How is One Bill accomplished within the Data Protection Act?

Southern Water has appointed South East Water to bill and collect their sewerage charges on their behalf as we already bill and collect the same customers for water. We have a data processing contract in place with Southern to allow customer data to be transferred.

Both companies bill and collect charges based on the fact that there is a legal obligation requiring water companies to supply water to household customers and a corresponding duty allowing them to bill and collect the charges for such services.

This therefore means that both parties process this data in accordance with condition 3 of Schedule 2 of the Data Protection Act, which means there must be a legal obligation to do so. Southern has outsourced their legal obligation to us to act on their behalf. Because of this legal obligation, there is no need to have the consent of a customer to do so as both parties are exercising their statutory obligations.