Privacy Notice
Introduction
At Jamaica Public Service Company Limited (“JPS”), we are committed to protecting the privacy and security of the personal data of our customers and other relevant stakeholders. This Privacy Notice along with our policies on data privacy and governance outlines how we gather, use, disclose and safeguard the personal data we collect from you while you interact with us online, through our Mobile App and offline during the course of us providing you with our electric utility services. We understand the importance of maintaining the confidentiality and integrity of personal data and strive to ensure compliance with applicable data protection and privacy laws and regulations.
This Privacy Notice applies to all users of our electric utility services, including residential and commercial customers, as well as visitors to our website and/or mobile application(s). By using our services and/or platforms, you consent to the data practices described in this Notice.
We encourage you to read this Privacy Notice carefully to understand our practices regarding your personal data and how we strive to protect your privacy. It explains the types of information we collect, the purposes for which we collect that information, and the choices/rights you have regarding the collection and use of your data.
We may update this Privacy Notice from time to time to reflect changes in our legal requirements or business practices. These changes will be posted on our website and/or our mobile applications or communicated through other appropriate means. By continuing to use our services and/or access our platforms after such changes have been made, you acknowledge and agree to be bound by the updated Privacy Notice.
Effective date: December 1, 2023
Last updated: June 1, 2024
Who does this statement apply to?
- Customers and prospective customers
- Commercial entities to the extent that these entities provide us with any personal data for example employee names and email addresses
- People to whom we wish to promote products and services
- People who visit our website
- People who have responsibility for managing or being a point of contact for another person’s account with us.
Your Personal Data – What information we collect
Data we process about you includes but is not limited to:
Personal data- This includes your name, address, date of birth, and other contact details, for example your email address and phone number. As proof of identification, we also may collect Taxpayers Registration Number (TRN) or other types of government issued identification such as National ID, Passport or valid Driver’s License. To make changes to your account with us, we may also collect a Marriage Certificate, Deed Poll or Death Certificate. As part of your customer records, we may also request a Land Title or Tax Receipt as proof of ownership or a permission letter from the owner of the premises for which you choose to open an account with us.
Financial Information – This includes payment details and other financial information as well as your bank details if you request a refund.
Information about your supply – This includes your meter number, meter type and location. This ensures we are linking you with the right meter and helps to keep our billing accurate.
Energy you use – This includes your energy usage such as your consumption, voltage and power quality information. If you have a smart meter, we will take consumption data directly from your meter. See section on ‘Smart Metering Information’ below for more details.
Records of conversations and interactions with us – This includes records of your discussions with our customer support team, including call recordings, webchat, emails and direct messages on social media. This will amongst other things help us to monitor our customer satisfaction and interactions to help better serve you in the future.
Marketing preferences – This includes your advertising and marketing preferences including any request for these communications to stop.
Internet or other electronic network activity information/cookies – When you visit our website or interact with us through online media and advertisements, certain information about your visit and/or interaction with us is automatically logged through the use of various tracking tools like browser cookies and web beacons. We collect information about users over time when you use this website.
Company data – If you are a company that does business with us, this includes data such as names, phone numbers and email address of representatives of your company.
Exercising your rights – If you make a Data Subject Access Request (DSAR) with respect to your personal data, we will keep a record of the request and how we responded. See section on “Your Rights as a Data Subject” for more details.
Data we may collect/receive from other people or organizations
Data such as your name and contact details may be provided to us by people moving in or out of a property you are occupying or a landlord/estate agent.
Data is available from sources such as the National Land Agency and its Land Titles Division, Tax Administration of Jamaica and the Government Electrical Regulator. These services help us to be more efficient and serve you better and faster.
Third parties may monitor relevant user sentiment across social media and provide us with insights and analyses based on information you have made publicly available. We use these insights to help improve our services.
How we use your data
We have a duty to use your personal data in compliance with the Jamaica Data Protection Act and other applicable laws. These laws require that where we use your personal data, we must have a lawful basis prescribed by law to do so.
Set out below are some of the purposes (compliant with the Act) for which we, at JPS, may process your personal data:
- To assess your needs, provide you with a quotation or deposit amount and agree a contract with you.
