Home Upgrade Grant (phase 2): privacy

This privacy notice tells you what to expect when we (Hart District Council) collect personal information about you. It applies to data collected under the Home Upgrade Grant Phase 2 (HUG2) operated by Hart District Council which is funded by the Department for Energy Security & Net Zero (DESNZ).

Please read DESNZ Privacy Notice 

This privacy notice should be read in conjunction with the Council's overarching privacy notice

Service area covered by this privacy notice

Climate Change

Purpose of the processing

The purpose for which we are processing your personal data is to support the delivery and administration of the HUG 2. 

Delivery and administration of the HUG 2 may require the linking of your data to other data sources held by DESNZ and other government departments, and shared with the Office of Gas and Electricity Markets (Ofgem), DESNZ contractors and other third parties for this purpose. 

The Council may process some special category data (e.g. health information) in order to support the delivery and administration of the HUG 2, but this data will not be shared with DESNZ

DESNZ will be conducting an evaluation of the HUG 2. 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 HUG 2, 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. 

The information we collect will be included in reports, statistics and returns to central government, where required. Any information for publication or use, outside of Council staff, to support the delivery and administration of the HUG 2 will be anonymised and will not identify any individuals.

Lawful basis for processing personal data

Any personal data, including special category data, that we process about individuals is done so in accordance with Article 6 and 9 of the UK GDPR and Schedule 1 of the Data Protection Act 2018 (DPA 2018) which 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, the HUG 2, a government-funded scheme aiming to raise the energy efficiency of low energy performance homes (those rated at EPC band D, E, F or G), including off-gas grid homes. Funding is provided to local authorities who engage with consumers and manage 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. 

The legal basis for DESNZ processing your personal data for further research is your opt-in consent.

Conditions for processing special categories of personal data

Substantial public interest - the legal basis for processing your sensitive personal data.

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Our Appropriate Policy Document provides further information about this processing. 

Who the data might be shared with

Your personal data will be shared with:

• relevant staff at Hart District Council
• Agility ECO
• Cambridgeshire and Peterborough Combined Authority (CPCA) and/or DESNZ for evaluation, auditing, research, statistical and fraud prevention purposes
• Ofgem, DESNZ contractors and other third parties for these purposes 

CPCA is the accountable body for the HUG 2 for DESNZ. Please read CPCA's 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.

As your personal data will be stored on our IT infrastructure, it will also be shared with our data processor Microsoft (who provide email and file storage services).

Personal data shared with DESNZ will be stored on their IT infrastructure and will therefore also be shared with their data processors Microsoft and Amazon Web Services.