OFGEM PRIVACY NOTICE
The Office of Gas and Electricity Markets (Ofgem) has commissioned a research agency, Close-Up Research, to capture the experiences of different energy customers through video diaries and video interviews.
The aim of the project is to help Ofgem better understand the experiences of a range of different energy customers. We want to understand better where energy fits in to customers lives, what their individual energy needs are, how they use energy and their experiences when choosing tariffs or interacting with energy suppliers and the market.
The result will be two or three short films for internal Ofgem use only. The footage won’t be shown on TV or publically online. And we won’t use the footage for any other purposes, or share your contact details with anyone else.
If you decide to assist us with this research, Ofgem and Close-Up Research may need to collect and use your personal data at different stages of the research project.
The General Data Protection Act (GDPR) gives individuals the right to be informed about the collection and use of their personal data. That is what this privacy notice is for; in this privacy notice, we explain our research project and how your personal data might be used if you choose to take part.
What is personal data?
Personal data is information that relates to an identified or identifiable individual – for example, your name and contact details.
Who is Ofgem?
Ofgem is the Office of Gas and Electricity Markets. We are a non-ministerial UK government department and an independent National Regulatory Authority.
Our aim is to make a positive difference for energy consumers, and our principal duty when carrying out our functions is to protect the interests of existing and future electricity and gas consumers. This informs our whole approach to regulation in Great Britain and the way that we work with stakeholders. It obliges us to evaluate almost any situation or proposed change through the lens of energy consumers.
You can find more information about Ofgem at www.ofgem.gov.uk.
THE RESEARCH PROJECT
Who is Close-Up Research?
Close-Up Research is a research agency specialising in ethnographic research and video. Ofgem has appointed Close-Up research to recruit and interview participants on our behalf in this research project. You can find out more about Close-Up Research at their website: www.closeupresearch.com
Why have I been selected for this research?
Our purpose for collecting and using (or “processing”) your personal data in this research project is as follows. We want to understand your experiences of the energy market and see where this fits in to your life.
You have been selected for this research because you have been identified as a customer type we particularly want to hear from. We are talking to energy customers in the following segments:
Heat network customer
Electricity only rural customer
Family with a child or children under the age of five / kids under 5
Prepayment meter customer
Electric vehicle customer and/or a customer with photovoltaic (solar) and/or a storage battery
Young London first time bill payer (renter or home owner)
A customer of a larger supplier
A customer of a smaller/new entrant supplier.
If Close-Up Research contacts you on our behalf, it is because we would like to hear more about your views on and/or experiences in the energy market.
What if I do not wish to participate?
You can of course choose not to take part in the research project; if so, no more of your personal data will be processed by us or by Close-Up Research in this project.
Why are Ofgem and Close Up Research processing my personal data in this project?
If you agree to participate in this research project, we will be processing your personal data as part of our research. The types of personal data which we will or may process in this research project are set out below. We must always ensure that our processing of personal data is lawful, fair and transparent, and that it complies with all the other principles and requirements of the GDPR. To ensure that our processing of personal data in this research project is lawful, we need to identify a “lawful basis” for processing it. These are requirements under Article 5 and Article 6 of the GDPR.
Ofgem will process personal data in this research project under the ‘public task’ lawful basis for processing (Article 6(1) (e) of the GDPR). This is where the processing of this information is necessary for the performance of a number of our statutory functions For example, this research project is partly being carried out on the basis of our legal powers in the Gas Act 1986 and the Electricity Act 1989 which relate to policy development regarding domestic energy consumers, and which may result in us making proposals to modify the licence conditions which energy suppliers must abide by.
The types of personal data Close-Up Research will process under this lawful basis will be your contact details, so that it can contact you.
Close-Up Research will be conducting the research interviews and editing video footage on our behalf and will only do so with your informed consent. As explained above, you can of course choose not to take part in the research project. The lawful basis for Close-Up Research and Ofgem processing personal data from the interview(s) with you is consent (under Article 6(1)(e) of the GDPR). Close-Up Reearch will therefore only collect, store and transfer (to Ofgem only) your personal data with your consent, and this will be explained to you beforehand. More information about consent is provided below.
How will Close-Up Research contact me?
Close-Up Research will initially contact you by telephone or email. If you consent to be interviewed in this research project, it will conduct interviews either by telephone or via an internet based platform (e.g. Zoom).
What information will I be given when I am first contacted?
When you are contacted by Close-Up Research, they will explain to you:
- why you are being contacted and the purpose of our research project
- the different stages of the research project
- what your participation in the research would involve
- if you agree to participate, how your personal data will be used and your rights in respect of that data
- who the relevant Ofgem and Close-Up Research points of contact are for this project (see below) if you have any questions at any point
- that it is your choice whether or not to take part in the research and, if you do take part, how you may withdraw your consent at any time.
If I take part, what could I be asked to do?
