At SONI Ltd (“SONI”), we take our obligations under data protection law very seriously and we're committed to keeping your personal data private and secure. This statement is designed to help you understand what Personal Data we hold, why we collect it, why it is required, what we do with it and how we protect it. It also explains your rights in relation to how we hold and use your personal data, how to exercise those rights, and what to do if more information is required or a complaint is to be made. 

This privacy notice applies to all Personal Data we hold, irrespective of any relationship with us.

We respect your right to privacy. If you have any questions about how we use your information, then please write to: the Data Protection Officer, Data Protection Officer, SONI Ltd. Castlereagh House, 12 Manse Road, Belfast, BT6 9RT or at DataProtection@soni.ltd.uk.  

About SONI

SONI, part of the EirGrid Group since 2009, is the electricity system operator for Northern Ireland: We are responsible for the consistent and reliable transmission of electricity on our high-voltage grid, matching supply and demand for power across Northern Ireland, every second of every day.

SONI also operates the all-island wholesale electricity market with EirGrid through the Single Electricity Market Operator (SEMO) which has been in operation since November 2007. 

In this privacy policy, the terms "we", "our", and "us" are used to refer to SONI. SONI is a “Controller” under the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) in respect of certain Personal Data you furnish to us.

SONI is regulated by the Utility Regulator Northern Ireland.

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.

Technical data collected

When you visit the SONI 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. We also collect certain information by the use of cookies. Cookies are small text files that web servers can store on your computer's hard drive when you visit a website. They allow the server to recognise you when you revisit the website and to tailor your web browsing experience to your specific needs and interests. For more information on our use of cookies, please see our Cookies Policy which can be found at http://www.soni.ltd.uk/Legal/#Cookies.

What personal data do we use?

We use, or process, a number of different categories of personal data. 

Information you give us – this is information about you that you give us when engaging with SONI for example by filling in forms, responding to questionnaires or by corresponding with us by phone, face-to-face or e-mail generally or when you respond to a public consultation exercise or an information gathering exercise which relates to SONI's general business or responsibility for the safe, secure, efficient and reliable operation of the high voltage electricity Transmission System in Northern Ireland. The information that you give us will include some or all of the following (depending on the circumstances):

• your name, date of birth, contact details;
• current and previous address, occupation, nationality, citizenship, photo or other I.D. confirmation;
• your property ownership and information about it where you have transmission infrastructure on or near your property;
• medical data (as it relates to your capacity);
• your views and feedback on SONI’s business or role as the electricity transmission system operator;
• records of any consents you have given; and
• your use of the SONI website.

We may record telephone calls you make to us for training or quality purposes. Where you provide information about others you must ensure that you have their consent or are otherwise entitled to provide this information to us.

Information we receive from other sources – this is information about you that we receive from other sources such as our business partners (e.g. N.I.E.N.), or from publically available sources such as (but not limited to) the land registry, death notices and electoral registers. The information that that we receive from these sources will include some or all of the following (depending on the circumstances):

• your name, date of birth, contact details;
• current and previous address, occupation, nationality, citizenship, photo or other I.D. confirmation;
• medical data (as it relates to your capacity);
• your property ownership and information about it where you have transmission infrastructure on or near your property; and
• your views and feedback on SONI’s business or role as the electricity transmission system operator.

What do we use personal data for?

Our core business and central focus is the safe, secure, efficient and reliable operation of the high voltage electricity Transmission System in Northern Ireland. To this end we use information held about you in the following ways (as applicable):

• establishing and maintaining records associated with connections to the electricity Transmission System;
• if you apply for one, to process personal data that you give us when you apply for a proximity payment;
• to ensure we are engaging with the correct landowner/home owner/stakeholder;
• to keep you informed about our activities including the operation of the high voltage electricity Transmission System in Northern Ireland;
• to analyse, assess, maintain, improve and develop the grid infrastructure;
• to verify the accuracy of the data you have to provided to us;
•  management of an electricity connection agreement;
• managing the safe, secure and reliable operation of the electricity Transmission System;
• planning and developing the electricity Transmission System;
• facilitating the reliable operation of the wholesale electricity markets;
• to meet our obligations to our regulators; and
• to deal with your enquiries and requests (e.g. complaints handling).

What are our legal grounds for processing personal data?

