Processing of personal data
Privacy Notice of Elering AS
Elering AS (hereinafter Elering) is an electricity and gas system operator. In its activities, Elering collects, uses and stores (i.e. processes) your data in order to comply with duties and requirements arising from legislation, perform the agreements and contracts concluded with you, or to use your personal data based on your consent. The protection of personal data is essential for Elering and we want you to be aware of what kind of data we collect about you, what kind of purposes we use it for, and what are your options and rights. We have included the respective information in this privacy notice (hereinafter the Privacy Notice).
We comply with the legislation of the Republic of Estonia and the European Union when processing your personal data as provided in this Privacy Notice.
For the sake of clarity, please note that the Privacy Notice only applies to the processing of personal data in the course of the activities of Elering and does not reflect the processing of personal data by other companies (including companies engaged in electricity or gas services or activities).
If you have any questions concerning your rights in relation to the processing of your personal data or if you have any questions about how we collect and use your personal data, please contact the Data Protection Officer of Elering:
Marit Saaretalu
andmekaitse@elering.ee,
tel. +372 715 2271,
Kadaka road 42, 12915, Tallinn.
Personal data means any information on the basis of which a natural person is identified or identifiable. Information on the processing of personal data applies to the personal data of natural persons. The information contained in the Privacy Notice therefore does not apply to the data of companies or other legal persons or institutions. However, the information provided in the Privacy Notice applies to the personal data of all natural persons engaged in professional activities (e.g. the employees of a company). For example, if you communicate with Elering as a person related to our client, we also register and use the data concerning you (personal data). You could be related to our client as, for example, a member of the management board, signatory, an employee, or any other related third party.
The following is a list of the data that we collect and use:
- electricity and natural gas consumption data pursuant to legislation;
- contact details concerning landowners through whose registered immovables power lines or gas pipelines belonging to Elering pass;
- data concerning the proceedings and payments in relation to applications for tolerance payments for utility networks;
- data concerning the proceedings and payments in relation to applications for renewable energy support;
- personal data related to the issuance of guarantees of origin;
- personal data required for using the e-Elering customer portal and other web environments of Elering and the personal data generated therein;
- surveillance equipment on the registered immovables belonging to Elering, including the main building (e.g. security camera recordings);
- contact details of the representatives of contractual partners communicated upon the performance of contracts related to the obligations of the system operator.
We use data for the objective we collected the data for and according to the scope required to meet that objective. Once the objective has been met, we will delete the personal data.
Processing of personal data for performance of tasks in public interest
Elering, being a system operator for both electricity and gas, maintains and administers an electricity market data exchange platform and a gas market data exchange platform. Therefore, Elering processes the personal data on the electricity market as well as on the gas market. Such data constitutes above all the name of the person, their address and metering point code, as well as consumption data. The objective of processing the aforesaid personal data is the obligation imposed on Elering as a system operator of ensuring the efficient functioning of the electricity and gas markets and encouraging competition. Information concerning the processing of the respective data (viewing the energy consumption data of metering points, viewing the data on contracts of energy service providers, granting third parties the right to view one’s data and represent oneself and viewing who has the access to the data and who has used the data) can be accessed in the e-Elering customer portal of Elering (https://e.elering.ee).
Furthermore, Elering has also created online environments or web solutions for the performance of tasks in public interest that allow for simplifying the exchange of data and to ensure faster communication with Elering. For example, the EGLE environment serves as an information system for renewable energy and allows one to join the transmission network. In these web environments, Elering processes personal data in order to perform the task provided in the Electricity Market Act and for the objectives and within the scope set out therein.
Performance of obligations arising from legislation
In addition to the performance of tasks in public interest, other obligations have also been imposed on Elering that are mainly related to being the owner of the electricity and gas transmission network. In the case of performance of obligations arising from legislation, Elering only collects and uses personal data within the scope required for meeting the objectives. For example, arising from legislation, Elering collects the data of landowners on whose registered immovables the power lines or gas pipelines of Elering are situated. The data is used by Elering to contact the landowner in order to agree on performing maintenance or construction work in the protection zone. Elering receives the respective contact details of the landowner by making enquiries to the Land Register, Commercial Register and the Population Register.
Elering also conducts the processing of personal data within the framework of obligations arising from legislation when making tolerance payments according to the application of the owner of the registered immovable. The processing of personal data when making tolerance payments comprises the inspection of the data submitted in the application and concluding the payment.
