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Privacy

Privacy Policy

 

1. About the Energy Saving Trust

We are a leading and trusted organisation helping people save energy every day. Our experts speak with millions of householders every year, deliver first class programmes for governments and provide consultancy to UK businesses and international companies. All our work is underpinned by our pioneering world-renowned research.

We are independent and impartial so the advice we give is all about helping you.

Energy Saving Trust manages Home Energy Scotland on behalf of the Scottish Government as well as the Nest scheme, which is managed on behalf of the Welsh Government by British Gas. Energy Saving Trust is a material subcontractor of British Gas.

Energy Saving Trust will treat any personal data you provide us carefully and securely.

Energy Saving Trust does not make cold calls (we do not sell insulation or solar panels etc). If you are receiving cold calls from an organisation, the Information Commissioner’s Office has some useful advice and, if you haven’t already, it may be worth considering registering with the Telephone Preference Service.

To contact our data protection officer please:

Write to: Energy Saving Trust England, 30 North Colonnade, Canary Wharf, London, E14 5GP. 

Email: DataProtectionOfficer@est.org.uk

2. When we collect data from you

When Energy Saving Trust or the advice services collect information about you we will tell you at least:

·         Who we are

·         Why we are collecting your information

·         Our legal basis for processing it e.g. the processing is required as part of a contract, for example if you apply for a loan from us

·         What we will do with it

·         If we will share it (and who we share it with)

Some of this may be provided to you through this privacy policy which will be updated from time to time. We will always provide detail of how to access our privacy policy.

3. What information will we collect about you?

We might collect:

·         Contact information (e.g. name, postal address, email address)

·         Information about you (e.g. date of birth, receipt of benefits)

·         Information about your property (e.g. property age, the level of insulation, type of heating)

·                               Bank account details and other financial information

Some of this information may, in some cases, be considered as not being personal data e.g. information purely about your property: property type or energy saving measures. 

4. Why do we ask for this information?

We will ask for your contact details so that we can:

·         respond to requests, enquiries and complaints received from you

·         to contact you about services requested by you

·         evaluate customer satisfaction and the success of any programmes we deliver and their impact on the environment

·         to keep our records up-to-date

·         for audit purposes

We will ask for information about you and your property so that we can:

·         provide services requested by you

·         assess eligibility for grant and loan funding you have applied for

·         assess likely eligibility for other assistance you may be able to receive

·         analyse householder trends

·         monitor the energy efficiency of UK housing stock, and to assist in targeting services and new schemes

We will ask for financial information so that we can:

·         process payments to you and repayments (e.g. of loans) to us

·         assess your eligibility for funding/assistance (for example by carrying out a credit reference check – see more information on credit checks here)

 
5. Where we collect information about you

We will normally only collect information directly from you. If we have received your information from a 3rd party, we will explain to you where we obtained your personal information from. The organisation sharing your information with us will get your permission to do so before sharing. This is likely to be from organisations such as Trading Standards or Citizen’s Advice, in order to help you save energy, or access funding you may be entitled to.

If you telephone us (Energy Saving Trust or the advice services) your call may be recorded for training and monitoring.

We will ask you to provide information for instance, when you contact us by telephone, if you make use of one of our tools (eg our Home Energy Check), if you submit a ‘contact us form’, enter a competition, attend an event, or complete a survey. If you ‘like’ or ‘follow’ any of our social media accounts (such as Facebook and Twitter) we will collect information about this (including any posts you ‘like’ or share). We will use this information to provide you with more personalised advertising and to understand how people are using the information we publish on social media. You can change your settings within your social media accounts to set how organisations can target advertising to you through them.

6. Sharing information about you

We sometimes use other companies and organisations (third parties) to process personal information for us. For example we use third parties to:

·         deliver our advice service

·         carry out credit reference checks

·         maintain our IT systems

·         carry out site inspections to assess compliance with a particular scheme

complete scheme evaluation

carry out research

using printing services.

Some of your information may be shared:

with your local authority, so that they can target specific areas for energy efficiency measures and schemes

with devolved and national government so that they can monitor household trends, the success of schemes to encourage the uptake of renewables and monitoring the output of devices, to facilitate MPs/MSPs etc where they have been asked to help by one of their constituents.

Where we make use of third parties to process personal information, we will ensure that they have adequate security measures in place and that they comply with this privacy policy.

We share information, for analysis and reporting purposes, with government departments and bodies (including the devolved nations) that provide funding to the Energy Saving Trust or have an interest in our activities.

We will also share information about you when we are required to so by law or if we have your permission to do so.

7. Direct Marketing

Energy Saving Trust will only send you direct marketing information if you have  agreed to receive this information when you provided your contact details, or when you have specifically asked us to send you direct marketing.

We may occasionally present a promotion that is sponsored by a third-party company or organisation. To qualify for entry, we may ask you to provide personal information – if we intend to share that information with the sponsors, we will make this clear and provide you with the opportunity to prevent this

You have the right to stop us using information about you for direct marketing purposes. You can do this at any time even if you previously consented to receive direct marketing. If you wish to change your marketing settings either select the link included in emails or contact us directly to let us know. We will change your setting as soon as we are able and at least within 28 days.

