Privacy Policy

The Société Wallonne des Eaux (hereinafter "SWDE", “We”, “Us” and “Our”), a civil company in cooperative form governed by public law, entered in the register of organisations with the number 0230.132.005, with its registered office at 4800 Verviers, Rue de la Concorde 41, is responsible for water supply in more than 200 municipalities in Wallonia and for monitoring water quality and the water distribution network in the Wallonia region. In carrying out these duties, SWDE complies with the applicable data protection regulations, including European legislation (the General Data Protection Regulations or "GDPR") and Belgian legislation (the Protection of Individuals Concerning the Processing of Personal Data Act of 30 July 2018).

The data you entrust to us when you visit our website, communicate with us and use our services is essentially personal data.

This Privacy Policy has been drawn up to inform you about SWDE’s processing of your personal data collected through various channels (via our website, in writing, by telephone, during visits to our offices, etc.).

We invite you to read this Policy carefully and to consult it regularly to take note of its content, which may change if SWDE's data processing activities also change.

Why we process your data

A.    Browsing our website

You can visit our site and find out about our services without having to provide us with any personal information.

However, certain cookies are needed if you want to browse our website. For further information on this, please refer to our cookies policy.

B.    Communicating with you

Data types – These include your surname, first name, e-mail address, telephone number and any other information you give us in the course of our dealings with you.

Purpose of processing – We process this data when you contact us by telephone, post or e-mail so we can communicate with you and answer your questions.

Lawful basis for processing – The processing of this data is necessary to answer your questions about the services and tasks carried out by SWDE. The data is therefore essential to carrying out the tasks in the public interest entrusted to us by the Water Code (Book II of the Walloon Environmental Code) in our capacity as Distributor. Without it, we cannot do our job properly. 
Data recipients – Your data may also be processed by our website host or another IT service provider for the purposes strictly necessary to comply with the instructions we send them. In this respect, they act as subcontractors.
Period kept – Data is kept for no more than one year after our last contact, unless you become a SWDE customer. 
 

C.    Creating an account on our website and accessing the features offered by our website

Data types – These may include: 

• identification details(gender, surname, first name, date of birth)
• contact details (home address, telephone number, e-mail address)
• financial details (bank account number)
• connection details (e-mail address, password, etc.)
• consumer details (customer number and account number)

If you want to use the "itsme" service to identify yourself, we also need to collect your National Registration number. It will not be used for any other purpose. SWDE does not want to store NR numbers or copies of the front and back of your identity card. Your National Registration number is automatically deleted 90 days after SWDE closes your customer account.

Purpose of processing – Creating an account on our website allows you to access your customer area and to view and modify your information and your consumption.

Your data is also processed for the purpose of carrying out the tasks in the public interest entrusted to us by the Water Code (Book II of the Walloon Environmental Code) in our capacity as Water Distributor.  This allows us to monitor water quality, manage the network and connections, and deal with distribution crises and incidents. 
Lawful basis for processing – Your data is processed by SWDE in order to supply you with water, monitor water quality, deal with any incidents in the distribution network and inform you about these matters. This processing is necessary for SWDE to carry out the tasks required of us by law as a Distributor. This data is essential therefore to carrying out the tasks in the public interest entrusted to us by the Water Code (Book II of the Walloon Environmental Code) in our capacity as Distributor. Without it, we cannot do our job.

Data recipients – Your data may also be processed by our website host or another IT service provider for the purposes strictly necessary to comply with the instructions we send them. In this respect, they act as subcontractors.

Your data may also be processed by debt collection agencies.

Period kept – For tax, accounting and liability reasons, the data you entrust to us is kept for 10 years from the time when you cease to receive water distributed by SWDE.  The period for which National Registration numbers are kept, indicated above, is an exception to this.

Data processed to carry out our tasks in the public interest as a Distributor is processed for as long as is necessary for carrying out these tasks.

D.    Water distribution and billing

Data types – These may include your surname, first name, date of birth, address or place of residence, telephone number, e-mail address, organisation, billing details, meter number, consumption data, etc. 
Data can be collected when you enter a connection request using the “Connect My Home” platform. Using this, ORES synchronises all operators to make all the utility, cable and telecom connections, including electricity, gas and water, carried out at the request of customers for new buildings in a single operation.

Your consumption data is obtained directly from you, by meter reading or via an easyCONSO smart meter.

