PLANS FOR IRISH Water to charge 58,000 households with excessive water usage were delayed amid concerns over data protection and how to deal with customers that have no water meters.
Letters and information packs were being readied to send last October telling households what they could do to reduce their water consumption and how Irish Water could help.
Internal records obtained under FOI describe detailed discussions to ensure that plans to start charging would be “very carefully managed”.
They explain how there would need to be messaging around how Irish Water was going to manage households that had no meters and how excessive use for them would be calculated.
Irish Water was prepared to start sending the letters as early as last October but the plan was postponed to deal with issues around how customer data would be managed, unmetered houses, and building IT infrastructure to support the project.
Discussions are currently underway with the Data Protection Commissioner over how the volume of personal data involved can be properly managed.
This would include names, addresses, water usage, the number of people living in each house, and special medical requirements of residents that might require additional water use.
It also includes strong indicators of when people are likely to be home based on when water is being used on a day-to-day basis, which in the event of a breach could create a burglary risk for households.
A spokeswoman for Irish Water said that household water conservation was a “unique project” and that the Department of Housing was consulting with the Data Protection Commissioner.
She said: “[We have] taken all the necessary steps to try to ensure that our approach is in line with GDPR requirements and that all measures are taken to protect personal data.”
The spokeswoman said that while GDPR was a key issue, detailed work on customer communications, building IT systems to ensure accurate notification, and the creation of a workable standardised approach to identifying unmetered households were also “essential to the progression of the project”.
“All of these elements are reaching a state of readiness. The project cannot proceed unless and until all elements are ready,” she said.
The internal Irish Water records explain how the process for charging would happen with a ‘call to action’ letter and leaflet sent to households at first.
This would include a “step-by-step guide on what a customer in receipt of a letter should do next – what options are open to them, what help can Irish Water provide, what can the household do?”
Customers would be told how much water they had used in the preceding twelve months and that this was “above the excess threshold amount”.
The letter would say: “If you continue to use more than 213,000 litres a year, you may have to pay excessive usage charges for water used above this amount.”
A discussion document said that the words “excessive usage charge” should be used consistently and also advised that a reference to cutting down on “toilet flushing” be removed from information leaflets.
Officials from the Department of Housing also warned Irish Water that it must stick rigidly to what was allowed for in legislation in their letters to households.
“If they appear to suggest that Irish Water is operating differently to what is in the legislation, they will be open to challenge,” said one email.
It continued: “We appreciate that a strong customer focus is important but it must be consistent with the legal provisions and it will be possible to accommodate both these objectives.”
A timeline shows how the first letters were scheduled to be sent in the period between October and December of last year.
A second letter would then have issued in April of this year. A third reminder letter would then be sent in January 2021 with the first bills issuing in July 2021 if excessive use had not been curtailed.
The excess would be charged at the rate of €1.85 per 1,000 litres up to a capped amount of €250 per service. “Customers with water in and water out services will be capped at €500 per annum,” it said.
The process would target 6,000 people with the highest excess use first.
A briefing said this would need to be carefully monitored because of the likelihood of leaks in these households and whether the repair work would have to be carried out by Irish Water.
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