety incidents. All cameras – monitored or otherwise – will store recordings of the footage, which may be reviewed at a later date and used as part of a security or safety incident investigation. If the footage captures evidence of an offence being committed, we will share this with the police.
CCTV is also used on some of our sites to monitor the opening and closing of automated or remotely operated gates or barriers to ensure you are not trapped or injured.
All of these measures are in the interest of your safety and wellbeing.
If you submit a DSAR we will search all systems and relevant hard copy data stores and retrieve the information that you request. We will hold copies of your request, along with copies of the information retrieved and disclosed to you (or, subject to the application of a valid exemption, withheld or redacted) as evidence of compliance. We may be required to share with the Information Commissioners Office (ICO) if required, for example to comply with an audit or investigation. Where we hold any special category personal information as such evidence we do so on the basis of establishing, exercising or defending legal claims.
Your voice may be recorded when making calls to some company numbers, for example helpdesks and trading desks. You will be informed at the start of the call if the call is to be recorded. We use these recordings to monitor compliance, conducting safety investigations, and for training purposes.
Where you have provided your Consent
Where we need your consent to hold your personal information, we will ask you separately to confirm your consent, either by a written statement or other ‘opt-in’ mechanism, such as ticking a box or clicking on a button. In each case we will inform you separately from this notice about why we are collecting the information, how we will use it, how long we keep it for, and how you can subsequently opt-out if you change your mind.
Where you have given your consent, we use your personal information for the following purposes.
If an electricity project is being proposed in your local area, we may invite you to sign up to receive information and updates on the project. If you provide your name and email address, we will use this, with your permission, to send you project updates. You may opt-out of receiving updates at any time: you will be informed of how to do so in each email we send you.
We also use third-party cookies that help us analyse and understand how you use this website, to store user preferences and provide content and advertisements that are relevant to you. These cookies will only be stored on your browser with your consent to do so. You have the option to opt-out of these cookies, but opting out of some of these cookies may have an effect on your browsing experience.
By registering for an ESO Account on the ESO website, you have access to a personal dashboard. Here, you can manage subscriptions to data portal updates, and other personalised information.
You consent to sharing you first name, last name and email address to create an Account. Alternatively, you can login via an existing Microsoft Account. Your email address will be verified via a one-time verification code, which will be sent to you, from our customer identity access management provider. Accounts that are not verified successfully will be deleted within 7 days of creation. Accounts that are inactive for a period of one year will be deleted.
Some areas of our ESO website invite you to sign up to receive emails containing information that you may find useful, for example regarding system balancing, power response, and future projects and developments in the electricity market. If you sign up to receive such emails, we will send them to the nominated email address you provide. If you decide that you no longer wish to receive these emails you may unsubscribe at any time via the ‘unsubscribe’ link within each email.
You can sign up via the ESO website to receive email updates on live datasets on the Data Portal too. If you decide that you no longer wish to receive these emails, you may unsubscribe at any time via your ESO Account.
If you subscribe to receive SMS notifications via the ESO website, and you provide us with your telephone number, you will receive service SMS notifications when a live dataset on the Data Portal is updated. If you decide that you no longer wish to receive these notifications, you may unsubscribe at any time via your ESO Account. You will not receive any SMS notifications for marketing purposes.
Through your ESO Account, you will be able to register and login to the SMP and EAC via multi-factor authentication (MFA). MFA is an additional security measure to protect access to our systems and services. This means that you have to provide another method of identification, after entering your login details, before being able to access SMP and EAC.
We will collect your email address and mobile phone number to carry out MFA.
Your name, email address and mobile number are shared and kept up to date between your Account, SMP and EAC.
Video, audio and photographs of you taken at one of our sites or public events, to market our services via multiple media channels such as TV, our website, hard copy publications and social media.
Who may we share your personal information with?
Your information will be processed by employees of ESO and may also be shared with the following parties:
- Employees or contractors working on our behalf of or in partnership with ESO.