Purpose of processing – Your data is used to distribute water to you, to monitor water quality, to calculate your water consumption and to send you bills based on this consumption. 
We also process your data to ensure the recovery of any debts and to manage intervention by public social services centres.
Your contact data may also be processed to inform you of any changes in water prices, distribution conditions or our Data Protection Policy (including new purposes).
Lawful basis for processing – Your data is processed by SWDE in order to supply you with water, monitor water quality, manage any incidents in the distribution network and inform you about these matters. This processing is necessary for SWDE to carry out the tasks required of us by law as a water distributor. This data is essential therefore to carrying out the tasks in the public interest entrusted to us by the Water Code (Book II of the Walloon Environmental Code) in our capacity as Distributor. Without it, we cannot do our job.
Your data is also processed to send you bills relating to your water consumption and to ensure they are paid, in accordance with Articles D.228 and following of the Water Code, and to call in the Water Social Fund, if necessary, in accordance with Articles D.234 and following of the Water Code. 
Data recipients – The data is sent to the social care authorities. It may be passed on to our legal advisors or to a bailiff for judicial debt recovery proceedings. 
Your data may also be processed by our website host or other IT service provider for purposes strictly necessary to comply with the instructions we send them. In this respect, they act as subcontractors.
Period kept – For tax, accounting and liability reasons, the data you entrust to us is kept for 10 years after we complete our tasks.

Data processed to fulfil our legal obligations or complete our tasks in the public interest as a Distributor is processed for as long as is necessary to fulfil these obligations or complete these tasks.

Specifics for VAT-liable companies

Electronic invoicing: As of January 1, 2026, when you act as a VAT-liable organization, we will issue and receive structured electronic invoices (via the PEPPOL network) in accordance with Belgian law.

For this purpose, we may consult the Crossroads Bank for Enterprises and, where applicable, the public information from the Federal Public Service Finance to verify your VAT status, VAT number, and/or PEPPOL ID.

Legal basis: Your data is processed to comply with the legal obligation to implement electronic invoicing.

Recipients: Electronic invoicing service providers.

Retention: The data you entrust to us is retained for 10 years after the end of our engagement for tax and accounting purposes, as well as for liability reasons.

E.    Additional services and billing

Data types – These may include your surname, first name, date of birth, address or place of residence, telephone number, e-mail address, organisation, billing details, meter number, consumption data, etc. 
Purpose of processing – Our laboratory carries out analyses on different types of water at the request of private individuals or companies. These services are not part of the public interest tasks entrusted to SWDE by law. An estimate is first given for them and they are invoiced separately to the customer. 
Lawful basis for processing – The processing of your data is necessary for the fulfilment of the contract, i.e. your order for a water analysis from the SWDE laboratories. Without it, we cannot carry out these analyses and bill you for this service.
Data recipients – If the results are sent to you electronically, your data may be processed by our website host or another IT service provider for the purposes strictly necessary to comply with the instructions we send them. In this respect, they act as subcontractors.
Period kept – For tax, accounting and liability reasons, the data you entrust to us is kept for 10 years after the end of our contract.

F.    Promoting our services

Data types – Your contact data (surname, first name, postal address, e-mail address, mobile phone number) may be used to promote our services.

Purpose of processing – We process this data in order to send you communications that may be of interest to you (development of new tools or features). 
In this way, we can keep you informed about our features, services and news.
Lawful basis for processing – Our legitimate interest in promoting our services provides justification for offering information or promoting our company's services to our existing customers. As a result, you may receive communications containing information about our services.

Data recipients – Your contact details may be passed on to e-mail service providers used by SWDE.

Period kept – We keep your contact data for this purpose until you ask us to stop.

You can notify us at any time that you no longer wish to receive information. Simply click on the unsubscribe link at the bottom of any electronic communication that we send you for this purpose.

G.    Quality control of our services

Data types – We may record telephone calls you make to our Customer Service department.

We may also send you satisfaction surveys to obtain your opinion on the quality of our services or products (water quality, flow or pressure of the supply, speed of actions, quality and accessibility of Customer Service, quality and time taken to deal with your requests, clarity of our information and documents, etc.).

Purpose of processing – Certain calls selected at random (after the customer’s prior agreement) are recorded to monitor the quality of support provided by our Customer Service department. 
Our Customer Service department also analyses the answers you give to our satisfaction surveys in order to improve our services and products.