- To set up your account with us, secure energy availability, apply the correct pricing, process consumption data, calculate charges and send bills.
- To contact you about your account about unpaid bills or to check information relating to your energy supply.
- To process payments, refunds and set up payment plans.
- To comply with regulatory reporting – we have a legal requirement to make certain reports to our regulator, the Office of Utilities Regulation (OUR), which may require us to process your personal data for this purpose.
- To manage any complaint or dispute you may have.
- To comply with orders made by a Court, for example where we are ordered to disclose information to law enforcement agencies.
- To meet our obligations as a licensed electricity supplier under the Electricity Act (“EA”) and the JPS Electricity Licence 2016 (the “Licence”)
- To pass your information to third parties with whom we contract to help us deliver services such as meter readings, action work orders, or print agencies. (see section about who we share your data with)
- For good governance, accounting, managing and auditing our business operations so that our business is effective and performs well.
- To manage our bad debt risk, including:
- Taking legal action against you if you breach the Standard Terms and Conditions of our service
- Performing credit and anti-fraud checks to assess your application for credit and offer suitable payment terms.
- To analyze your consumption so that we can offer you tariffs that suit your circumstances and give you tailored energy efficiency/conservation advice.
- To develop, test and improve the products and services we provide.
- For research and insight purposes, to enable us to provide good customer service and how we might improve our products and services. In some circumstances, our partners or we may use your contract details to ask you for your opinion of a service or interaction you have had with us to help us monitor and improve in the future.
- For the prevention, detection and prosecution of fraud, illegal abstraction of energy or other unlawful acts which could harm our business and the public.
Smart metering information
Smart meters record your energy consumption details and allow that information to be transferred to JPS remotely. This helps you receive more accurate bills. Smart meters also allow you to see what energy you are using at that point in time (via myJPS mobile app).
How we use your smart data:
From the date we install your smart meter, we may use the energy consumption data we obtain remotely from your smart meter for the following purposes:
- To produce bills based on actual reads, reducing the need to estimate your bills.
- To provide information and feedback to you about your energy consumption and how you could better manage your energy usage and save money.
- To calculate your energy usage and any debt or credit accrued.
- To provide energy usage for industry purposes in line with industry regulations.
- To let us know that it is safe and operating and recording correctly.
- To provide you with interactive tools to analyze your energy consumption through myJPS mobile app.
- To help us forecast demand for energy.
- To give you tailored advice and recommendations on how to reduce the amount of energy you use based on your specific energy usage.
- To carry out internal reporting, modelling and analysis to understand our customers better.
- To help us conduct investigations to prevent fraud.
Additional smart energy data use requirements
It may not be possible to purge (remove) all your energy data from the systems once it has been collected. If requested, we will de-personalize or stop processing that data unless we have a legal basis to do so.
Who we share your data with
There are various circumstances where we may need to share your data with other third parties. These are:
- Our shareholders and subsidiaries.
- Agents and third-party contractors engaged by us to facilitate our contract with you, such as Meter Readers, Field Service Technicians and other Data Collectors.
- Third-party IT suppliers who provide and/or help us operate our IT systems.
- Third-party digital customer engagement platforms providers who allow us to interact with you seamlessly via your channel of choice including social media platforms.
- Property Owners or housing associations if we or another organization suspect the property is connected to fraud or theft.
- Other people you have authorized us to share data with, such as family members, banks and financial institutions, credit bureaus etc.
- Debt collection agencies and other organizations assisting us with debt recovery (for example investigators, bailiffs, courts, losses technicians)
When we share your personal data with third parties, we impose measures to secure and protect your personal data within our contractual agreements.
How we store your personal data
Our retention periods for personal data are based on legal requirements and business needs. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When you share your personal data with us, we will keep it in accordance with applicable laws and approved data retention schedules.
We will dispose of your data in accordance with approved disposal methods when we no longer have a reason to retain it.
How do we keep your information safe?
