Warm homes local grant scheme privacy notice

Who the data controller is for the information we collect

The purpose of the Warm Homes Local Grant scheme is to improve the domestic energy efficiency of private sector homes in the city. This will involve LCC (Climate Energy and Green Spaces) claiming grant funding from central government, verifying household eligibility, organising contractor works and reporting to central government.

This Privacy Notice is provided to meet the requirements of the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) to explain how we process your personal data in delivering Warm Homes: Local Grant scheme.

Leeds City Council is the data controller for the purposes of the Data Protection Act 2018 and other regulations including the UK General Data Protection Regulation, which means it determines what your data is used for and why it is collected. The contact details of the data controller are Leeds City Council, Merrion House, 110 Merrion Way, Leeds, LS2 8BB.

The data we will collect

To deliver the Warm Homes: Local Grant scheme, we will process the following data:

  • the addresses and corresponding details of properties applying, or being referred, for installation of a measure
  • contact details for the occupants and owners (if different) of the property where the installation took place, as well as details about how and why they were identified by the Grant Recipient for participation in WH:LG and details about any financial contributions they have made towards the cost of the installation
  • details of the energy efficiency measures, or low carbon heating system installed, including type, size, cost and month of completed installation
  • details of any additional funding used to support the installations, for example from the owners, landlords or other third parties
  • pre- and post-installation property SAP or RdSAP assessments with scores
  • details of the installers in relation to each installation of a WH:LG measure, including their contact details and any relevant accreditation or registration information; and
  • contact details for households offered an installation but who do not accept
  • household income status, benefit receipt status, home ownership or tenure status and any other scheme eligibility information
  • lodgement certificate number, lodgement date, installations details from TrustMark and the Microgeneration Certification Scheme
  • customer referral source or customer source for initial awareness of the scheme
  • information of previous access to government grant schemes
  • income data (to check eligibility)

Special Category (including finance data)

  • personal data revealing racial or ethnic origin (for equality monitoring only)
  • data concerning health (for some eligibility criteria and equality monitoring)

How do we collect information about you

We collect information about you from you directly (e.g. by asking you to complete one of our forms, via the telephone through our contact centre or face-to-face).

We may also obtain your information from other sources such as:

  • your family members, carers or other persons acting on your behalf (with your permission)
  • referrals from our internal Council Departments (with your permission)
  • referrals from the Department of Energy Security and Net Zero (with your permission)
  • NHS Trusts (with your permission)
  • The Department of Energy Security and Net Zero (to confirm eligibility)
  • Internal Council Departments (to confirm eligibility)

Why we process your data

We use your information to:

  • assess your eligibility to the scheme.
  • verify the eligibility of your property.
  • to support the delivery and administration of the Scheme. This includes the assessment of expressions of interest by the local authority for the funding of installations at the property, monitoring the use of the DESNZ funding and creating a record of installations.
  • to ensure that a maximum of one property per landlord is fully funded.
  • scheme evaluation.
  • for statistical, research, audit and fraud, error and noncompliance prevention and detection purposes.
  • for the prevention and detection of fraud, error and non-compliance. 

All the data collected will be treated in strict confidence and in accordance with the requirements of the Data Protection Act 2018 and UK General Data Protection Regulation (UK GDPR). The data provided by you will only be used for the purpose(s) specified.

Lawful basis for processing

We will process your data in accordance with UK GDPR Article 6(1(a). The processing shall be lawful only if and to the extent that the following applies:

  • Article 6(1)(a) – the data subject has given their consent to the processing of his or her personal data for one or more specific purposes.
  • Article 6(1)(e) – 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 controller. The specific public task is the delivery, administration, audit and evaluation of the scheme, as well as statistical, research and fraud prevention purposes relating to the scheme. WH:LG is a government funded scheme aiming to improve the energy performance of homes in England rated at EPC Band D, E, F or G. The Government funding is provided to Local Authorities who set up arrangements for consumer engagement and the delivery of installations in homes.

The lawful basis for processing your special category data is in accordance with the following:

  • Article 9(2)(a) UK GDPR the data subject has given explicit consent to the processing of those personal data for one or more specific purposes UK GDPR
  • Article 9(2)g) - processing is necessary for reasons of substantial public interest. 

The processing of special category data under Article 9 are further supported by the following conditions in Schedule 1, Parts 1, 2 and 3: 

  • 6. Statutory and government purposes
  • 10. Preventing or detecting unlawful acts
  • 14. Preventing fraud
  • 37. Insurance

These Schedule 1 conditions require an Appropriate Policy Document to be in place, which sets out and explains the procedures for securing compliance with the principles in Article 5 and policies regarding the retention and erasure of such personal data. 

Our Appropriate Policy document provides further information about this processing.

