DR1178 – Change of Customer Details

Suppliers have had a concern since 2010 that NIE Networks continue to hold previous occupiers’ names on market systems even
though that occupier has ended their supply agreement with the registered Supplier.
The concerns include the following:

1. As Suppliers are the data processors, they are currently not meeting the necessary requirements under Data Protection legislation

2. Under section 29 “Compliance with Laws and Data Protections” of the MRC Suppliers have an obligation to “ensure all personal data
disclosed by it to NIE Networks are accurate and shall ensure that NIE Networks is, at all times, kept up to date regarding any
required corrections or deletions if any Personal Data previously disclosed is found to be inaccurate or no longer relevant.” 29.5.3.
Furthermore, under Section 29.7 of the MRC the Supplier “shall indemnify and keep indemnified NIE Networks against all losses, liabilities,
claims, costs (including legal costs and disbursements) and expenses incurred by NIE Networks arising from or in connection with any
failure by such Supplier to obtain appropriate Customer consents or to provide fair processing information” –
Thus, Suppliers are completely exposed and liable by being unable to inform NIE Networks about any occupiers who they are aware have
left a property.

3. In the event of an SOLR NIE Networks will provide to the SOLR a list of customers from the exiting supplier.
The SOLR will then upload this customer list to their systems and begin billing the customers.
Due to the current process and the exiting supplier being unable to accurately update NIE Networks, the list of customers will contain data
belonging to customers with no connection to this site.

4. Suppliers believe NIE Networks are covered by both statute (for non consumption cases) and the Deemed Contract Scheme
(for when consumption takes place) in the cases where the site is energised but there is no connection agreement or supply agreement.

Therefore, the Suppliers are suggesting using the MPNI 24 “Change of Customer Details” process via a MM 013 to notify NIE Networks
when an old occupier moves out and the new occupier is unknown.

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