Performance of contracts
Elering also processes your personal data if you enter into a contract with Elering. In such instances, the majority of landowners have entered into deforestation agreements, contracts on establishing a personal right of use, or other contracts regulating the use of a registered immovable. Elering uses the personal data in order to prepare the respective contracts and after entry into the contract in order to perform the obligations undertaken with the contract.
Consent-based processing of data
Consent-based processing of data means that Elering does not process your data on the basis of legislation or a contract, but you have instead granted your consent for processing your data. Such processing of personal data is conducted by Elering in its customer portal e-Elering. We have created the terms and conditions for using the portal in the e-Elering customer portal in relation to consent-based processing of data. This allows you to gain an overview of the purposes on which Elering processes the respective data. The terms and conditions are announced to you when you first log into the e-Elering customer portal, and once you accept them, they will be saved and you will be able to examine them again at any time. Consent is a basis for data processing that you can always refuse, if you wish. For this purpose, you must withdraw the consent you have granted. The relevant instructions are provided in the terms and conditions for using the e-Elering customer portal.
Legitimate interest
Ensuring the security of supply of electricity and gas in the whole of Estonia is a vital task. Therefore, strict requirements have been imposed on the buildings and civil engineering works of Elering (e.g. substations) for ensuring security and safety. In order to comply with the requirements and ensuring the safety of the electricity and gas systems, Elering has a legitimate interest for using surveillance equipment by means of security cameras for ensuring the physical security of the electricity and gas system. Respective stickers informing you that video surveillance is active on the territory are used to notify you of the use of surveillance equipment.
We may use personal data presented to us under legitimate interest from a third party for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Elering ensures the confidentiality of personal data within the framework of applicable legislation and implements relevant technical and organisational measures for protecting personal data from unauthorised access, unlawful processing or disclosure, accidental loss, alterations, or destruction.
Similarly to many web environments, Elering also uses cookies on its websites. Cookies are small text files that are stored in the computer of the user via the server of the online environment. The purpose of this activity is to enable the recognition of the same user as the web browser sends the cookie data back to the online environment every time it is used. Elering uses cookies to identify the user and provide services. For more information, please visit https://e.elering.ee/#/cookies.
In some instances, Elering may use its contractual partners for the processing of personal data. Such partners conclude personal data processing activities for meeting the principal obligation as provided in their contract. Such cases include maintenance and performance work of power lines and gas pipelines where a contractual partner of Elering organises the communication with the owner of the registered immovable for the performance of the work and reaching the required agreements. The contractual partners of Elering are obligated to comply with all the rules established for the processing of personal data which Elering also complies with.
Elering does not use or store personal data any longer than required for performing the tasks arising from legislation, performing a contract between the parties, or for drawing up legal claims. The storage period may be based on contracts, the legitimate interest of Elering or the applicable legislation (e.g. legislation related to accounting, terms for data storage accompanying the obligations of a system operator, or limitation periods arising from legislation).
The right to access data
You will always be able to examine your personal data that has been collected and is being used as well as its sources and objectives for the use thereof. You are also able to receive information as to how long Elering stores the data and to whom and to what extent the data is disclosed. The right to access your personal data may be limited by legislation, the rights of other persons for ensuring their privacy or other justified needs (e.g. the know-how, business secrets, internal evaluations and other materials of Elering).
The right to rectify personal data
If your data is incorrect, incomplete or irrelevant, you are able to apply that your data be rectified or deleted, taking into consideration the limitations arising from applicable legislation and the rights related to the processing of data.
The right to object
You have the right to object to the processing of your personal data, including in cases in which Elering refers to its legitimate interests when processing data.
The right to limit data processing relating to you
You have the right to limit the processing of your personal data on the basis of applicable legislation, for example when Elering assesses whether a person has the right to the deletion of their data, unless the data must be processed for the performance of a legal obligation of for the performance of a task in public interest.
The right to be forgotten
If personal data is processed on the basis of your consent and you have withdrawn your consent, you have the right to apply for the deletion of your personal data. This right does not apply if the personal data that you request to be deleted is also processed on the grounds of another legal basis, e.g. on the basis of a contract, for the performance of a legal obligation of for the performance of a task in public interest.
Right to data portability
If Elering uses data on the basis of your consent or on the basis of an agreement and the data processing is automated, you have the right to receive a copy of the submitted data in an electronic machine-readable format.
If you have any questions concerning your rights in relation to the processing of your personal data or if you have any questions about how we collect and use your personal data, please contact the Data Protection Officer of Elering:
Marit Saaretalu
andmekaitse@elering.ee,
tel. +372 715 2271,
Kadaka road 42, 12915, Tallinn.