Data protection laws require that we meet certain conditions in order to use your data in the manner described in this privacy statement.  We rely on the following legal grounds in order to process your data:

• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in SONI. Pursuant to the TSO Licence and its legislative functions, SONI must operate, maintain and develop a safe secure and reliable electricity transmission system and in doing so is required to process the information about you referred to in this document. 
• That you have given your consent to the processing of your Personal Data. We may use your contact details to provide you with certain promotional information about our activities where you have provided your explicit consent for us to do so. You may withdraw this consent at any time by asking us to stop sending you such promotional information.
• The processing is necessary for the performance of a function conferred on SONI by statute. We may be provided with certain medical information (for example from legal personal representatives), which relates to physical or mental capacity. We may need to process this information when carrying out statutory functions of operating, maintaining and developing a safe secure and reliable electricity transmission system. We only use this information to allow us to ensure we deal with landowners and other stakeholders in an appropriate manner.   

Who do we share personal data with?

We may share your personal information with the EirGrid Group. This means EirGrid plc, the Single Electricity Market Operator for the island of Ireland (known as "SEMO"), EirGrid Interconnector DAC and EirGrid Telecoms DAC.

We will only disclose your information:

• to business partners (e.g. N.I.E.N.), service providers, consultants, advisers, suppliers and sub-contractors for the performance of any contract we enter into with them;
• to third party suppliers and service providers to the extent they assist us with our legal / regulatory obligations or are business operations;
• to our regulators for the purposes of complying with our operating licence;
• to law enforcement agencies as well as our legal advisors, courts any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.
• in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency or winding up situation (e.g. the administration or liquidation) of any member of the EirGrid Group, including SONI Limited;
• if we, or substantially all of our assets, are acquired by a third party or if our functions or powers, or substantially all of them, are transferred to a third party, in which case information held by us about you may be transferred to such third party;
• to protect the rights, property, or safety of us, our staff, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of staff and customer safety, and crime prevention; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

Transfers of your personal data outside of the European Union

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the "EEA"), in particular, where we use third party cloud storage providers.

When we send personal data overseas, we will make sure suitable safeguards are in place, in accordance with European data protection requirements, to protect the data. In all cases these safeguards will be one of the following:

• Sending the data to a country that's been approved by the European authorities as having a suitably high standard of data protection law.
• Putting in place a contract with the recipient containing terms approved by the European authorities as providing a suitable level of protection.
• Sending the data to an organisation which is a member of a scheme that's been approved by the European authorities as providing a suitable level of protection. One example is the "Privacy Shield" scheme agreed between the European and US authorities.

More information on these safeguards can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en

How long is personal data kept for?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The retention period may vary depending on the purposes for which the information was collected.

Where a specific legal or regulatory requirement applies to your information we will retain it for the period of time specified in such legal or regulatory requirement. In the absence of a specific legal or regulatory requirement we will retain your information for the applicable statutory limitation period following the end of the matter to which it relates. We may be required to extend the retention period if the information is required in relation to a complaint, investigation, judicial review, a claim or litigation. 

Please also note that we are sometimes legally obliged to retain original legal documents, such as easements or title deeds, indefinitely.

Your rights

You have a number of rights under data protection law in relation to the way we process your personal data. These rights are a right to:

1. access personal data held by us about you;
2. require us to rectify any inaccurate personal data held by us about you;
3. require us to erase personal data held by us about you;
4. restrict our processing of personal data held by us about you;
5. receive your personal data in a structured, commonly used and machine readable format and you also have the right to require us to transfer this personal data to another organisation, at your request (known as the "right of portability");
6. object to our processing of personal data held by us about you; and
7. withdraw your consent, where we are relying on it to use your personal data.

These rights are subject to certain restrictions provided for in data protection legislation. For example:

• The right of portability will only apply to the extent that we process your information on the basis of your consent or on the basis of a contract, and we process it by automated means.
• The right to restrict our processing of personal data held by us about you will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.

You may contact us using the details on our website (or by contacting our DPO directly – details below) to exercise any of these rights. Please address any questions, comments and requests regarding our data processing practices to our Data Protection Officer in the first instance. Our DPO can be contacted by writing to the Data Protection Officer, SONI Ltd. Castlereagh House, 12 Manse Road, Belfast, BT6 9RT or you can email DataProtection@soni.ltd.uk.

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office – Northern Ireland.

The Information Commissioner’s Office in Northern Ireland's contact details are:

Telephone: +44 28 9027 8757 OR 0303 123 1114

E-mail: ni@ico.org.uk  

Postal Address

The Information Commissioner’s Office – Northern Ireland
3rd Floor
14 Cromac Place,
Belfast
BT7 2JB

Changes to our privacy statement

We may update this privacy statement from time to time.  Any changes we may make in the future will be posted on this page of our website and, where appropriate, we will endeavour to bring the changes to your attention by other means.

Last updated 24 May 2018