Gas Networks Ireland (“we”, “us, “our”) is a controller under the General Data Protection Regulation ((EU) 2016/679) ("GDPR") in respect of certain Personal Data we may process about you including in the course of operating the gas network in Ireland and otherwise. Gas Networks Ireland is part of Ervia. We own, operate, build and maintain the natural gas network in Ireland and connect all customers to the network. Gas Networks Ireland holds both Asset Owner and Asset Operator Licences for the Natural Gas Transmission and Distribution networks and is regulated by the Commission for Regulation of Utilities. Gas Networks Ireland has its registered office at Gas Networks Ireland Headquarters, Gasworks Road, Cork.
Gas Networks Ireland acts as a joint controller with GNI (UK) Limited (“GNI(UK)”) in respect of Personal Data that we may process in providing services to GNI(UK), such as responding to queries that you have made to GNI(UK). GNI(UK) has its registered office at 8th Floor, 20 Farringdon Street, London, EC4A 4AB. GNI(UK) is a wholly owned subsidiary of Ervia. Further details of this joint controller relationship are provided in section 2 below.
This Privacy Notice is intended to help you understand what Personal Data Gas Networks Ireland and GNI(UK) processes about you, why we collect it, and what we do with it.
1. What is Personal Data?
“Personal Data” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier such as a user IP addresses or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Special Categories of Personal Data;
"Special Categories of Personal Data" is any Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; genetic data or biometric data and data concerning health or sex life and sexual orientation.
2. Joint Controllers
Gas Networks Ireland has entered into an agreement with GNI(UK) that sets out our respective responsibilities of Personal Data as joint controllers, including in connection with:
- responding to queries raised by industry participants;
- managing the transmission network, enforcing rights and obligations under agreements with landowners and responding to queries from landowners;
- providing services to customers and responding to their queries;
- dealing with health and safety incidents, including compliance with legal obligations; and
- processing requests for access to information (including Personal Data).
With respect to Personal Data processed jointly by Gas Networks Ireland and GNI(UK), Gas Networks Ireland has agreed to perform certain responsibilities of a controller on behalf of itself and GNI(UK). This includes dealing with the exercise by you of your data subject rights. If you wish to exercise your data subject rights, please contact us using the email address in section 11.
3. Personal Data Collected and Processed
We collect and process Personal Data relating to you in connection our relationship with you. This
Personal Data includes:
- your name and contact details, including your address, phone number and email address;
- customer service records, including surveys and complaints;
- details related to your connection, including service requests, work orders and details;
- your account record, including meter readings, billing, payments and collections;
- health and safety records in the event of a health and safety risk, an accident, an incident or a hazard;
- any Freedom of Information or Subject Access Request details;
- landowner records where relevant to a right of way exercised by Gas Networks Ireland;
- data relating to landowners, including escalation records, interaction records, landowner records, bank details, landowners and location datasets, notice / communications records, project stakeholder database, publication records and response records; and
- any other Personal Data relating to you that you provide to us or that we generate about you in connection with our relationship with you, including records of any consent you have given and your use of the Gas Networks Ireland website.
4. Technical Data Collected
When you visit the Gas Networks Ireland website, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
5. Sources of Personal Data
6. Purposes for which we hold your Personal Data
The Personal Data that is referred to above will be processed for the purposes of:
- performing our functions as a public authority, including operating and maintaining the gas transmission and distribution systems;
- complying with our legal obligations;
- providing customer service to you and contacting you if required to respond to any communications you might send to us;
- establishing, exercising or defending legal claims and enforcing our rights;
- sending you promotional and marketing materials;
- improving the services we provide to you; and
- processing requests for information (including Personal Data).
Our legal basis for collecting and using this information in accordance with the provisions of this Data Privacy Notice is:
- that it is necessary for the performance of a contract with you;
- that it is necessary for the performance of tasks that we carry out in the public interest or in the exercise of official authority vested in us by law (including the Energy Act 2016 and the Safety, Health and Welfare at Work Act 2005);
- that it is necessary for compliance with a legal obligation that applies to us; or
- that you have provided consent to us for the use of your Personal Data
Where you have provided consent for the use of your Personal Data, you can withdraw it at any time by informing firstname.lastname@example.org, however, this will not affect the lawfulness of processing which was carried out based on your consent prior to its withdrawal.
7. Disclosure of your Personal Data to third parties
We disclose your Personal Data to various recipients in connection with the above purposes, including:
- to third parties who we engage to provide services to us, such as outsourced service providers, IT service providers, professional advisers and auditors;
- to other public authorities and bodies where required or permitted by law, such as An Garda Síochána or other law enforcement authorities for the purposes of prevention, investigation or detection of crime; and
- to comply with any applicable law or regulation, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
8. Transfers of your Personal Data outside of the European Union
In connection with the above we may transfer your Personal Data outside the European Economic Area, including to a jurisdiction which has not been found by the European Commission to provide an adequate level of protection for Personal Data.
If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a data processing agreement in respect of the transfer which contains the ‘standard contractual clauses’ approved by the European Commission, or in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework (or any replacement framework). Further details of the measures that we have taken in this regard are available on request from email@example.com.
9. How we secure your Personal Data
Where you communicate with us via the Gas Networks Ireland website, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
10. Your Rights
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your Personal Data:
- the right to access your Personal Data;
- the right to request the rectification and/or erasure of your Personal Data in certain circumstances;
- the right to restrict the use of your Personal Data in certain circumstances;
- the right to object to the processing of your Personal Data;
- the right to be forgotten in certain circumstances; and
- the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller, in certain circumstances.
11. How you can exercise your rights
In order to execute any of the rights set out above, please contact us at firstname.lastname@example.org.
12. How long we retain your Personal Data
We will not hold your Personal Data for longer than is necessary. We retain your Personal Data for as long as we need it for the purposes described in this Privacy Notice (including but not limited to section 7 (Disclosure of your Personal Data to third parties), or to comply with any applicable statutory requirement.
13. Changes to this Privacy Notice and our Policies
We reserve the right to make changes to this Privacy Notice at any time without prior consultation. Any changes to this Privacy Notice will be posted on the Gas Networks Ireland website so that you are always aware of what Personal Data we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail.
14. Questions and Complaints
If you have any questions regarding this Privacy Notice, you can contact us using the information below:
Data Protection Officer
Gas Networks Ireland
Networks Services Centre
St. Margarets Road
You have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie/en/contact/how-contact-us).