This notice sets out how your data will be used and shared during your application to the Warmer Homes scheme, and your rights. In order to process your application, your data will be shared with our scheme managers, AgilityEco. In order to provide reports to the funders, your data will also be shared with the department for Business, Energy and Industrial Strategy (BEIS).
Your data and BEIS
BEIS will process the following personal data:
- Your name
- Address and details of property receiving the energy efficiency or low-carbon heating installation(s) under the scheme
- Details about the installation(s) installed under the scheme, including type, size and cost
- Contact address (if not the property receiving the installation(s))
- Address and details of property offered, but not receiving, installation(s) under the scheme
- Household income and any other scheme eligibility information
- Any financial contribution you have made towards the installation(s) under the scheme
- SAP or RdSAP assessments with scores
- Email address (optional)
- Phone number (optional)
The purpose(s) for which we are processing your personal data is to support the delivery and administration of the scheme.
Delivery and administration of the scheme may require linking of your data to other datasets held by BEIS.
BEIS will be conducting an evaluation of the scheme. This may include you being contacted to take part in further research. Where the research involves processing of personal data in addition to that already collected for the delivery of the scheme, you will be given the opportunity to opt-in to that research at the point of contact.
Your data may be used for statistical, research and fraud prevention purposes.
Legal basis of processing
Public Task – Processing is necessary for the performance of a task carried out in the public interest.
The specific task is the delivery, administration and evaluation of, as well as statistical, research and fraud prevention purposes relating to, the scheme, a government funded scheme aiming to raise the energy efficiency of low energy performance homes (especially those rated at EPC Band E, F or G). The government funding is provided to local authorities who set up arrangements for consumer engagement and the delivery of installations in homes.
Consent – Use of your personal data to contact you to take part in further research will be subject to your consent.
Your personal data will be shared with:
- The department for Business, Energy, and Industrial Strategy (BEIS) and its contractors for delivery, administration and evaluation of the scheme, statistical, research and fraud prevention purposes.
- Ofgem and delivery partners of central and local government home energy schemes such as the Energy Company Obligation and Renewable Heat Incentive.
Your data may also be shared with other government departments where necessary.
We may share your data if we are required to do so by law, for example by court order to prevent fraud or other crime.
Personal data shared with BEIS will be stored on our IT infrastructure and may therefore also be shared with our data processors Microsoft and Amazon Web Services. As personal data shared with BEIS will be stored on our IT infrastructure and may be shared with our data processors Microsoft and Amazon Web Services, your data may be transferred and stored securely outside the UK and European Economic Area. Where that is the case, it will be subject to equivalent legal protection through the use of Model Contract Clauses.
Your personal data will be stored securely by BEIS for a maximum period of 25 years following the close of the scheme. BEIS may chose to store anonymised data beyond this period.
You have the right to request information about how your personal data are processed, and to request a copy of that personal data.
You have the right to request that any inaccuracies in your personal data are rectified without delay.
You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.
You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.
You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.
You have the right to object to the processing of your personal data.
You have the right to withdraw consent to the processing of your personal data at any time, where processing is based on your consent.
How to make a request
If you wish to make a request associated with any if the rights listed above, contact BEIS using the contact details at the end of this notice.
If you consider that your personal data has been misused or mishandled, you make a complaint to the Information Commissioner, who is an independent regulator. They can be contacted at:
Information Commissioner’s Office
0303 123 1113
Any complain to the Information Commissioner is without prejudice to your right to seek redress through the courts.
You can contact the BEIS Data Protection Officer at:
BEIS Data Protection Officer
Department for Business, Energy and Industrial Strategy
1 Victoria Street
Your data and AgilityEco
AgilityEco operates Warmer Homes in conjunction with a wide variety of partners, details of whom can be provided to you at your request. Our partners include, but are not limited to:
1. Local Authorities;
2. Social Housing Providers;
3. LEAP (Local Energy Advice Partnership)
4. Bierce (operating our telephone contact centre)
5. Central Heating Installers
6. Gas Distribution Network Operators
Your local council, housing association or other local agency may have referred you to us, in which case you will have been asked by them to give your consent for your contact details and other personal information to be provided to us so that we can assess whether you qualify for the scheme and where you do, for us to contact you directly. Personal information we may collect from you may include information on your health and personal circumstances. You do not have to disclose any information to us that you feel uncomfortable sharing with us at any stage during the Warmer Homes service.
If you have previously consented to us contacting you, but have changed your mind, you may withdraw this consent at any time by contacting us using the information given in this Privacy Notice.
