The Data Usage Policy of Watts Electrical

This policy explains how, when and why we collect your personal information during the course of providing services to you, under what situations we may disclose your personal information to others, and how we keep it secure.

Who holds responsibility for data?

As a Sole Trader and a one person organisation, responsibility for the control of data lies with Mark Watts of Watts Electrical. Mark Watts is therefore the Data Controller and Processor.

What data is recorded and how is it held?

We need to collect information about you to offer the right range of products and services for your circumstances.

Customer's and Supplier's data are both held; this is personal data in the form of name (and possibly preferred form of address), billing address and (if different) delivery address, contact numbers and email address. It may be possible to infer from this data that some Customers may own more than one property or to identify the addresses worked at by Watts Electrical as a sub/co-contractor to other contractors

All the above information is held using Intuit's software accounting package “Quickbooks Pro 2015” which runs on a laptop which rarely if ever leaves the address of the office. A copy is made to an external hard drive to ensure continuity of service in the event of a failure of the laptop.

In future such accounting data may be migrated to another software package which may or may not be 'Cloud' based. If that is the case, only a well-known, reputable software package/system will be used.

Information is collected during and for the purposes of creating and submitting Electrical Installation Certificates, Minor Electrical Works Certificates and Electrical Installation Condition Reports. This information is initially recorded in hand-written form on paper before being transferred via the laptop mentioned above to the NICEIC website. Once transferred to the NICEIC the hand-written originals are shredded and then composted on site. Completed forms reside on the NICEIC computer and are subject to their custody as Data Processors. Some completed forms are downloaded back onto the laptop to enable quick access for future reference eg. as when further works may be requested/required to a recently modified installation. No paper copies of Electrical Certificates are held.

What is the data used for?

The data collected in the form of address and contact details is used for the following purposes:

to create estimates and invoices

to create Electrical Installation Certificates and to issue Certificates of Building Compliance to Building Control.

On which lawful bases for processing is data used?

Data is used under the following legal bases:

Contract; the use of your information is necessary to perform a contract – eg. for customer name, billing address or location of works.

Legal obligation; the processing is necessary for compliance with the law – eg. for Electrical Installation Certificates and notification of Certificates of Building Compliance; as a necessary adjunct to proper and correct financial record-keeping to enable accurate submissions to be made to Her Majesty's Revenue and Customs (HMRC).

Legitimate interests; the processing is necessary for our legitimate interests eg. to ensure payments are received or the recording of supply characteristics for subsequent works.

What happens to the data collected?

Watts Electrical sends Invoices and Bills to HK Accounting Services for book-keeping where it is anonymised and forwarded to our Accountants. Watts Electrical may be legally obliged to give HMRC access to such Invoices.

Electrical Certificates and Building Control Notifications are handled by Certsure LLP trading as the National Inspection Council for Electrical Installation Contracting (NICEIC).

Information held by Watts Electrical is not knowingly or deliberately shared with any other party. Watts Electrical will never exchange Customer's information with third parties for marketing purposes.

What are the Rights of the Individuals to whom the data relates?

Customer's data which is five years or more old will be destroyed. This includes name, address, transaction history and Electrical Certificates.

Customers may request to see the data held on them at any point in time; they may ask for any errors to be rectified; and they may ask for copies for themselves. They may also request the destruction of such data.

All of this should be free of charge but a charge can be made for requests which are manifestly unfounded; if a request is refused the individual must be told why and that they have the right to complain to the ICO and to a judicial remedy. This must all be done within 30 days

Data Breaches

We work hard to keep your data safe. We use an appropriate combination of technical and organisational measures to ensure, as far as reasonably possible, the confidentiality, integrity and availability of your information at all times. If you have a security-related concern please contact us.

Data breaches will be reported where it is likely to result in a risk to the rights and freedoms of individuals eg. it may result in financial loss or loss of confidentiality.

What do Watts Electrical do to reduce the risk of breaches?

Watts Electrical takes the following steps to reduce the risk of data breaches;

1.Keeping the Operating System of the laptop up to date:- update set to fully automatic

2.Use 'Windows Defender' as the anti-virus software and keep it automatically updated; carry out full computer scans regularly

3.Keep the Accounting software used up to date

Retaining your data

The information we collect about you is subject to various regulatory and legislative requirements. In addition, we will endeavour not to keep your personal information for longer than we have to for us to fulfil our obligations to you. Where it is not possible for us to delete your data, we will ensure the appropriate security and organisational measures are put in place to protect the use of your data.



We work hard to ensure that your personal information is treated safely and securely. If you have a complaint, please talk to us. You also have the right to complain to the Information Commisioner's Office.

Changes to our Privacy Policy

We review our Privacy Policy regularly and will place any updates on our website.

Mark Watts

For and on behalf of Watts Electrical

This revision dated 21-5-18


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