If you are not satisfied with how we process your personal data and your inquiry to our Data Protection Officer did not result in a satisfactory outcome, you are able to file an electronic complaint at info@elering.ee or via post to Kadaka tee 42, 12915 Tallinn.
You are also able to file a complaint with the supervisory body. The Estonian supervisory body is the Data Protection Inspectorate; e-mail: info@aki.ee; postal address: Väike-Ameerika 19, 10129 Tallinn; telephone 6 274 135; website: www.aki.ee. The Data Protection Inspectorate is a state authority that can be addressed for consultation or assistance on topics relating to the protection of personal data.
Personal data means any information on the basis of which a natural person is identified or identifiable. Information on the processing of personal data applies to the personal data of natural persons. The information contained in the Privacy Notice therefore does not apply to the data of companies or other legal persons or institutions. However, the information provided in the Privacy Notice applies to the personal data of all natural persons engaged in professional activities (e.g. the employees of a company). For example, if you communicate with Elering as a person related to our client, we also register and use the data concerning you (personal data). You could be related to our client as, for example, a member of the management board, signatory, an employee, or any other related third party.
The following is a list of the data that we collect and use:
- electricity and natural gas consumption data pursuant to legislation;
- contact details concerning landowners through whose registered immovables power lines or gas pipelines belonging to Elering pass;
- data concerning the proceedings and payments in relation to applications for tolerance payments for utility networks;
- data concerning the proceedings and payments in relation to applications for renewable energy support;
- personal data related to the issuance of guarantees of origin;
- personal data required for using the e-Elering customer portal and other web environments of Elering and the personal data generated therein;
- surveillance equipment on the registered immovables belonging to Elering, including the main building (e.g. security camera recordings);
- contact details of the representatives of contractual partners communicated upon the performance of contracts related to the obligations of the system operator.
We use data for the objective we collected the data for and according to the scope required to meet that objective. Once the objective has been met, we will delete the personal data.
Processing of personal data for performance of tasks in public interest
Elering, being a system operator for both electricity and gas, maintains and administers an electricity market data exchange platform and a gas market data exchange platform. Therefore, Elering processes the personal data on the electricity market as well as on the gas market. Such data constitutes above all the name of the person, their address and metering point code, as well as consumption data. The objective of processing the aforesaid personal data is the obligation imposed on Elering as a system operator of ensuring the efficient functioning of the electricity and gas markets and encouraging competition. Information concerning the processing of the respective data (viewing the energy consumption data of metering points, viewing the data on contracts of energy service providers, granting third parties the right to view one’s data and represent oneself and viewing who has the access to the data and who has used the data) can be accessed in the e-Elering customer portal of Elering (https://e.elering.ee).
Furthermore, Elering has also created online environments or web solutions for the performance of tasks in public interest that allow for simplifying the exchange of data and to ensure faster communication with Elering. For example, the EGLE environment serves as an information system for renewable energy and allows one to join the transmission network. In these web environments, Elering processes personal data in order to perform the task provided in the Electricity Market Act and for the objectives and within the scope set out therein.
Performance of obligations arising from legislation
In addition to the performance of tasks in public interest, other obligations have also been imposed on Elering that are mainly related to being the owner of the electricity and gas transmission network. In the case of performance of obligations arising from legislation, Elering only collects and uses personal data within the scope required for meeting the objectives. For example, arising from legislation, Elering collects the data of landowners on whose registered immovables the power lines or gas pipelines of Elering are situated. The data is used by Elering to contact the landowner in order to agree on performing maintenance or construction work in the protection zone. Elering receives the respective contact details of the landowner by making enquiries to the Land Register, Commercial Register and the Population Register.
Elering also conducts the processing of personal data within the framework of obligations arising from legislation when making tolerance payments according to the application of the owner of the registered immovable. The processing of personal data when making tolerance payments comprises the inspection of the data submitted in the application and concluding the payment.
Performance of contracts
Elering also processes your personal data if you enter into a contract with Elering. In such instances, the majority of landowners have entered into deforestation agreements, contracts on establishing a personal right of use, or other contracts regulating the use of a registered immovable. Elering uses the personal data in order to prepare the respective contracts and after entry into the contract in order to perform the obligations undertaken with the contract.
Consent-based processing of data
Consent-based processing of data means that Elering does not process your data on the basis of legislation or a contract, but you have instead granted your consent for processing your data. Such processing of personal data is conducted by Elering in its customer portal e-Elering. We have created the terms and conditions for using the portal in the e-Elering customer portal in relation to consent-based processing of data. This allows you to gain an overview of the purposes on which Elering processes the respective data. The terms and conditions are announced to you when you first log into the e-Elering customer portal, and once you accept them, they will be saved and you will be able to examine them again at any time. Consent is a basis for data processing that you can always refuse, if you wish. For this purpose, you must withdraw the consent you have granted. The relevant instructions are provided in the terms and conditions for using the e-Elering customer portal.