Data requested from you
In line with our principles, in addition to electronic data automatically collected when you use our website, in order to provide you with a service or to respond to any questions or queries you may have, we may request and collect the following data from you:
1. Your name; and
2. Your contact Information such as email addresses and telephone numbers.
Data provided to us through our contact form, or where you e-mail us, is processed by us with your consent. You may remove your consent at any time by contacting us using the information given in this Privacy Notice.
When we receive your enquiry, we will contact you by telephone using the number(s) you have provided and will then seek your consent to collect further information about your personal and household circumstances in order to establish whether you are eligible for the Warmer Homes service and to ensure that we provide you with the best service that we can through the scheme. This information may include:
1. Household income information
2. Names of any state benefits you receive
3. Relevant information about health problems
Our use of your data
Where you have requested we provide you with a service, we will keep your data for the purposes of evidencing that you were eligible to receive the service, and to ensure we tailor the service to your needs or for other closely related purposes. For example, where you are provided with a service from us, we may contact you to ask you if you were happy with the service and if there is anything we can do to improve our service. We will never rent or sell any of the data you provide to us, and any third parties we use will only ever process your information for us on a need to know basis and in accordance with this Privacy Notice.
We will only provide you with marketing information where you consent to this, and you can withdraw consent or change your preferences about marketing activities at any time by contacting us using the details set out above.
Our Data Retention Policy
Other than data we are legally obliged to keep for longer periods, e.g. taxation records, we will retain any data you submit to us for between 18-24 months in order to comply with regulatory requirements. This includes e-mail correspondence. All of your data which we collect is stored securely with appropriate physical, managerial and electronic safeguards in accordance with the principles of the General Data Protection Regulation and any other applicable legislation.
Third Party Access to your data
We strive to keep third party access to your data to a minimum. However, data provided by you to us may in some circumstances need to be passed to third parties which we use for the running of our scheme, for example:
1. to the hosting provider of our website;
2. to Zoho Corporation who host our cloud based data;
3. to third party suppliers working for the Warmer Homes programme.
Information passed to third parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties for us will be processed within the terms of this Privacy Notice and in accordance with the General Data Protection Regulation.
Your access to your data which is held by us
Under the General Data Protection Regulation you have certain rights as regards the personal data we hold on you. Where you would like to exercise these rights, you can do so by using a Subject Access Request or (‘SAR’).
In a SAR you can ask us if we hold personal data on you, and if so, request a copy of that data. We will also give you a description of the data, tell you why we are holding it and tell you who we could have disclosed it to. We do not charge for the provision of this information.
You can also use a SAR to:
• ask us to rectify data on you which is incorrect;
• ask us to stop processing data on you;
• ask us to delete the data we hold on you;
• ask us to stop processing your data;
• ask us to transfer your data to another Data Controller/provide you with your data in a machine readable format;
• object to us processing your data (including for use in direct marketing); and
• exert rights in relation to automated decision making and profiling.
We will reply to all requests as soon as possible, and in no event later than one month. Not all of these rights may be available to you, and will depend on the lawful basis we process your information. For more information on your rights under The General Data Protection Regulation, please see the ICO website.
Transfers outside the European Economic Area (‘EEA’)
Some of our third party service providers may be located out-with the EEA, including Zoho Corporation who we use for cloud based data storage. Therefore personal data which we collect from you may be stored, processed in and transferred to such countries, which may not have as stringent data protection laws as found in the EEA. If we transfer your data outside the EEA in this way, we will ensure that the third party provider which we use is compliant with the GDPR and that your privacy continues to be protected as outlined in this Privacy Notice.
Changes to our Privacy Notice
Although any changes are likely to be minor, we reserve the right to change and update this Privacy Notice as we may deem necessary from time to time or as may be required by law. Your continued use of this website after any changes means you are deemed to have accepted any change to the terms of this Privacy Notice. As and when any changes occur, they will be set out on a change log. There are currently no changes.
Right to lodge a complaint
Our supervisory authority is the ICO and you have the right to lodge a complaint with them if you do not feel we have adequately upheld your rights under the GDPR. Contact details for the ICO can be found here. In addition to complaining to the ICO, where you feel we have breached your rights and the privacy of your data, you are also entitled to pursue action against us in the courts or other legitimate legal forums, such as arbitration or dispute resolution.
Governing law and jurisdiction
This Privacy Notice governed by English law and any disputes will be subject to the exclusive jurisdiction of the English courts.