Withdrawing your consent

You have the right to withdraw your consent from participating in the scheme / service at any time up until any works are carried out. Withdrawing your consent will not affect any services or benefits you receive as a tenant of the Council. However, it may mean you will not be eligible for any energy efficiency measures to your home to improve energy efficiency, lower bills, and reduce carbon emissions. If works are undertaken under the scheme, we will need to retain some of your information for the purposes of scheme administration and audit. If you decide that you no longer wish to participate in the scheme, please contact us.

Data retention, storage and destruction

Leeds City Council

Our data retention policies and procedures are designed to help ensure that we comply with our legal obligations in relation to the retention. This means that your information will be kept for 8 years after we cease to provide a service to you unless the law says that we need to hold it for longer or if there is a business requirement to do so. After this, your information will be deleted or archived.

Department of Energy Security and Net Zero

Your personal data will be stored securely by DESNZ for a maximum period of 25 years following the close of the Scheme but not longer than required. Your personal data for the purposes outlined for fraud, error and non-compliance will be retained and used proportionate to risk relevance and the retention period for data could be stored and used up to 25 years. An individual record may be kept longer if it relates to ongoing actions such as prosecution, appeals or debt recovery.

Who we can share your data with

Leeds City council are obliged to share data relating to suspected fraudulent, erroneous or non-compliant activity with the Department of Energy Security and Net Zero when it is identified. This could include personal data such as address, installer details, measure details etc as relevant to the case.

We will also share your data with:

  • our contractors, who will use this information to undertake and monitor works.
  • the delivery partners and other government departments who will use this information to allocate funds, administer and monitor the scheme.
  • Trustmark, who will use this information to register works for quality monitoring and insurance purposes.
  • OFGEM

The data may be linked to other data sets held by the Department of Energy Security and Net Zero and other agencies listed above for the purposes of evaluation, auditing, research, statistical and for the purposes of prevention and detection of fraud, error and non-compliance (including independent assurance review).

In addition, we will share your personal data:

  • where such disclosure is necessary for compliance with a legal obligation to which we are subject;
  • in order to protect your vital interests or the vital interests of another natural person;
  • for the purposes of security and prevention of fraud and other criminal activity;
  • where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Automated decision making

Your data will not be used for any automated decision making, including profiling.

Your rights

The following rights under data protection law are available under the UK GDPR:

  • the right to access – you can ask for copies of your personal data
  • the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data the
  • the right to erasure - where you can ask us to erase your personal data
  • the right to restrict processing – you can ask us to restrict the processing of your personal data
  • the right to data portability (where you can ask that we transfer your personal data to another organisation or to you
  • the right to object to processing (where you can object to the processing of your personal data) and
  • the right to complain to a supervisory authority – you can complain about our processing of your personal data the right to
  • withdraw consent (to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent

All data rights apply where we process your information based on your consent.

Where we process your data under the public task basis, certain rights to do not apply, such as erasure, data portability and the right to withdraw consent.

These rights are subject to certain limitations and exceptions. You can learn more about your rights through the ‘Your individual rights and how to exercise them’, and the Information Commissioner’s Office website. You may exercise any of the above rights in relation to your personal data by writing to us, using the contact details provided below.

When your data gets sent to other countries

The information you provide will not be transferred to another country outside of the UK by Leeds City Council.

Personal data shared may be stored on the Department of Energy Security and Net Zero’s IT infrastructure and may therefore also be shared with DESNZ’s data processors Microsoft and Amazon Web Services. This means your data may be transferred and stored securely outside the UK or European Economic Area. Where that is the case, it will be subject to equivalent legal protection through the use of Model Contract Clauses.

Contact us

Any queries in relation to this Privacy Notice should be forwarded to:

Name: Climate Energy and Green Spaces Team

Phone: 0113 336 8812

Email: homeenergyhelp@leeds.gov.uk

Data Protection Officer

Aaron Linden

Head of Information Management and Governance - Data Protection Officer

Leeds City Council

Merrion House

110 Merrion Way

Leeds

LS2 8BB

Email: DPO@leeds.gov.uk

The Council privacy notice is available to view here

Complaints

If you are unhappy with the way in which your information has been handled, you should speak with the specific service in the first instance.

Any data protection complaints about how the council has processed your personal data, will be handled in accordance with the council’s Complaints Policy. You can find out how to submit a complaint by visiting this link.

If we cannot resolve your complaint, you can refer to the Information Commissioner if you consider that there has been an infringement of data protection legislation. Further details can be found on the Information Commissioner’s website.

Changes to this notice

We keep our privacy notice under regular review. We will notify you of significant changes to this notice by email or other means as appropriate. This privacy notice was last updated March 2025.