Privacy Notice EC04 Flex and GBIS

Spelthorne Borough Council ECO4 Flex and GBIS Privacy Notice

This privacy notice is designed to help you understand how the Council may process your personal data for the purpose of the ECO 4 Flex and Great British Insulation Scheme (GBIS).

The Energy Company Obligation (ECO) is an obligation on energy suppliers aimed at helping households cut their energy bills and reduce carbon emissions by installing energy saving measures.

The Council has issued a Statement of Intent in accordance with the Electricity and Gas (Energy Company Obligation) Order 2022. This confirmed that the Council intends to identify households that may benefit from heating and energy saving measures.

The Sustainability and Climate Change Team at the Council is responsible for administering ECO4 Flex and GBIS.

ECO4 Flex and GBIS run until 31 March 2026 and is regulated by Ofgem. 

We are the data controller for the personal information we hold about you in relation to processing of applications for flexible eligibility for this scheme. To comply with data protection legislation, we want to be sure you understand how we use this information.

Whose personal data do we process?

We will process the personal data of households who have been identified as potentially eligible under ECO4 Flex and GBIS and submitted to the Council on your behalf. 

What personal data do we process?

The personal data we process may include: 

1. Contact information including your name, address, telephone number, email address;
2. Identification evidence including photograph ID, date of birth and National Insurance number;
3. Date of birth and National Insurance number;
4. Household status including whether you are a homeowner or occupier, council tax letters, mortgage statements;
5. Financial information including details of income, tax returns, P60 documentation, pension statements, P45 documentation, credit checks, benefit entitlement, Council tax reduction evidence, bank statements; 

We may also need to consider personal data which comprises Special Categories of Personal Data relating to your health. This may include: 

1. Details of GP/Hospitals/ NHS trusts;
2. Medical and health conditions;
3. Eligibility for benefits due to medical or health conditions; 

Why do we process personal data? 

As the Council has issued a Statement of Intent, it is required to assess and determine whether a household is eligible under ECO4 Flex and GBIS. 

The Council must consider the relevant supporting evidence to determine that one of the routes referred to in the Statement of Intent is met. It will then issue a declaration. 

The Council must also retain this information in accordance Ofgem's audit requirements until 31 March 2029.

The Council is not involved with the selection of contractors available to work within the ECO4 flex scheme and GBIS. It will be for the individual to ensure their credentials are genuine. The Council will ask contractors requesting approval to supply their company details holding them for future audit by Ofgem. The Council is not involved in any part of an installation, its approval or the amount of funding available to any applicant. The Council's role is only to verify resident details supplied.

Where do we get your personal data from?

Your personal data is provided to the Council by approved Installers who will identify if you are in a potentially eligible household. They will collect the relevant evidence and submit that evidence, along with an application form, to the Council on your behalf.  

You may also provide your personal data to the Council directly if you contact us to make enquires about the ECO4 Flex scheme and GBIS.  

The Council will use publicly available data to identify homes which may benefit from available government funding through ECO4 flex and GBIS. Homes with low energy performance certificates, Census information and known areas of deprivation. 

Who do we share your personal data with?

Ofgem, Action Surrey & approved installers

What is the legal basis for using your personal data?

We rely on the following lawful basis to process personal data for ECO4 Flex: 

• Public Task: The processing is necessary for the Council to perform a task in the public interest or for its official functions with a basis in law. 

The legislation that relates to ECO4 Flex includes, but is not limited to: 

• Electricity and Gas (Energy Company Obligation) Order 2022
• Digital Economy Act 2017 

We rely on an additional lawful basis to process your Special Categories of Personal Data. The lawful basis is "Reasons of substantial public interest (with a basis in law)" meeting the condition in Schedule 1, Part 2 of the Data Protection Act 2018 as below: 

• (6) Statutory etc and government purposes.  

You have the following rights:

·         you have the right to be informed via Privacy Notices such as this

·         you have the right to request access to and to receive a copy of any information we hold about you (including in an electronic format) - to request a copy of this information you must make a subject access request in writing

·         if you find that the information Spelthorne Borough Council holds about you is no longer accurate, you have the right to ask to have this corrected

·         you have the right - under certain conditions - to ask us to erase your personal data

·         you may request that Spelthorne Borough Council stops processing your personal data in relation to any council service (this may delay or prevent us delivering a service to you, we will seek to comply with your request but may be required to hold or process information to comply with our legal duties)

To exercise any of these rights contact the Data Protection Officer at data.protection@spelthorne.gov.uk.

You also have the right to make a complaint to the Information Commissioner's Office (ICO). This is an independent body responsible for making sure that organisations comply with Data Protection legislation.