Lawful basis for processing – This processing is carried out to fulfil SWDE's legitimate interests in improving its services. 
When you call our Customer Service department, you will be informed that the call may be recorded and you can refuse to agree to recording. This allows you to exercise your right to refuse in advance, without giving reasons. 
When we invite you to take part in a satisfaction survey, you are entirely free to refuse and not to follow up this invitation.  

Data recipients – This data is processed by our Customer Service department managers.

Period kept – Recordings of telephone conversations are deleted after 30 days. 
Responses to satisfaction surveys are kept for no more than six months after the end of these surveys, unless you have agreed to SWDE following up a request you have made in the context of one of these surveys. In that case, for tax, accounting and liability reasons, the data you entrust to us is kept for 10 years after our task is completed.

H.    Exercising your rights 

Purpose of processing – When you exercise the rights conferred on you by the GDPR and described in this data protection policy (right of access, rectification, etc.), we keep the data strictly necessary to prove we have taken appropriate action in response to your requests. 
Lawful basis for processing – This data is kept based on the legal obligation imposed by Article 5.2 of GDPR, namely the duty of accountability. 
Data types – These are your surname, first name, request, and proof of the action taken by SWDE in response to the request.  
Data recipient – This data is not passed on to any recipient other than the data protection authority or our advisers.

Period kept – We keep your data for as long as we may be held liable for failure to comply with requests, i.e. for no more than 10 years.

  
I.    Social media

Data types – These may include details relating to your account and details relating to content sharing or to your communications with other people.

Purpose of processing – The data you provide by visiting our social media pages is, or may be, processed jointly by the social network concerned and by our administrator of these pages for the following purposes: 

• to collect certain data using cookies; 
• to allow the social network concerned to improve its advertising system; 
• to share information from our website on social media using its "share" buttons;
• to obtain audience statistics for these pages. 

Lawful basis for processing – This data will only be processed by our administrator of these pages in the context of their legitimate interest in obtaining statistics on visitors to these pages in order to promote them appropriately. The audience statistics established by each social network concerned are transmitted to our page administrator only in anonymised form.

When you use the information sharing buttons, the processing of your data is based on your consent. This means that when you visit our website, data is never automatically transmitted to a social network. Only when you click on the button corresponding to a social network (= by clicking on the social network’s icon) will your browser connect to the social network’s servers. You then consent to your browser connecting to the social network’s servers and sending usage data to the social network operator.

Data recipients – It may be necessary to pass on the data to our employees, suppliers, external service providers or consultants to achieve this purpose.
Period kept – This data is, or may be, processed for as long as the page exists and you visit it.
The personal data use policies of each social network can be found by clicking on the following links:

• Facebook 

• YouTube,

• LinkedIn,

• Instagram

J.    Job application management  

Data types – We process your identification and contact details as well as your professional details (CV, covering letter, qualifications, languages, experience, etc.).

Purpose of processing – If you send us an unsolicited application – for example via our web page specifically for recruitment (accessible via the “Jobs” menu on our website) – or respond to a job advertisement issued by SWDE, your data will be processed at your request to assess the possibility of a contractual relationship.

Lawful basis for processing – Processing is necessary to take pre-contractual measures, at the request of the data subject.

Data recipients – Data is shared only with SWDE recruiters.  

Period kept – If your application is unsuccessful, the data you provide us with as part of a job application will be kept for no more than 12 months after the end of the selection process.

K.    Compliance with our legal obligations and requests from municipal or government authorities.

Data types – For this purpose, we process your identification data and data relating to your consumption.

Purpose of processing – If SWDE receives a legitimate request from the police or other law enforcement agency, your personal data will be shared with the police or law enforcement agency concerned.

Similarly, SWDE processes your data so it can respond to requests from local authorities concerning dwellings presumed to be unoccupied by sending them a list each year of buildings consuming less than 15m3 of water per year:

as part of the Walloon Region's fight against unoccupied housing (Article 80 §1 of the Walloon Sustainable Housing Code) and/or
in the context of establishing a municipal tax on unoccupied and/or dilapidated buildings intended for housing) (Article 327, §1 of the CIR92, applicable to municipalities under Article L3321-12 of the CDLD).

Lawful basis for processing – The processing is necessary for SWDE to comply with a legal obligation.