No data transmitted over the Internet or website can be guaranteed to be 100% secure from intrusion. However, we will take appropriate technical and organizational measures to protect your personal data via these platforms and otherwise in accordance with data protection legislative requirements.
Data transfers outside Jamaica
If we have to disclose/transfer your personal data to an entity outside of Jamaica, we will only do so where the receiving country has laws that provide an adequate level of protection for personal data, or we have a contract in place which includes appropriate data protection clauses requiring that your personal data is processed to the same standards we uphold.
Automated decision making and profiling
We may utilize automated decision making, including profiling. This involves processing your personal data without human intervention to evaluate your personal situation such as your interests and behavior, for instance in relation to consumption patterns on your account. We may do this for the following reasons:
- To produce statistics for analysis purposes
- To assess your credit risk
- To assess your defection risk
The rationale behind making a decision or building a profile about you will differ in each case but generally we will use what we know about you, your household and your account history and combine this with demographic and general trend data.
This activity is on the basis of our legitimate interest in improving our business, tailoring our services, the offers we make, and developing and innovating our products and services which we can offer to you.
Consent
We require consent for the collection and processing of facial biometric data by MyJPS Mobile App (“the App”) for user authentication to enable expedited Smart Meter connection.
The facial biometric data collected by the App may include:
- Facial images or video recordings
- Facial landmarks or features
The App may collect facial biometric data through the following methods:
- Use of device camera for facial scanning
- Uploading existing facial images or videos from device storage
The data will be processed securely and stored in encrypted format on secure servers. Facial biometric data will only be collected for expedited smart meter connection and is disclosed to our third party processor UAB “Ondato”. You can submit requests regarding your personal data for more detailed information at support@ondato.com. Ondato’s consent notice is also provided at the point the data is captured for processing.
Facial biometric data will be retained for as long as necessary to fulfil the purpose listed above. Consent can be withdrawn for the collection and processing of your facial biometric data at any time. However, please note that withdrawal of consent may limit or restrict certain features or functionalities of the App in relation to expedited smart meter connection.
Your Rights as a Data Subject
Your rights under the Data Protection Act may include the following (where applicable):
- Right to correct inaccuracies or incomplete personal data– You may challenge the accuracy or completeness of personal data which we process about you. You have the right to provide verification and have inaccurate personal data corrected or completed as appropriate. You can reach out to our customer care using any of our contact channels found on our website https://www.jpsco.com/ or make a request in writing to the Data Protection Officer (DPO). See section below on how to contact DPO.
- Right of access – You may request access to your personal data which we hold, commonly known as a Data Subject Access Request (DSAR). Most of the data we process you already have access to via our MyJPS mobile app. If you need to action a DSAR, you may make a request on the MyJPS Mobile app using the Data Privacy and Protection section or you may direct this request in writing to:Data Protection Officer
c/o Manager – Data Privacy and Governance
Legal, Claims & Compliance
Jamaica Public Service
6 Knutsford Boulevard
Kingston 5
St Andrew
In order to process your request we may ask you to provide specific information and/or documentation to verify your identity including but not limited to your JPS account number and a valid government issued ID. However, please note that we may deny a request to the extent permissible by law.
- Right to object to or restrict data processing – Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data. Requests should be made in writing to JPS Data Protection Officer (DPO). See section below on how to contact DPO. Please note that in so far as the data is required to provide services to you, we may not be able to prevent processing.
- Right to withdraw consent – You have the right to withdraw your consent to any processing for which you have previously given, including for direct marketing. Requests to withdraw consent may be made in writing to our DPO. See section below on how to contact DPO. However, please note that if consent is the only legal basis upon which we can process your data, your withdrawal may affect our ability to fulfil the purpose for which you consented and may have implications not determined by us (for example if you consent to us sharing your data for services to be provided by another).
- Right to object to automated decisions – You have the right to object to certain decisions about you made solely by automated means using your personal data and request human intervention. Requests to object to automated processing may be made in writing to DPO. See section below on how to contact DPO.
How you can contact our Data Protection Officer
JPS’ Data Protection Officer supports and advises JPS on all data protection matters. The Data Protection Officer can be contacted by email at dpo@jpsco.com.