Privacy Policy

Alt HAN Co is a vehicle established to allow all Great Britain (GB) energy suppliers to deliver Alternative Home Area Network (Alt HAN Co) technological solutions and services. Our work includes assessing for the deployment of smart metering devices and technological solutions to allow smart meters to communicate with each other, otherwise known as Alt HAN Co equipment. Alt HAN Co is committed to protecting your privacy and compliance with all relevant legislation, including the UK Data Protection Act 2018 (DPA), in addition to the Privacy and Electronic Communications Regulations 2003 and other applicable legislation.

This Privacy Policy covers our treatment of information that is gathered by this website and while the deployment and provision of Alt HAN Co services, including by our third-party partners and contractors. This Policy does not apply to information collected by third party websites, or personal data collected in the context of employment. Additionally, certain information may be collected by energy suppliers, which may be used during the Alt HAN Co services. In this case, we take steps to ensure such organisation provide notice to these individuals that their personal data will be processed for Alt HAN Co services, where they are best placed to do so.

Typically, we will collect the personal data of energy customers, and residents and landlords in premises that may be suitable to benefit from Alt HAN Co services, in addition to staff at our suppliers, contractors, partners and other third parties. This will include the following:

Contact & Business Details. You may give us your Contact Details by filling in forms on our website, through an existing business relationship with your company, or through the course of research or surveys conducted in the deployment of Alt HAN Co services. We may use this information to contact you or during the provision of services to you. This information could also be collected through your interaction with Alt HAN Co during business, including where you provide services to Alt HAN, as is related to the installation of Alt HAN Co smart metering equipment in your building, or when you submit a complaint to us or make any other request.

This will include information such as:

  • Your name
  • Position and Company
  • Phone number
  • Physical address
  • Email address
  • Contact preferences (for marketing purposes)
  • Country or location

Financial Details. Where we need to make a payment to you or your organisation, or issue an invoice, we many collect your financial details to facilitate this. Generally, this will include:

  • Bank name and sort code
  • Bank account number

Energy Data. Where you are a resident at a building that may be suitable for the deployment of Alt HAN Co equipment or otherwise fall within the remit of smart metering as an energy customer, we may process personal data specific to your smart meter, including meter serial numbers (MPANs, MPRNs, MPxNs). We may receive such data from external energy databases such as those provided by ECOES (RECCo), Xoserve and Electralink, as well as directly from your energy supplier. We may also process limited meter reads and consumption data for short durations, as incidentally collected by Alt HAN Co or your energy supplier during the testing of smart metering equipment. We process such data in line with the Smart Energy Code (SEC), which provides the basis for our business processes and use of this data.

Building Data. Where you are a resident, tenant, owner or other occupant at a building that may be suitable for the deployment of Alt HAN Co equipment or otherwise fall within the remit of smart metering as an energy customer, we may also collect and store information about your premise, including its address and postcode, from external energy databases. We use this information to conduct a market sizing analysis of the suitability of business premises for Alt HAN Co smart metering equipment. This will generally not be considered personal information, and will largely consist of location (e.g., GPS coordinates), building measurements and specifications.

Technical Data. Similarly, to other websites, we may also collect information from your device and store it in log files, as you interact with our website or websites hosted by our third-party partners or cookies embedded in our website, to support your website experience and interactions with us. This information could include data on your IP Address, Location, device identifiers and information on links that you click on or content that you view.

Other Information. We may also collect information relating to an activity/complaint or engagement with the member of the public. We may also collect information in relation to Health and Safety incidents that occur with respect to our sub-contractors/surveyors when conducting surveys on-site, as part of our Health and Safety duty of care. This information will be anonymised where possible. We may also process photographs/video/audio recordings of energy supplier’s employees and other attendees, as collected at Accelerated Solutions Environment (ASE) events as part of the course of our business activities. Moreover, our surveyors (sub-contractors) may also take photographs of residences in the course of surveying them for market sizing activities, which may incidentally include photographs of residents (although we take steps to check and remove photos that include images of residents). In some cases, we may use site visit information to inform our data sets.

Alt HAN Co processes personal data only where there is a valid lawful basis to do so under UK data protection law. The lawful basis relied upon will depend on the nature of the activity and the relationship with the individual concerned.

We most commonly process personal data under one or more of the following lawful bases:

Legal Obligations: We process personal data where this is necessary for compliance with a legal obligation to which Alt HAN Co is subject. This includes obligations relating to health and safety, financial and tax records, regulatory requirements, and statutory reporting.

Performance of a contract: We may process personal data where this is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract. This includes processing relating to suppliers, contractors, and service relationships. An example of this, processing information of our subcontractors’ staff, and processing data of suppliers and other parties in relation to the installation of Alt HAN Co Equipment.