- External suppliers and service providers who perform functions on our behalf under contract, or support our systems, operations and/or processes. These include External Affairs Agencies collecting consultation feedback in relation to planning applications; Land Agents negotiating wayleave and easement agreements and processing damage claims and compensation payments.
- Consultation feedback obtained during the planning application process will be shared with the Secretary of State, Examining Authority, and members of the public who request access.
- We may also be required to share your personal information with law enforcement or other regulatory bodies who request access to information about you for the prevention and detection of crime and the apprehension or prosecution of offenders.
- We might have to share personal information with government bodies and agencies to meet our legal and regulatory obligations. When we share your information with other organisations we’ll make sure it’s protected as far as reasonably possible.
Where we use another organisation to process your personal information on our behalf we are still the Controller with regard to that information and have strict controls in place to make sure it’s properly protected.
As ESO is currently part of the National Grid Group, which operates globally, it may be necessary to transfer your data to other National Grid companies outside the UK, for example those based in the USA. Any such transfers will be subject to the relevant Data Protection laws and National Grid’s data security policies.
Retention periods will vary depending on the purpose for which we hold your personal data, but information will only be kept for as long as necessary in relation to the purpose for which it was collected.
- Consultation feedback obtained as part of the planning application process will be kept for the life of the particular asset (if constructed); otherwise for 7 years from the date the Decision Notice is issued.
- Deeds of Grant of Easement are retained for as long as we maintain interest in the land in question.
- Wayleave agreements will be retained for the term specified in the agreement, or until you cease to own / occupy the land in question.
- Details of damage claims and compensation payments for 7 years from the date of settlement.
- Customer enquiries and complaints correspondence is kept for 6 years.
- Health, Safety and Competency Records are kept for 6 years
- Customer, Supplier and Service Provider Data is kept for 6 years
- Visitor logs are kept for 3 years
- CCTV footage is generally kept for 30 days before being overwritten, but if required for an incident investigation may be extracted from the system and kept for as long as necessary in relation to that investigation
- Data Subject Access Request data is kept for 3 years
- Email addresses used to provide project updates / system notifications are kept either for the duration of the particular project, or until you unsubscribe – whichever is the earlier
Your rights are outlined below:
- The right to access information we hold about you, why we have that information, who has access to the information and where we obtained the information from.
- The right to correct and update the information we hold about you. If the data we hold about you is out of date, incomplete or incorrect you can inform us and your data will be updated.
- The right to have your information erased. If you feel we should no longer be using your data you can request that we erase the data that we hold. Upon receiving a request for erasure we will confirm whether it has been deleted or a reason why it cannot be deleted (for example because we have a legal obligation to keep the information or we need it for a legitimate business interest)
- The right to object to processing of your data. You may request that we stop processing information about you. Upon receiving your request we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Even after you exercise your right to object, we may continue to hold your data to comply with your other rights or bring or defend legal claims.
- The right to data portability. You have the right to request that we transfer your data to another controller. This right does not apply where we have a legal obligation or legitimate interest for processing, as set out in the notice above.
- The right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- The right to withdraw consent at any time where we are relying on consent to process your personal data.
To exercise your privacy rights please send your request in writing. We may be required to verify your identity for security purposes.
To exercise your rights by email please send your request to:
Alternatively, please write to us at:
Data Protection Team
National Grid House
Warwick Technology Park
We will comply with your request where it is feasible to do so, within one month of receiving your request. There are no fees or charges for the first request. However additional requests for the same data may be subject to an administrative fee to cover our costs.
At ESO we aim to ensure all information collected about you is done so fairly and lawfully, whilst implementing robust measures to keep your information secure. If you are not satisfied with the information provided in this notice, please contact us in the first instance so we can resolve your queries or provide you with any additional information required.
Alternatively, it is your right to contact your local Data Protection Authority and lodge a complaint. In the UK the lead Data Protection Authority is the Information Commissioner. For more information, please visit the Information Commissioner’s office at www.ico.org.uk/concerns or call them on 0303 123 1113.