Notice

Establishing eligibility under the Warm Home Discount: privacy notice

Updated 16 February 2024

© Crown copyright 2024

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This publication is available at https://www.gov.uk/government/publications/establishing-eligibility-under-the-warm-home-discount-privacy-notice/establishing-eligibility-under-the-warm-home-discount-privacy-notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK General Data Protection Regulation (UK GDPR).

Your data

We will process the following personal data.

1. For establishing eligibility:

  • address and location data for domestic properties in England and Wales
  • property characteristics of domestic properties in England and Wales
  • modelled energy costs for domestic properties in England and Wales calculated from property characteristic data
  • name, date of birth, and address data for recipients of certain benefits and Tax Credits in Great Britain

2. For evaluation of the Warm Home Discount scheme:

  • the first half of post codes (post code stub)
  • unique property reference number (UPRN)
  • electricity meter point administration number (MPAN)

3. For monitoring of the Warm Home Discount scheme, all data items listed in 2 (for evaluation) and in addition:

  • benefit type
  • age
  • gender
  • receipt of a disability benefit
  • household composition (number of adults and children)
  • property characteristics

Purpose

The purposes for which we are processing your personal data are:

1. Establishing eligibility. To identify households eligible for a rebate under the Warm Home Discount scheme. The data processing enables government to both identify households eligible for an automatic rebate and to contact households who are eligible or potentially eligible by letter.

2. Evaluation of the Warm Home Discount scheme. Your personal data will be processed for activities including but not limited to:

  • sampling – the activity of using your personal data to contact you, to invite you to participate in research activities, including but not limited to surveys and interviews
  • data analysis – the activity of carrying out statistical activities on your personal data, either in isolation or combined with other datasets

3. Monitoring the Warm Home Discount scheme. Your data will be processed for activities including but not limited to:

  • monitoring Warm Home Discount rebates issued in each scheme year
  • the publication of Official Statistics
  • data analysis – the activity of carrying out statistical activities on your personal data, either in isolation or combined with other datasets
  • linking - your data may be linked to other datasets in which your data is stored for monitoring purposes

The legal basis for processing your personal data under the UK GDPR is:

Article 6 (1)(e) Public task: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

The Warm Home Discount scheme’s objective is to address fuel poverty, which is an objective of public interest and is laid out in law in the Schedule of The Digital Government (Disclosure of Information) Regulations 2018 and the Warm Homes and Energy Conservation Act 2000. The scheme from 2022/23 until 2025/26 is in the Warm Home Discount (England and Wales) Regulations 2022 and the Warm Home Discount (Scotland) Regulations 2022.

Section 9 of the Energy Act 2010 provides the enabling powers for the Warm Home Discount as a scheme for reducing fuel poverty.

Sections 35-37 of the Digital Economy Act 2017 and the Disclosure of State Pension Credit Information (Warm Home Discount) Regulations 2011 provide the legal gateways for the data to be shared.

Sensitive personal data includes data concerning a person’s health. The legal basis for processing your sensitive personal data about receipt of disability benefits is:

Article 9(2)(b): Processing is necessary for carrying out the obligations and exercising specific rights of the controller in the field of social protection law.

Recipients

Your personal data will be shared by us with:

  • the Department for Work and Pensions for matching data on receipt of benefits
  • energy suppliers participating in the Warm Home Discount scheme for matching eligible households to customer accounts
  • the Warm Home discount helpline, contracted by Department for Energy Security and Net Zero (DESNZ), to enable the helpline to establish the eligibility of people calling the helpline
  • any contractor or sub-contractors deemed necessary by DESNZ for undertaking monitoring and evaluation activities

As your personal data will be stored on our IT infrastructure it will also be shared with our data processors Microsoft and Amazon Web Services.

The Department currently has an evaluation contract with RSM UK Consulting LLP and Winning Moves (in consortium) who may contact you as part of the evaluation.