8. Google Analytics Advertising

Energy Saving Trust has implemented the following Google Analytics Advertising features:

Remarketing – this enables Energy Saving Trust to display advertising to visitors on our website as they move to other sites.

Display Network Impression Reporting – Energy Saving Trust can use this to understand the impact of adverts displayed on other sites. We will be able to see when someone views an advert elsewhere and then later visits Energy Saving Trust’s website.

Demographics and Interest Reporting – this allows us to obtain anonymous information about the users of our website. For example, we will be able to see how many visitors we had to our site in a particular age range. Find out more about how Google obtains this information.

9. Targeting

If you have agreed that we can send you direct marketing using email, we may make use of social media to target advertising to you. This will take the form of adverts about Energy Saving Trust services that appear in your newsfeed etc. This is done by ‘hashing’ your email address. A process which converts your email address to a line of numbers which is then matched against the social media provider’s records. Any hashed addresses which do not match to their records will be destroyed. No personal data is shared. You can adjust your setting within your social media:

Facebook ad settings information >

Twitter: how Twitter ads work >

10. How long will we keep your data for?

EST will keep your information for:

Financial records –  Where you have applied for a loan through Energy Saving Trust we will keep those records for the length of the loan and an additional 7 years.

Contact information – 7 years from the last active contact with Energy Saving Trust. Unless we have a reason to keep for longer (for example where you have received a loan from us or where the funder has included longer data retention as part of their terms and conditions).

Property information – we will keep information about your property indefinitely so that we can provide funders (eg the Scottish Government) with historic information about the UK’s housing stock. This will be anonymised.

(this list will be added to regularly)

11 Your rights

The General Data Protection Regulation will change the rights you have with regards to the personal data we hold and use about you. Your new rights are described in the guidance below. If you have any questions or concerns about how we use your personal information please contact our Data Protection Officer*. You can also find useful information on the Information Commissioner’s Office’s website.

*Data Protection Officer details for Energy Saving Trust:

Write to: Energy Saving Trust England, 30 North Colonnade, Canary Wharf, London, E14 5GP. 

Email: DataProtectionOfficer@est.org.uk

If you feel that we have not responded appropriately to any requests to use your rights you have the right to complain to the Information Commissioner’s Office (as detailed above).

For any request relating to your information we will ask for proof of identity to make sure we are talking to the right person, and to avoid disclosing information that belongs to another person. This may be done through asking questions (such as your address, telephone number, email address and reference number, should you have one) or sometimes we might ask for other evidence.

If you are asking about information relating to another person, a relative for example, we need to be sure you have the authority to act on that person’s behalf. Normally this can be done through evidence of a ‘Power of Attorney’ or similar document.

Accessing information we hold about you

If you think we hold information about you, you can ask us about that information. You do not have to make this request in writing, however we will always ask questions to make sure we know who you are or we might ask for further proof of identity. This additional proof may take the form of recent utility bills or we may request to see photographic identification such as a current driving licence.

We will let you know if we are using your information and let you have access to it. We may ask you to let us know exactly what information you are looking for if we hold a large amount of information about you.

We will give you the following information:

What we are using your information for (including the details of any credit check carried out if you applied for loan funding through us), What sort of information about you that we hold, Who we have shared your information with, If we didn’t get your information from you, we will tell you where we got it from, How long we are likely to keep your information.

 

 

Right to object to direct marketing

See section regarding direct marketing.

Research

You may have agreed to be part of some research that we are carrying out – for example, into changing behaviour. If you change your mind about being part of any research, please let us know and we will stop using your personal information and remove your details from the research.

 

Automated Decisions

You have rights relating to any automated decisions that we may take about you.

We use a credit checking service when you apply to receive loan funding us. The service provider does not give a ‘pass’ or ‘fail’ answer when we use their services. Instead we are given a ‘score’ based on your information held by them. We have used our knowledge to decide what ‘score’ is needed for people to be eligible for the loan.

If you do not meet the requirements, we will give you an opportunity to appeal this decision, by giving us some additional information. It may be that the information held by the credit checking service is incorrect – you can contact them to find out what they hold and make any corrections if needed

We will always carry out a credit check if you apply for a loan and this forms part of the conditions of the funding.

Profiling

We may use your information to map the way people use energy in their homes, to get an understanding of how energy efficiency measures can change the amount of energy used in homes or to get a better picture of the housing stock of the UK.

When we use your information in this way, we will always make sure your information is kept secure. We will use modelling techniques and data minimisation to make sure that you are not able to be identified from any reports produced.

Additionally, only certain types of organisations will be able to access this information. When we do so we will make sure there is a contract in place restricting the use of the information.  We will only release information at level that will ensure no individual can be identified. Organisations will only be able to use the information for specific reasons related to improving the efficiency of buildings and reducing the impact of climate change. 

  • if we still have a valid reason for using your personal information, or
  • in connection to any legal action.

If we have agreed to restrict the use of your personal information, we will only use it with your agreement, to defend any legal action, to protect the rights of another person or in the public interest.