If you agree to take part in the research, Close-Up Research will provide you with information about participation over the course of the project, either via telephone or through an internet based platform at a time that suits you. You will be asked to provide monthly vlogs about your experience in the energy market. You will also be conteacted by Close-Up Research to take part in an interview via the internet.
USE OF YOUR PERSONAL DATA IN THIS RESEARCH PROJECT
What types of personal data will be processed?
The types of personal data which Ofgem and Close-Up Research will process in this project are:
- your contact details – so that Close-Up Research can contact you about the research project
- Your experiences and thoughts about the energy market
Under the GDPR certain personal data is treated as being more sensitive. This includes:
- personal data revealing racial or ethnic origin
- personal data revealing political opinions
- personal data concerning health.
None of the questions you will be asked in the research interviews will require you to disclose any such sensitive data because we do not need it – it is not necessary for or relevant to this research project. However, we acknowledge that this type of data might nonetheless be volunteered by a participant in the research interviews, or be able to be inferred by the Close-Up Research in conducting the interviews and by Ofgem in viewing any video recordings. For example, if asked about wider energy issues in Great Britain, a participant might disclose a political opinion. We mention this just because processing by Close-Up Research or Ofgem of sensitive data requires your explicit consent. This will be explained to you before any research interview.
Will my responses to the research be confidential?
Only your first name will be made known to Ofgem. All other personal data collected during the interviews/vlogs will remain completely confidential and will not be made public. Your vlogs and interview responses will be analysed by Ofgem and Close-Up Research, and held securely by Ofgem and Close-Up Research for the periods of time set out below. A collated and edited video of vlogs and interviews from this research project, which will not include any of your personal data, will be used internally at Ofgem and shown to its employees only. It will not be published externally on the Ofgem website.
Who will receive my personal data?
Only members of the Consumer and Behavioural Insights team in Ofgem and Close-Up Research. No other party will receive your personal data.
Who controls my personal data in this research project?
If you agree to take part in the research interviews, both Ofgem and Close-Up Research will be joint “data controllers” in relation to any personal data processed in the course of the interviews, or when analysing the results of the interviews. This is because Close-Up will be conducting the interviews and editing film output on our behalf for the purposes of this research project. Ofgem and Close-Up Research have agreed a project-specific joint controller agreement, as required under the GDPR. The joint controller agreement sets out:
- that Ofgem and Close-Up Research are required to keep your personal information secure and accurate
- that Ofgem and Close-Up Research must comply with data protection law at all stages of the research project
- procedures for obtaining the consent of research interview participants
- that neither Ofgem nor Close-Up Research will process or retain personal data in this research project for longer than necessary, and shall delete the personal data in accordance with the retention periods set out below
- that Close-Up Research’s representative (Elliot Manches, elliot[AT]closeupresearch.com) shall be the main contact point for any participant who wishes to exercise their data protection rights in relation to this project, but that participants may also contact Ofgem’s representative (Adam Knight, adam.knight[AT]ofgem.gov.uk) to do so.
Video /audio recording
If you agree to take part in this research, Close-Up Research will ask to record your interview. This would only ever be done with your explicit consent, and with your right to withdraw that consent at any point being fully explained to you by Close-Up Research before any recording began.
The video footage from the interview and the vlogs you provide will be edited by Close-Up Research to be shown to Ofgem employees. Ofgem wants its staff to hear and see customer stories and experiences first-hand.
How long will my personal data be held?
If you do not agree to take part in the research, your contact details will be deleted immediately by Ofgem and by Close-Up Research.
If you agree to take part in the research interviews, your contact details will be stored securely by Ofgem and Close-Up Research for 24 months after the project completion date. This is in case Ofgem or Close-Up Research need to contact you following the interview for any follow-up questions (with your consent). After that period Ofgem and Close-Up Research will delete your contact details.
If you agree to take part in the research, the information you provide at interview will be analysed and retained by Ofgem for a period of no longer than 24 months following project completion. This is so that Ofgem can analyse and use the results of the research.
What rights do I have in respect of my personal data?
Under data protection law, you have the right to:
- request access to the information which Ofgem and / or Close-Up Research holds about you;
- request amendment or destruction of your information;
- request Ofgem and / or Close-Up Research to restrict the processing of your information;
- object to Ofgem and / or Close-Up Research’s processing of your information
- withdraw your consent to Ofgem and / or Close-Up Research’s processing of your information; or
- request Ofgem and / or Close-Up Research to transfer your information to another organisation.
In order to exercise any of these rights, please contact Close-Up Research or Ofgem. If you have further questions about this research project, you can contact us at conusmeraffairs[AT]ofgem.gov.uk .
At any time you can also raise any questions or concerns you may have in respect of your personal data with:
- Ofgem’s Data Protection Officer, who can be contact at dpo[AT]ofgem.gov.uk, or
- Close-Up Research (elliot[AT]closeupresearch.com).
More information on our general data privacy policies can be found on our respective websites:
- Ofgem: https://www.ofgem.gov.uk/privacy-policy
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Your rights in relation to your personal data are explained in more detail on the ‘Individual Rights’ section of the ICO website.