Legitimate interest
Ensuring the security of supply of electricity and gas in the whole of Estonia is a vital task. Therefore, strict requirements have been imposed on the buildings and civil engineering works of Elering (e.g. substations) for ensuring security and safety. In order to comply with the requirements and ensuring the safety of the electricity and gas systems, Elering has a legitimate interest for using surveillance equipment by means of security cameras for ensuring the physical security of the electricity and gas system. Respective stickers informing you that video surveillance is active on the territory are used to notify you of the use of surveillance equipment.
We may use personal data presented to us under legitimate interest from a third party for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Elering ensures the confidentiality of personal data within the framework of applicable legislation and implements relevant technical and organisational measures for protecting personal data from unauthorised access, unlawful processing or disclosure, accidental loss, alterations, or destruction.
Similarly to many web environments, Elering also uses cookies on its websites. Cookies are small text files that are stored in the computer of the user via the server of the online environment. The purpose of this activity is to enable the recognition of the same user as the web browser sends the cookie data back to the online environment every time it is used. Elering uses cookies to identify the user and provide services. For more information, please visit https://e.elering.ee/#/cookies.
In some instances, Elering may use its contractual partners for the processing of personal data. Such partners conclude personal data processing activities for meeting the principal obligation as provided in their contract. Such cases include maintenance and performance work of power lines and gas pipelines where a contractual partner of Elering organises the communication with the owner of the registered immovable for the performance of the work and reaching the required agreements. The contractual partners of Elering are obligated to comply with all the rules established for the processing of personal data which Elering also complies with.
Elering does not use or store personal data any longer than required for performing the tasks arising from legislation, performing a contract between the parties, or for drawing up legal claims. The storage period may be based on contracts, the legitimate interest of Elering or the applicable legislation (e.g. legislation related to accounting, terms for data storage accompanying the obligations of a system operator, or limitation periods arising from legislation).
The right to access data
You will always be able to examine your personal data that has been collected and is being used as well as its sources and objectives for the use thereof. You are also able to receive information as to how long Elering stores the data and to whom and to what extent the data is disclosed. The right to access your personal data may be limited by legislation, the rights of other persons for ensuring their privacy or other justified needs (e.g. the know-how, business secrets, internal evaluations and other materials of Elering).
The right to rectify personal data
If your data is incorrect, incomplete or irrelevant, you are able to apply that your data be rectified or deleted, taking into consideration the limitations arising from applicable legislation and the rights related to the processing of data.
The right to object
You have the right to object to the processing of your personal data, including in cases in which Elering refers to its legitimate interests when processing data.
The right to limit data processing relating to you
You have the right to limit the processing of your personal data on the basis of applicable legislation, for example when Elering assesses whether a person has the right to the deletion of their data, unless the data must be processed for the performance of a legal obligation of for the performance of a task in public interest.
The right to be forgotten
If personal data is processed on the basis of your consent and you have withdrawn your consent, you have the right to apply for the deletion of your personal data. This right does not apply if the personal data that you request to be deleted is also processed on the grounds of another legal basis, e.g. on the basis of a contract, for the performance of a legal obligation of for the performance of a task in public interest.
Right to data portability
If Elering uses data on the basis of your consent or on the basis of an agreement and the data processing is automated, you have the right to receive a copy of the submitted data in an electronic machine-readable format.
If you have any questions concerning your rights in relation to the processing of your personal data or if you have any questions about how we collect and use your personal data, please contact the Data Protection Officer of Elering:
Marit Saaretalu
andmekaitse@elering.ee,
tel. +372 715 2271,
Kadaka road 42, 12915, Tallinn.
If you are not satisfied with how we process your personal data and your inquiry to our Data Protection Officer did not result in a satisfactory outcome, you are able to file an electronic complaint at info@elering.ee or via post to Kadaka tee 42, 12915 Tallinn.
You are also able to file a complaint with the supervisory body. The Estonian supervisory body is the Data Protection Inspectorate; e-mail: info@aki.ee; postal address: Väike-Ameerika 19, 10129 Tallinn; telephone 6 274 135; website: www.aki.ee. The Data Protection Inspectorate is a state authority that can be addressed for consultation or assistance on topics relating to the protection of personal data.