Home Upgrade Grant Phase 2 (HUG2) Privacy Notice

Home Upgrade Grant (HUG) funding allocated to local authorities by Department for Energy Security and Net Zero (DESNZ) aims to improve the energy efficiency of low energy performance homes not connected to the mains gas grid for heating.

How we use your information

The categories of information that we collect, process, hold and share include:

  • personal information (such as name, address, contact information, name and ages of people and children living at the property, contact address (if not the property receiving HUG2 installation) National Insurance number and bank account details, home ownership and tenure)
  • income information (such as benefits checks and earned income)
  • property information (such as address of property receiving the HUG2 installation(s), property type and characteristics, details of installation installed at property including type, size and cost, address of property offered, but not receiving a HUG2 installation(s))
  • scheme awarded grant amount and any financial contribution you or others have made towards the installation(s) under the scheme.
  • information of previous access to government grant schemes
  • details about the expected energy, carbon and cost savings expected to be delivered by the installation, including pre and post installation property EPC details where appropriate.
  • Customer referral source or customer source for initial awareness of the scheme
  • Other scheme participation information, such as local authority, scheme reference number, unique property reference, property type and characteristics including EPC rating.
  • Photographs

Personal data collected about installers to the HUG2 scheme.

  • Personal information (such as name, address, contact information)
  • Relevant accreditation and registration information
  • Details of HUG2 installations delivered; whether directly contracted or subcontracted by TMBC to install HUG2 installations
  • The number of employees in your organisation

Why we collect and use this information.

We use your data to support the delivery and administration of the scheme:

  • enable us to carry out specific functions for which we are responsible
  • enable us to assess applications for grant funding
  • enable us to monitor the use of HUG2 funding and create a record of installations and share this with DESNZ.
  • provide statistics to DESNZ and its delivery partners/agents which may include you being contacted by them to take part in further research. 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, audit, and fraud prevention purposes.

The lawful basis on which we use this information.

The lawful basis for processing your personal date is Article 6(1)(e) UK GDPR 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.

For the scheme, the applicable legislation is:

Local Government Act 1972

Localism 2011, s1

Warm Homes and Energy Conservation Act 2000 

The specific task is the delivery, administration, audit, and evaluation of the Scheme as well as statistical and fraud prevention purposes relation to the scheme.

Collecting this information

Whilst the majority of the information you provide to us is mandatory, some of it is provided to us on a voluntary basis. In order to comply with the data protection legislation, we will inform you whether you are required to provide certain information to us or if you have a choice in this.

Storing this information

Your personal data will be stored securely for a maximum period of seven years after March 2025.

Who we share this information with

We routinely share information with:

  • internal departments (such as council tax)
  • the applicant’s landlord (such as private sector landlords and housing associations)
  • The appointed HUG2 managing agent EON Energy Solutions Limited and their subcontractors including installer, retrofit roles consultant PAS 2035.
  • 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.
  • Ofgem, and other organisations administrating central and local government home energy schemes such as the Energy Company Obligation and Renewable Heat Incentive. This is to prevent the duplication of support or other breach of scheme rules.
  • Trustmark for the purpose of upholding installation standards
  • H M Land Registry

Why we share this information.

Delivery and administration of the scheme may require linking of your data to other data sets held by the Data Controllers.

We share data with our council tax department to enable us to assess an applicant’s eligibility for grant funding in accordance with HUG2 eligibility criteria.

We share data with the applicant’s landlord to help us assess the eligibility of an applicant’s home. This data sharing enables us to, where necessary, obtain the landlords permission for works to be carried out and to process the landlord HUG2 contribution to the cost of works.

We routinely share data with our HUG2 scheme Managing Agent E.ON who are responsible for delivering the HUG2 scheme including supporting customers and checking eligibility.

We routinely share data with E.ON to monitor key scheme performance targets which we report on to DESNZ and in some cases Greater Southeast Net Zero Energy Hub.

Your personal data may also be shared with other Government Departments where necessary. We may share your data if required to do so by law, for example by court order or to prevent fraud or other crime.

Data collection requirements

To find out more about the data collection requirements placed on us by DESNZ and how they will use this data, see Annex 5 BESNZ Template Privacy Notice for installers, householders and landlords.

Requesting access to your personal data

Under data protection legislation, you have the right to request access to information about them that we hold. To make a request for your personal information please contact Adrian Stanfield, the council’s Data Protection Officer at foi@tmbc.gov.uk.

You also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress
  • prevent processing for the purpose of direct marketing
  • object to decisions being taken by automated means
  • in certain circumstances, have personal data rectified, blocked, erased, or destroyed; and
  • claim compensation for damages caused by a breach of the data protection regulations

If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at How to make a data protection complaint to an organisation .

Further information

If you would like further information about this privacy notice, please contact Adrian Stanfield, the council’s Data Protection Officer at foi@tmbc.gov.uk.

The council collects and uses personal information for a number of purposes across all of its departments and functions. To find out more about how the council uses the personal information it collects, please refer to the Corporate privacy notice.