Privacy Policy

Community Home Solutions Ltd

Community Home Solutions Ltd are committed to ensuring we comply with General Data Protection Regulation (GDPR).

The below notices set out how your personal data will be used, and your rights under Articles 13 and/or 14 of the UK General Data Protection Regulation (GDPR).

The relevant notice is defined by the Funding route for your installation(s).

What information do we collect?

Community Home Solutions Ltd will process the following personal data on behalf of Scheme funders:

• Address and details of the property receiving installation(s) under the Scheme
• Details about the installation(s) installed at the property, including type, size and cost
• Contact address (if not the same as the property receiving the installation(s))
• Address and details of the property offered, but not receiving the installation(s)
• Full name(s) and titles
• Household income and any other scheme eligibility information, including household occupancy and tenure
• Property address data, including Unique Property Reference Number (UPRN) and pre and post Energy Performance Certificate (EPC) data, EPC xml data, Medium Term Retrofit Plans
• Details about any financial contribution you have made towards the installation(s)
• Details about the expected energy, carbon and cost savings expected to be delivered by the installation, including pre- and post-installation
• Property Energy Performance Certificate (EPC) details where appropriate
• Email address (if available)
• Phone number (if available)
• Health referrals – agencies can refer households to the scheme if they have certain health conditions, the nature of the condition will not be shared by the health professional, but they will provide a declaration that the referral has an eligible condition. (This information will only be shared if we have obtained your explicit consent)
• Customer satisfaction surveys
• Any financial contribution made towards the installation(s) for example from the owners, landlords or other third parties.

Purpose

The purpose(s) for which we are processing your personal data is to support the delivery and administration of Energy Efficiency Schemes.

Delivery and administration of these Schemes may require linking of your data to other datasets held by the Department for Energy Security and Net Zero (DESNZ) or the Office of Gas and Electricity Markets (Ofgem).

DESNZ and Ofgem conduct evaluations of their Energy Efficiency Schemes. 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 delivery of the Scheme, you will be given the opportunity to opt-in to that research at the point of contact.

Your data may also be used for statistical, research and fraud prevention purposes.

Legal basis of processing

The legal basis for processing your personal data is:

Public task: Processing is necessary for the performance of a task carried out in the public interest.

The specific public task is the delivery, administration and evaluation of, as well as statistical, research and fraud prevention purposes relating to Energy Efficiency Schemes aimed at raising the energy efficiency of low energy performance homes (those rated at EPC Band D, E, F or G).

Consent: Use of your personal data to contact you to take part in further research will be subject to your consent.

Sharing your details

Your personal data will be shared with:

• The Department for Energy Security and Net Zero (DESNZ) and its contractors for delivery, administration and evaluation of the scheme, statistical, research and fraud prevention purposes
• The Office of Gas and Electricity Marketing (Ofgem) and delivery partners of central and local government home energy schemes such as the Energy Company Obligation and Renewable Heat Incentive
• Local Authorities participating in the relevant Scheme(s)
• Research organisations working on approved projects for public interest benefit research purposes. Your data will be stored securely at a data archive and made accessible through a secure environment to accredited UK researched working on approved research projects.

Your personal data may also be shared with other Government departments where necessary and as required in support of the Purpose of this Privacy Notice.

We may share your data if we are required to do so by law, for example by court order or to prevent fraud or other crime.

How is personal data collected?

We may use different methods to collect Personal Data including the following:

• You provide us with Personal Data directly, for instance by filling in online forms requesting this information
• We obtain some Personal Data from other sources, including from other people and organisations, including some publicly available sources e.g. HM Land Registry, Companies House, Registrars and background and credit check providers.

If any of the Personal Data you have given to us changes, such as your contact details, please inform us without delay by contacting us using the contact details at the bottom of this notice.

Storing your data

We have put in place appropriate physical and technical measures to safeguard the Personal Data we collect in connection with our services. Save where additional consent is obtained, we limit access to Personal Data to those employees, agents, contractors and other third parties who have a need to know in service of the Purpose. They will only process Personal Data on our instructions and are subject to a duty of confidentiality.