Legitimate Interests: We may process personal data where it is necessary for the purposes of our legitimate interests, or those of a third party, provided those interests are not overridden by your rights and freedoms. These interests may include supporting the delivery of Alt HAN Co services, maintaining business relationships, ensuring network and information security, managing complaints, and defending legal claims. Where we rely on legitimate interests, we take the impact on individuals into account and ensure processing is proportionate and aligned to reasonable expectations.

Consent: In limited circumstances, we may rely on consent as the lawful basis for processing personal data, such as for optional marketing communications or where you explicitly agree to specific processing activities. Where consent is relied upon, you have the right to withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

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.

We will retain the following data for the applicable periods below.

Type of dataRetention periodLegal BasisJustification
Contact DetailsStaff at our partners, suppliers, or third parties: For the duration of the business relationship, or 2 years since the last contact
Members of the public: A maximum of 2 years
Legitimate interest: Maintaining communications with business partnersTo keep in contact with you in relation to Alt HAN services
To manage the provision of Alt HAN services
Energy DataEnergy customers: For the duration of the provision of Alt HAN Co services/ Alt HAN Co ProgrammeLegitimate interest: Supporting GB’s smart metering rolloutTo ensure the analysis of suitability for, and provision of Alt HAN services to, specific residences
Financial Details6 years from the end of the financial year in which the payment was madeLegal obligation: Section 12B, Taxes Management Act 1970; Section 388(4)(a)(b) Companies Act 2006For processing payments and for our legal/financial obligations
Other InformationPhotos from ASE events: For the duration of the provision of Alt HAN Co Services
Health and safety risk information: Duration of Alt HAN Co services/up to 3 years maximum following collection (whichever is the greater)
Legitimate interest: Maintaining communications with business partnersFor administering, carrying out and reporting progress at ASE events
For risk assessing and recording information on particular residences
Technical DataDevice identifiers/IP address/Cookies: Variable (See Cookies Policy below)Legitimate interest: Maintaining the functioning of the Alt HAN Co website.With your consent and/or to understand interactions with our website

Cloud servers: We store personal data within our UK and EEA-hosted servers and other third-party databases. These include:

  • Microsoft Office 365/Sharepoint (with data stored in Microsoft Azure data centres in the UK)
  • Database providers for HR and Customer Relationship Management (CRM) details (such as JIRA, where data is stored on UK or EU data centres)
  • Finance system providers (including Cloud & Content), with information stored on data centres in UK)

We ensure that security controls are in place around these systems, including that access controls are limited to the appropriate staff and contractors needed (for operational purposes) to access those systems. Where we exchange personal data in attachments via email, we also use password-protection and encryption solutions where possible.

Alt HAN Inventory: The Alt HAN Inventory is a database we have developed with building and premise data, which we use to assess residences for their suitability for the deployment of Alt HAN equipment. This may also include information about residents, including Energy Data. We have several security safeguards in place around the Alt HAN Inventory, which involve i) VPN connections for remove logins, or permitting connections from certain buildings or addresses (such as our office), or ii) log-on credentials and 2 factor-authentication in a web-based version of the Inventory interface.

Third Parties: We may also transfer your personal data to our clients and third parties, as detailed below. Some of these third-party providers may have staff outside the UK or European Economic Area (EEA), and may access personal data, subject to suitable and secure safeguards. Where these are used, we typically ensure that such systems employ appropriate access controls to limit usage only to the necessary staff. These are discussed further in the section below.

We may share your personal data with the parties set out below. This will typically include in the following circumstances:

  • Contractors and partners that we work with to carry out Alt HAN Co business processes (including the identification of residences for Alt HAN equipment), such as Capgemini, who act as an Operational Service Provider, and sub-contractors, such as Daly International
  • Energy Suppliers, that we may work with to provide your residence with Alt HAN equipment.
  • Business partners, such as the Technology Services Vendor, which works on developing Alt HAN equipment.
  • Database providers where we store business data and personal data, such as Huddle, JIRA, Microsoft, Cloud & Content, and others.
  • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom, who require reporting of processing activities in certain circumstances.
  • Public authorities who make lawful requests for the disclosure of information by Alt HAN Co, including to meet national security or law enforcement requirements.

Alt HAN Co with enter into agreements with third parties to ensure that they respect the security of your personal data, treat it in accordance with the law, and notify us if any security breaches occur.

Where we use such third-party providers as listed in Section 5, we take steps to enter into agreements to ensure that such third parties have the adequate safeguards in place, which include:

Generally, where data has been transferred from Alt HAN Co to other third parties outside the UK, we will ensure that any parties who receive such data have the appropriate measures to ensure secure transfers in place. In particular, this will include our sub-contractors and business partners, whose staff may access personal data on the Alt HAN Co Inventory from outside the UK and may include some of our systems used for storing and sharing personal data.

Alt HAN Co will not transfer any data or allow any access to such data to such third parties until one of the following mechanisms are in place:

  • An adequacy decision from the Secretary of State or Information Commissioner’s Office (ICO)
  • UK-approved Standard Contractual Clauses or International Data Transfer Agreements
  • Binding Corporate Rules that have been put into place.

