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Data Protection Complaints Procedure

1. Purpose

NSI Mobile Water Solutions UK Ltd (“Mobile Water Solutions”) is committed to protecting the privacy and personal data of all individuals whose information we process.

This procedure outlines how individuals can raise concerns or complaints regarding the collection, use, storage, sharing, retention, or security of their personal data and how those complaints will be handled.

2. Scope

This procedure applies to all individuals whose personal data is processed by MWS, including but not limited to:

  • Customers
  • Prospective customers
  • Suppliers
  • Website users
  • Employees and job applicants
  • Any individual whose personal data is processed by Mobile Water Solutions

3. Grounds for a Complaint

Individuals may submit a complaint where they believe that:

  • Their personal data has been processed unlawfully or unfairly
  • Their data protection rights under UK GDPR have not been respected
  • Personal data has been used without a valid legal basis or appropriate consent
  • There are concerns relating to cookies, tracking technologies, or analytics
  • Personal data has been disclosed to third parties without appropriate safeguards
  • Personal data is inaccurate, outdated, or being retained for longer than necessary
  • There are concerns regarding the security of personal data

4. How to Submit a Complaint

If you have concerns about how your personal data has been collected, used, shared, retained, or protected, you may submit a complaint using one of the following methods:

Complaints should be submitted using the following contact details:

Email: MWS@nijhuisindustries.com

When submitting a complaint, please provide:

  • Full name
  • Contact details
  • Clear description of the concern
  • Relevant dates or context
  • Any supporting information (where available)

If insufficient information is provided, Mobile Water Solutions may request additional details to properly investigate the complaint.

5. Complaint Handling Process

5.1 Logging and Acknowledgement

All complaints will be acknowledged within 5 working days of receipt.

The acknowledgement will include:

  • Confirmation that the complaint has been received
  • A reference number (where applicable)
  • The name of the person handling the complaint
  • Expected timescales for investigation

5.2 Investigation

Each complaint will be reviewed by the Data Protection Lead (or designated representative).

The investigation may include:

  • Review of relevant internal records and systems
  • Review of consent and cookie management records (where applicable, e.g. Cookiebot)
  • Review of CRM, marketing, and communications data
  • Review of analytics and website tracking configurations (e.g. GA4, GTM)
  • Consultation with relevant internal teams and external service providers where required

All investigations will be conducted in a fair, proportionate, and confidential manner.

5.3 Response

A written response will be provided within 30 calendar days of receipt of the complaint.

The response will include:

  • Summary of the complaint
  • Outcome of the investigation
  • Any corrective actions taken or planned
  • Confirmation of the individual’s escalation rights

Where a complaint is complex or requires further investigation, this timeframe may be extended. Where this occurs, the complainant will be informed of the delay and provided with an updated response timeframe and reason for the extension.

6. Resolution and Corrective Action

Where a complaint is upheld, Mobile Water Solutions will take appropriate corrective action, which may include:

  • Correcting or updating personal data
  • Deleting data where appropriate and lawful
  • Updating consent or marketing preferences
  • Reviewing and amending internal processes or controls
  • Implementing technical or organisational safeguards

7. Escalation Rights

If an individual is not satisfied with the outcome of their complaint, they have the right to escalate the matter to the UK Information Commissioner’s Office (ICO).

Information Commissioner’s Office (ICO)

Website: https://ico.org.uk

Telephone: 0303 123 1113

Individuals are encouraged to allow Mobile Water Solutions the opportunity to resolve concerns before contacting the ICO.

8. Record Keeping

Mobile Water Solutions will maintain a secure Data Protection Complaints Register.

Records will include:

  • Complaint reference number
  • Date received
  • Complainant name
  • Nature of complaint
  • Responsible investigator
  • Actions taken
  • Date closed
  • Outcome

Complaint records will be retained for a minimum period of 3 years, unless a longer retention period is required by law or regulatory obligation.

9. Roles and Responsibilities

Data Protection Lead (or appointed delegate) is responsible for:

  • Oversight and coordination of complaint handling
  • Conducting or delegating investigations
  • Ensuring timely responses
  • Maintaining complaint records
  • Escalation management
  • Reporting trends or systemic issues where identified

10. Review

This procedure will be reviewed periodically and updated where necessary to reflect changes in legislation, regulatory guidance, or internal operational requirements.