Data recipients – Data may also be shared with the police and other competent public authorities, as well as with municipal authorities when it comes to combating unoccupied housing. The data may also be sent to our lawyer and/or bailiff in the event of a legal dispute.

Period kept – We will keep your data for as long as we are liable for any failure to comply with requests, i.e. for no more than 10 years.

L.    Security of our premises and equipment

Data types – These are video surveillance images and the register visitors are required to complete in the “Reception” area at the entrance to some of our sites.
Purpose of processing – Your data is processed in as far as is necessary to ensure the security of our infrastructure, equipment and events organised there, and to protect people.
Lawful basis for processing – We process your personal data for the purposes of our legitimate interest in securing our premises and equipment and protecting individuals.
Data recipients – The visitor register and video surveillance images are not passed on to any third party. However, they may be transferred to the relevant police service on request. 
Period kept – Video surveillance images are not kept for more than 30 days. Visitor register data is deleted after 30 days.

Recipients of your data

In the course of our business, we may pass on your personal data to the following recipients:

•    Debt collection agencies, lawyers, bailiffs;
•    Mail management company;
•    Call centre company;
•    Printing companies;
•    Companies responsible for conducting satisfaction surveys;
•    Social services centres (any consumer who may be eligible for benefits can receive financial support for paying their water bills. This support is based on a fund known as the "Social Water Fund". This fund is provided for in Articles 234 to 251 of the Belgian Environmental Code, Book 2. — Belgian Water Code);
•    SPGE (Public Water Management Company), particularly in the context of the public management of household sanitation, in accordance with the data framework protocol concluded on 12 May 2021 between the SPGE and the SWDE; 
•    Public bodies/authorities.

Website

Our website contains hyperlinks to third-party websites and information about them. We have no control over these sites, and are not responsible for their confidentialitý policies, which we invite you to consult.

Location of your data

In the European Union – In principle, your data will only be stored on servers located in the EU.

In the event of transfer outside the European Union – Your data will only be transferred to a country that does not offer an adequate level of protection if the handling of your case requires the sharing of information with legal professionals from non-EU countries.

In such cases, we naturally ensure that recipients are obliged to comply with the same data protection standards as in the EU by means of appropriate contractual clauses and additional measures. You can obtain a copy of these guarantees on request.

Data security and confidentiality

In accordance with standard industry practice, we use technical and organisational measures to ensure an appropriate level of security for the personal data processed. Nevertheless, security requires the efforts of all parties involved. We therefore encourage you to support these efforts by taking appropriate security measures yourself, including using strong passwords and keeping all usernames and passwords (if any) confidential.

We train our staff in the proper use of confidential data.

 Your rights

Information – This right is exercised via this document. If the data processed includes your staff's data, you must ensure they are familiar with the document.
Access and rectification – You have the right to access your data and have it rectified if necessary.
Objection – You may object to the processing of your data by us on the basis of our legitimate interest.
Withdrawing your consent – When data is processed on the basis of your consent, you may withdraw this at any time, without calling into question any past processing. 
Erasure – You may have your data erased or insist on restricted processing under the conditions set out in Articles 17 and 18 of the General Data Protection Regulations.
Portability – The data you have provided us with can be passed on to you or to a third party of your choice in electronic format.
Lodging a complaint with the Data Protection Authority – As a data subject, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data breaches the applicable personal data regulations.
For more information on this subject:
https://www.autoriteprotectiondonnees.be/citoyen/vie-privee/quels-sont-mes-droits-

Who to contact

The data controller, Société Wallonne des Eaux, entered in the register of legal entities under number 0230.132.005, with its registered office at 4800 Verviers, Rue de la Concorde 41, and its data protection officer, will be happy to answer any questions you may have or deal with any requests relating to the rights set out above:
SWDE Data Protection Officer, Rue de la Concorde, 41, 4800 Verviers; E-mail: dpo@swde.be).  
If you would like further information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse, 35 - 1000 Brussels, Tel. + 32 2 274 48 00 - https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).

Amendments to this policy

The Policy may be corrected, added to or amended at any time for various reasons. The most up-to-date version can be consulted on our website at any time. We invite you to consult it regularly.

Applicable law

This policy is governed by Belgian law. Any legal dispute relating to the interpretation or implementation of this policy will be subject to Belgian law.

This Data Protection Policy was updated on 22 January 2025.