UK GDPR privacy notices - Warm Homes Healthy People Privacy Notice

Introduction

Warm Homes Healthy People have provided this privacy notice to help you understand how we collect, use and protect your information whilst we assess your eligibility for the schemes we deliver.

The document below will describe how we may collect and process your personal information.

The purpose of this document is to clearly acknowledge the council’s responsibilities in relation to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Definitions

Personal data means any information related to an identified or identifiable natural (living) person (‘data subject’) i.e. a person that can be directly or indirectly identified by reference to a name, ID reference number, email address, location data, or physical, physiological, genetic, mental, economic, cultural or societal identifier.

Special personal data, previously known as ‘sensitive personal data’, relates to race, ethnic origin, politics, religion, trade union membership, genetic data, biometric data, health, sex life or sexual orientation. Records of criminal personal data must also be treated in a similar way.

Data Controller determines the purposes and means of processing personal data.

Data Processor is responsible for any operation which is performed on personal data on behalf of the controller, e.g. collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure or destruction.

Third Party is someone/somebody who is not the Data Controller, the Data Processor or the Data Subject.

Who we are

Warm Homes Healthy People is a Suffolk wide, multi-agency partnership comprising all of the districts and borough councils in Suffolk. The project aims to keep vulnerable households warmer and easier to heat, while increasing health and well-being.

The council is the ‘data controller’ for the information which is collated and processed. This means we are responsible for deciding how we can use your information. If you want more information regarding the services delivered, please go to our website.

The council regards lawful and correct treatment of personal information as critical to their successful operations, maintaining confidence between the council and those with whom they carry out business. The council will ensure that they treat personal information correctly in accordance with the law. Our services are statutory and are governed by the Local Government Act 1972 (as amended).

The services provided by the Warm Homes Healthy People service are discretionary.

The Data Protection Officer for ESC is Siobhan Martin, Head of Internal Audit, and can be contacted at dataprotection@eastsuffolk.gov.uk.

How the law protects you

UK GDPR says that we are allowed to use personal information only if we have a proper reason to do so. More information on how the law protects you can be found on the East Suffolk website.

Our responsibilities

UK GDPR provides us with main responsibilities for processing personal data. All personal information provided by you is held securely and in confidence by us in our computerised and other records. When we process your personal information, we do so in compliance with UK GDPR. For further information on our responsibilities, please see our website.

Your rights

The UK GDPR and DPA 2018 provide you with the following rights:

• The right to be informed: You have the right to be informed about the collection and use of your personal data, and this is outlined in this privacy notice.
• The right of access: You have the right to request access to the personal data we may hold about you. This is undertaken using a Subject Access Request.
• The right to rectification: You have the right to request that inaccurate personal data we hold is rectified.
• The right to erasure: In certain circumstances, you have ‘the right to be forgotten’ and have your personal data erased.
• The right to restrict processing: In certain circumstances, you have the right to request the restriction or suppression of your personal data.
• The right to data portability: In certain circumstances, you have the right to request to obtain your own personal data for your own use or to give to other organisations.
• The right to object: In certain circumstances, you have the right to object to your personal data being collated, stored and processed.
• Rights in relation to automated decision making and profiling: You have the right to request that we do not make our decisions based on solely an automated process, and you can object to an automated decision and ask that a person reviews it in certain circumstances.
• The right to withdraw consent: In our discretionary service provisions, you have the right to withdraw your consent at any time.
• The right to complain: You have the right to complain through our complaints procedure, and then to the Information Commissioner. Any requests in relation to your rights with regard to the personal data we hold should be made verbally or in writing to the Data Protection Officer. For further information on your rights, please see the ICO website.

Your responsibilities

You are responsible for making sure you give us accurate and up to date information, and to let us know if any personal information we hold is incorrect.

When do we collect information about you?

We collect information about you from different places, including:

• From yourself
• From your home survey
• From professionals, such as health workers, who you authorise to share information with us

What information do we maintain?

The information about you which we will maintain will include:

• Name, address, date of birth
• House type and technical features (including number of bedrooms, type of walls and so on)
• Household income, benefits, savings and investments
• Household occupants
• Demographic data such as sex and ethnicity

The sensitive information about you which we may maintain include:

• Health conditions in the household

How do we use your information?

We will be using your information to:

• Assess your eligibility for funding related to your needs
• To enable our installers to survey your home
• Report outcomes and other statistics to our partners and funders
• We will not use your personal data for other purposes other than for what it was collated unless we have obtained your consent or for other lawful purposes (e.g. detection and prevention of fraud).

We do not use any automated decision making.

How long do we keep your information?

We will hold your information until no longer needed for scheme verification eligibility and audit purposes, or your application ends. In some cases where required by our funders, data is stored up to 6 years, for the purposes of occasional randomly selected audits by our funders. You can request that your personal information is deleted at any time. If you request for your personal information to be deleted before any eligibility check has been conducted, you may not be entitled to access any of our current funding opportunities.

Data sharing

We will share your personal information with:

• Suffolk County Council (ICO registration no Z5113825), the primary fund holders of the Warm Homes Fund, Home Upgrade Grant (HUG), and other members of the Suffolk Climate Change Partnership for reporting and audit purposes
• Installers who have been procured and on-boarded to deliver the grant funded works related to your application. These installers will change in line with new grant funds and procurement exercises
• Our funders for audit purposes, Affordable Warmth Solutions (ICO registration number Z1655808), National Energy Action (ICO registration number Z847023X) and Ofgem
• HM Government Department for Energy Security and Net Zero (DESNZ) for reporting purposes.

Transferring your information overseas

Currently, we do not transfer any personal information outside of the European Economic Area (EEA).

National Fraud Initiative (NFI)

We may share information provided to us with other bodies responsible for auditing, or administering public funds, or where undertaking a public function, in order to prevent and detect fraud. For further information, see the East Suffolk website.