However, please note that although we take appropriate steps to protect Personal Data no device, computer system, transmission of data or wireless connection is completely secure and, therefore, we cannot guarantee the absolute security of Personal Data shared with us over the internet.

Retention

Your personal data may be stored for up to 25 years. Where a guarantee is in place for the installation of an Energy Efficiency Measure, we may retain your data to match the lifetime of the guarantee(s) provided.

We may retain your personal data for up to seven years after the scheme ends, in line with HM Revenue & Customs record management.

The Department for Energy Security & Net Zero will hold some information about the measures installed under the Scheme, including your address and which may include some information about the Scheme eligibility criteria applying to your home or household, but not your name or other personal information, for up to 25 years for policy, research and statistical purposes.

Your rights

As a data subject you have the following rights:

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 where it is processed for direct marketing purposes.

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 of the rights listed above, contact us using the contact details at the bottom of this notice.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF

0303 123 1113
casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

If you wish to exercise any of the rights above, please contact our data protection officer.

ECO4

Introduction

Under ECO4 and The Great British Insulation scheme large energy suppliers provide funding towards energy efficiency measure installations in domestic homes. In order for you to have a measure installed into your home under the ECO4 or The Great British Insulation Scheme we need to collect some of your personal information and share this with other organisations. We will only collect and use personal data in ways that are described here, in a way that is consistent with our obligations and your rights under the law.

The personal data we collect and use

We collect your data directly and this data may include:

• Your name, address, and in some cases your date of birth (so we can check you are eligible for the scheme and contact you regarding your installation);
• Proof of identity (which may be collected to evidence a supporting component or for eligibility evidence);
• Copies of documents showing proof of benefits and income supplied to you by the Department for Work and Pensions, HMRC and the Ministry of Defence (this will be limited to information showing you are eligible for the scheme);
• Your phone number and email address (so you can be contacted as necessary for the Purpose outlined in this notice);
• Optional: the financial amount you have contributed towards the cost of the installation (to help the Department for Energy Security & Net Zero develop future schemes).

Providing your personal data

We will tell you if providing some of your personal data is optional. In all other cases you must provide your personal data, or we will be unable to install a measure into your home under ECO4 or The Great British Insulation Scheme.

Using your personal data: legal basis and purpose

We will process your personal data:

• As necessary to fulfil our contract with you, e.g
  • to manage and undertake the contract (including the installation of a measure into your property).
• As necessary to pursue our legitimate interests, e.g.
  • to check you are eligible for ECO4 or The Great British Insulation Scheme;
  • to share your data with third parties who administer, support or enforce ECO4 / The Great British Insulation Scheme (as specified under ‘Sharing your personal data’).
  • to collect the financial amount you have contributed towards the cost of the installation.
• As necessary to comply with a legal obligation, e.g.
  • where you exercise your rights to make requests under data protection law.

In some circumstances we may need to process special categories of data (e.g., Information related to your health as evidence you are eligible for the scheme). In these cases, we’ll need to rely on an additional condition for processing this information. Where the data is being processed by a government body, local authority, the Crown or a Minister of the Crown under the exercise of its functions under an enactment or rule of law, this will be based on a substantial public interest.

Any data processing of your disability benefit data will also be carried out in compliance with an “appropriate policy statement” a copy of this will be provided on request.