Retention

Your personal data will be kept:

  • by us for up to one year after the end of each scheme year for the purpose of establishing eligibility (each scheme year runs between 1 April and 31 March)
  • by the organisations we share your personal data with for an agreed period of time, for up to a maximum of 18 months from receiving the data
  • by us or our contractors for the purposes of evaluating and monitoring the WHD for up to 6 months after this activity has concluded
  • in the case of property-level data extracts (for example households that have received a Warm Home Discount rebate in a given year), for 25 years for statistical analysis and research purposes

Automated decision making

Your personal data may be subject to the following automated decision making:

Core Group 1 / Core Group (England, Wales, and Scotland)

You have been identified as eligible for an automatic rebate because:

  • you were in receipt of the guarantee credit element of pension credit on the relevant date and
  • you have been matched with an energy supplier

Core Group 2 (England and Wales)

You have been identified as eligible for an automatic rebate because you met the criteria set out in an eligibility statement, including the following criteria:

  • you were in receipt of a relevant means-tested benefit or Tax Credit on the relevant date and
  • you were residing in a property on the relevant date with an energy cost score above the threshold as set out in the eligibility statement

If you have been identified as eligible for an automatic rebate, the government will send you a letter confirming that your electricity supplier will apply the discount to your electricity account and you do not have to do anything.

For all other households that are not automatically awarded a rebate, this is not considered to be solely automated decision-making.

If you meet the criteria but the government has not been able to match you with a participating energy supplier, the government will send you a letter advising you to call a Warm Home Discount helpline to establish if you are eligible. You will also receive a letter if we have insufficient data to establish if you are eligible for a rebate.

If you do not meet the criteria on the basis of the data we hold, you may check the eligibility criteria on the Warm Home Discount gov.uk page.

If you believe you should be eligible, you may contact the Warm Home Discount helpline. Please see the privacy notice for contacting the Warm Home Discount helpline.

Where personal data has not been obtained from the data subject

We obtained the data from the following sources:

  • property address (including UPRN), location, and property characteristic data: the Valuation Office Agency, Energy Performance Certificates, the Ordnance Survey, Office for National Statistics, and English Housing Survey
  • property modelled energy cost: calculated by the Department for Energy Security and Net Zero
  • name, address, date of birth, receipt of benefits and characteristics such as age, gender and household composition: the Department for Work and Pensions
  • name, address, income, and receipt of Tax Credits: His Majesty’s Revenue and Customs
  • name and address: your electricity supplier
  • meter point administration number (MPAN): your electricity supplier or the Electricity Enquiry Service

Your rights

You have the right:

  • to request information about how your personal data are processed, and to request a copy of that personal data
  • to request that any inaccuracies in your personal data are rectified without delay
  • to request that any incomplete personal data are completed, including by means of a supplementary statement
  • to request that your personal data are erased if there is no longer a justification for them to be processed
  • in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
  • to object to the processing of your personal data where it is processed for direct marketing purposes
  • to object to the processing of your personal data

International transfers

Your personal data will not be processed outside of the UK.

As your personal data is stored on our IT infrastructure and shared with our data processors Microsoft and Amazon Web Services, it 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.

Updates to this notice

If this privacy notice changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures you are always aware of what information we collect, how we use it, and under what circumstances we will share it with other parties.

The ‘last updated’ date will also change and the revision to the privacy notice will be recorded alongside the date of change. If these changes affect how your personal data is processed, we will take reasonable steps to let you know.

Last updated

16 February 2024

Recipients section amended to include: “The department has an evaluation contract with RSM UK Consulting LLP and Winning Moves (in consortium) who may contact you as part of the evaluation.”

Complaints

If you have a complaint about misuse or mishandling of personal data, you can contact the Information Commissioner, (supervisory authority), who is an independent regulator set up to uphold information rights.

Information Commissioner's Office

Email icocasework@ico.org.uk

Contact form https://ico.org.uk/glo...

Telephone 0303 123 1113

Textphone 01625 545 860

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

Contact details

The data controller for your personal data is the Department for Energy Security and Net Zero (DESNZ).

Contact the DESNZ DPO:

DESNZ Data Protection Officer
Department for Energy Security and Net Zero
3-8 Whitehall Place
London
SW1A 2EG

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