Additionally, where data transfers occur to countries outside of the UK, European Economic Area, or those without adequacy decisions, Alt HAN Co will assess the laws and practices of the third country of destination for the transfer and of any relevant contractual, technical or organisational safeguards put in place, before allowing the transfer to occur.

Under certain circumstances, you have rights under the GDPR and DPA in relation to your personal data, upon request:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of inaccurate or incomplete personal data we hold about you.
  • Request erasure of your personal data where there is no lawful basis for us to continue processing it.
  • Request restriction of processing in certain circumstances, for example while accuracy or lawful basis is being considered.
  • Request the transfer of your personal data to you or to a third party in a structured, commonly used and machine-readable format, where processing is carried out by automated means and is based on consent or the performance of a contract.
  • Object to processing where we rely on legitimate interests, where you believe that such processing may have an impact on your particular circumstances.
  • Opt out of marketing communications at any time.

Where applicable, we may need to verify your identity before responding to a request, and in certain circumstances we may lawfully refuse or limit a request. We aim to respond to all valid requests within one month, or will notify you if an extension is required.

To exercise these rights with respect to Energy Data, please contact your energy supplier in the first instance.

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 could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

At Alt HAN Co, we may use cookies to allow us to personalise your visits to this site, keep track of your preferences and learn about the way you use the site.

A cookie is a small text file that is downloaded onto your computer when you visit our website and allows us to recognise you as a user. Typically, these contain two pieces of information: a site name and unique user ID. All information these cookies collect is aggregated and anonymous. Cookies are essential to the effective operation of our website. Cookies make the interaction between you and the website faster and easier. Cookies may also be set by the website you are visiting (first party cookies) or may be set by other websites who run content on the page you are viewing (third party cookies).

Cookies are generally collected across the following categories:

  • Strictly Necessary: Cookies that are strictly necessary to enable you to move around our websites or to provide certain basic features.
  • Functional: Cookies that are used to enhance the functionality of the website, including by storing your preferences
  • Analytics: Cookies that track visitor statistics and user traffic that allow us to monitor the popularity of sections of our website (e.g., Google Analytics)
  • Marketing: Cookies that are used to track users across pages or websites to build up a user profile and display advertisements relevant to them

Currently, we have the following cookies in use on the Alt HAN Co website:

COOKIE NAME/ID CATEGORYPURPOSERETENTION PERIOD
Google Analytics (_gid, _ga)AnalyticsCookies used to track users’ interactions with our web pages2 years
PHPSSEIDFunctionalityTo provide web functionality during a user’s browsing sessionSession only
Complianz (cmplz_all, cmplz_choice, cmplz_id, cmplz_stats)Strictly NecessaryCookies used to record evidence of a user’s consent to cookies1 year

We require you to accept or decline certain cookies by accepting or declining our Cookie Consent Notice when first accessing our website. By accepting and using our websites you consent to our use of cookies as updated from time to time and the cookies we use will be stored on your device (unless this functionality is rejected or disabled by your browser).

You may access our Cookie Consent Notice to opt-out of cookies at any time subsequently. You may access our Cookie Consent Notice to opt-out of cookies at any time subsequently. For more information on how to manage cookies usage on your device, you can visit this link: Managing the Cookies Stored on Your Device

Please note that if you prefer to block some or all the cookies Alt HAN Co uses, you might lose some of our website’s functionality.

Alt HAN Co utilises Artificial Intelligence (AI) and Machine Learning (ML) technologies to support internal operations, analysis, and strategic decision-making. Machine learning refers to systems that identify patterns and improve performance by learning from data, while AI encompasses broader techniques that support analysis and insights.

We primarily apply machine learning models to analyse datasets provided by suppliers and partners. These datasets are used to support operational efficiency and data-driven insight and are processed in accordance with applicable contractual and legal safeguards.

All use of AI and ML technologies is carried out in compliance with UK data protection law. In particular:

  • Personal data is processed only where a clear lawful basis applies.
  • Personal data is not used in model training without appropriate safeguards.
  • Outputs generated by AI or ML tools are subject to appropriate human oversight and validation.
  • AI and ML use is periodically reviewed to assess legal compliance, risk, and ethical impact.

Alt HAN Co does not make decisions producing legal or similarly significant effects about individuals solely through automated processing. Should our use of AI or ML change materially in the future, this Privacy Notice will be updated accordingly.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) within Alt HAN Co. If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO) at dataprotection@althanco.com at any time.

For the purposes of compliance with the law, our registered address is:

Alt HAN Company Ltd.,
5 Norwich Street,
London,
EC4A 1EJ.

COMPLAINTS

You 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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. You can contact the ICO using the following:

Email address: casework@ico.org.uk

Postal address: Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone number: +44 (0) 303 123 1113

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