Sharing your personal data

• We will share your personal data with:
  • if necessary the Department for Work and Pensions 3 will profile your data in order to provide a YES/NO response via the Energy Saving Trust4 to verify whether or not you receive the relevant benefits to be eligible for the scheme;
• The Office of Gas and Electricity Markets (Ofgem)4 will:
  • use and share your information in order to fulfil its statutory duties;
  • if requested, share your information with the installer of the measure in order to verify whether it has been notified to Ofgem;
  • if necessary, share your information with auditors contracted to ensure the integrity of the scheme.
  • when required, disclose your personal information to the Secretary of State of the Department for Energy Security & Net Zero. They may use the data to review and develop Government policy, and for research and statistical purposes and may, for these purposes, link the data with other data sources they hold. They may also share some of the data with other Government Departments and with the Scottish and Welsh Governments for these purposes.
• The obligated energy supplier5 (who will make a contribution towards the cost of the measure; and will process data as necessary to comply with a legal obligation 5 and in accordance with their own privacy policies);
• Trustmark: The government-endorsed quality scheme TrustMark who provide assurance, certainty and protection to homeowners and is responsible for the administration of the Great British Insulation Scheme technical monitoring
• Relevant companies supporting the installation:
  • The retrofit coordinator (RC)
  • the installer (who installs the measure);
  • the installer’s certification body (who monitor a sample of installations to ensure they meet the correct standards);
  • technical monitoring agents (who monitor a sample of installations to ensure they meet the correct standards);
  • managing agents (who facilitate the funding and installation of measures)
  • external auditing agencies (who provide assurance that the data being processed is correct);
  • building control inspectors (who check installations are installed in accordance with building regulations);
  • guarantee companies (who provide warranties for some measures such as wall insulation);
  • the property owner, social housing provider, local authority or managing agent (as and where applicable);
  • software providers (who process your data).
• Anyone else where it is required by law, where you have been notified of the sharing or for whom we have your consent.
• The information you provide may be transferred to 3rd parties outside of the European Union. However, this will only take place where this is necessary for the Purpose outlined above. We will ensure all appropriate safeguards, including those set out by the ICO 8, are in place to protect your data before any transfer takes place.
• Your data will only be processed for purposes relating to ECO4 or The Great British Insulation Scheme, unless you have specifically consented otherwise.

Criteria used to determine data retention periods

• Retention for measures with a twenty-five year guarantee (including wall insulation): we may retain your personal data for up to twenty-five years, or as needed to match the lifetime of the guarantees provided;
• Retention for all other measures: we may retain your personal data for up to seven years after the scheme ends, in line with HM Revenue & Customs record management
• The Department for Energy Security & Net Zero, will hold some information about the measures installed under the scheme, including your address and which may include some information about the scheme eligibility criteria applying to your home or household, but not your name or other personal information, for up to 25 years for these policy, research, and statistical purposes.

Your rights, including accessing your data or amending correct data

You have certain rights regarding information held about you by the Controller (these do not apply in all circumstances). These include the right:

• to access your personal data;
• to be informed about our processing of your personal data;
• to have incorrect data corrected;
• to data portability (to move, copy or transfer your personal data);
• to have your personal data deleted;
• to have the processing of your personal data restricted, or to object to processing of your personal data;
• to complain to the Information Commissioner’s Office (who can investigate compliance with data protection law), see www.ico.org.uk/concerns/

HUG2

The Midlands Net Zero Hub (MNZH) as part of Nottingham City Council is leading on the regional delivery of a project called Home Upgrade Grant Phase 2 (HUG 2).

HUG 2 is a national government scheme funded by the Department for Energy Security and Net Zero (the Department) which awards grants to Local Authorities for energy efficiency and clean heating upgrades in owner occupied and private rented sector fuel-poor homes off the gas grid. It will provide energy efficiency upgrades and low carbon heating via local authority funding, to households in England that are low income, are off the gas grid or have an Energy Performance Certificate (EPC) between D and G.

The following organisations are separate data controllers who are processing your personal data under this scheme:

• MNZH will use your data for funding compliance and reporting on the Scheme to the Department
• Staffordshire County Council will collect and use your data for funding compliance and reporting on the Scheme to the Department
• Community Home Solutions Ltd will collect your data in order to confirm eligibility for the Scheme, provide customer support and advice about energy efficiency, and if eligible, refer your details into the relevant local authority scheme to enable a survey and installation to take place. When we process personal information relating to you, we will only do so when it is necessary and where we have a lawful reason to do so. We will use the information provided by you for a number of reasons, depending on the service or reasons for interacting with you. When we process your personal information, we will comply with data protection legislation and enable you to exercise your rights contained within the legislation.

What personal information will the data controllers process?

• Your Home address if you are applying, or being referred, for installation of a measure
• Your contact details - and owners (if different) including if you are offered an installation but who do not accept
• Eligibility and funding - details about how and why you were identified by your Local Authority for participation in HUG 2 and details about any financial contributions you have made towards the cost of the installation, including benefit eligibility and details of any additional funding used to support the installations, for example from the owners, landlords or other third parties
• Measures installed - details of the energy efficiency measures or low carbon heating system installed, including type, size and cost
• Property heating scores - pre- and post-installation property SAP or RdSAP assessments with scores
• Details of installers in relation to each installation of a HUG 2 measure, including your contact details and any relevant accreditation or registration information.

Lawful basis for processing

The basis under which we use your personal information for the purposes of administering the Scheme is that this is necessary for the performance of a task carried out in the public interest by the Council or in the exercise of official authority vested in the Council.

Will my information be shared with other organisations or used for other purposes?

The data controllers will only share your personal information with other departments within their organisations and with other organisations when it is necessary to provide the services to you, and when we have a lawful reason to do so. The data controllers may also share your information when we are obliged to by law.

In relation to the Scheme, the data controllers will share your personal information with each other and with the following organisations:

• The Department
• Customer Journey Support
• Installers or assessors of energy efficiency measures appointed by your Local Authority

The information provided by you may also be used for the purpose of any other function carried out by the Council. This may include sharing your information across the Council, or with external organisations. Information about these functions and the legal basis on which information is used for them can be found at www.nottinghamcity.gov.uk/privacy-statement/

The information will only be used for another purpose where it is lawful to do so.

Do I have to provide the information?

You are not obliged by statute to provide the information that is specified here. However, if you do not provide the information we will not be able to assess you for eligibility or administer the Scheme to your property.

How long will the Council retain the data for?

Some of the information that you have provided will be kept for 25 years. This is in order for the Department to detect instances of fraud. The Council publish an Information Asset Register (IAR), this will outline the retention periods for the personal data we process. You can find this IAR on our website www.geoserver.nottinghamcity.gov.uk/information-asset-register/

Information Rights

The UK General Data Protection Regulation provides for the following rights as prescribed by the legislation:

• A right to request a copy of your information
• A right to request rectification of inaccurate personal data
• A right to request erasure of your data known as ‘the right to be forgotten’ • A right to in certain circumstances to request restriction of processing
• A right in certain circumstances to request portability of your data to another provider
• A right to object to processing of data in certain circumstances
• A right regarding automated decision making including profiling

However, the data controllers can restrict the above rights in certain circumstances for example to avoid obstructing an investigation, avoid prejudicing the prevention, detection, investigation or prosecution of criminal penalties or to protect the rights and freedoms of others.

Data Protection Officers

Midland Net Zero Hub (part of Nottingham City Council) you can contact the data protection officer at:

Loxley House
Station Street
Nottingham
NG2 3NG
or at data.protectionofficer@nottinghamcity.gov.uk

Staffordshire County Council
Information Governance Unit
Staffordshire County Council
1 Staffordshire Place
Stafford
ST16 2DH
Or at DPO@staffordshire.gov.uk

Community Home Solutions Ltd
Oaktree House
2 Phoenix Place
Phoenix Park
Nottingham NG8 6BA
Or at info@communityhomesolutions.co.uk

Further Information

For more information about these rights please refer to our detailed privacy statement at:

Nottingham City Council’s Privacy Notice: www.nottinghamcity.gov.uk/privacy-statement

Staffordshire County Council’s Privacy Notice: www.staffordshire.gov.uk/Your-council-and-democracy/Privacy-notices/

Community Home Solutions’ Privacy Notice: Privacy Page