We will let you know if we intend to remove any restriction on using your personal information, for example when we have found your personal information to be correct.

If we have shared your information with other organisations, we will let them know about any corrections, deletion or restriction of use of your personal data.

 

Data Portability

You have the right to obtain the data you have given us through the Home Energy Check. This is because you provided the information through our online tool which automatically provides you with information about your property and ways you can improve the energy efficiency of your home.

If you would like us to do this for you, we will do this free of charge and in a way that should be able to be understood by the other organisation’s computer systems. They will be able to use this information to provide you with their services. In some cases we may be able to transfer this information directly to the other organisation – but this will depend on their systems being able to work with ours and allowing the transfer of information.

We will in most cases be able to provide you with your information within a month, but we may need longer than this if your request is complicated or if you have asked for many (up to two months).  We will let you know if we need longer to give you your information and we will explain why we can’t give you the information more quickly.

Please contact us if you wish to take advantage of this service and we will be happy to help you.

 

Right to Object

You can object to our use of your personal information. This is because we will have either obtained you permission to use your personal information, or we will have provided you with a condition known as a ‘legitimate interest’. A ‘legitimate interest would be where, for example, you had asked us to send you a loan application form. In order to complete this request we need to know and be able to use some of your personal information.  

We will always let you know you have this right when we first take your information. 

In some cases we will be unable to carry out your instruction to stop using your information. This will be:

when we are carrying out a legally required task (for example information relating to the Energy Performance Certificate Register),

We will provide you with information about the action we have taken in one month of receiving your request to delete your information and having received any proof of identity asked for. In some cases we may require additional time to provide you with a response. We will only do this if the request is complicated or there are more than one request submitted. We will always keep in touch and let you know the status of your request.

 

Restricting the use of your personal information

You have the right to restrict our use of your personal information where:

The accuracy of your personal information is in dispute and until we have been able to check your personal data to ensure that it is right The use of your personal data is unlawful and you want to prevent us from deleting it We no longer need your personal data for the reason it was collected but you want the information kept to take or defend legal action You have objected to our use of your personal information for direct marketing (in this case we would no longer send you direct marketing but would keep your information on a ‘list’ of people not to be contacted by us)

In some cases we may have received permission to use your image in our marketing material, on our website and/or through our social media sites when you were a child (either from you or your parents/guardian). Please let us know if you would like to withdraw this permission and we will remove your images as requested. We will additionally contact the providers of our advice service to make sure your image is no longer used by them. 

 

Refusing your request

We may refuse a request to delete your information if the use of your information is:

for exercising the right of freedom of expression and information (e.g.  for the purposes of journalism), to comply with legislation, or carrying out a task in the public interest, or in an official capacity (e.g. the retention of Environmental Performance Certificates as the ‘Keeper of the Register), used for statistical purposes (normally concerned with the state of the housing stock) used in relation to a legal claim.

We will provide you a copy of your personal information in one month of receiving your request for your personal information and having received any proof of identity asked for. In some cases we may require additional time to provide you with all your information. We will only do this if the request is complicated or there are more than one request submitted. We will always keep in touch to let you know when you will receive the copy of your information, if there will be a delay in providing your information and the reason for any delay.

If you request your information via email (or by any other electronic way) we will normally provide the copy of your personal information electronically where we can. However, we will discuss with you how you would prefer to receive the copy of your information and explain any reasons if we cannot provide your information in the way you would prefer.

Charges and refusing requests for personal information

We will normally not request payment to give you a copy of your personal information. However, we may make a charge if you have already recently requested the same information. In some very rare cases where numerous requests for the same information have been made we may refuse to provide the information again. Where we can, we will always clearly explain any decision to refuse to provide you with your personal information.

If the information you have requested includes the personal information of another individual we will (depending upon the circumstances) remove information that identifies that person.

 

Correcting information

If we hold information about you that is wrong you have the right to have this corrected. If we agree that the information is incorrect we will always correct this information quickly or complete information where appropriate. If we do not agree that the information is wrong we will record that you have raised a request to have the information altered and that it is in dispute.

Removing information

You can request that we delete, remove or that we erase the information we hold about you. We will do this if any of the following is true and if no legal reason to keep your personal information exists:

Your personal information is no longer needed for the reason they were collected You withdraw consent where the use of your information was based on consent and we have no other legal basis to continue using your information We have been using your personal information unlawfully We are required to remove your personal information because of a law applying to us

When we respond to your request for your information we will give you details about the other rights you have. Including:

The right to submit a complaint to the Information Commissioner’s Office The right to request correction or deletion of personal information The right to request the restriction of your personal information Or to object to the processing of your personal information.

12. Cookies

Please visit here for information about cookies.

13. Scottish Parliament Cross Party Group on Renewable Energy and Energy Efficiency (SPREEE) 

As part of our role to provide secretariat services for the Cross Party Group on Renewable Energy and Energy Efficiency (SPREEE), Energy Saving Trust will collect the personal data of SPREEE members. 

What information will we collect from you?

- Name
- Organisation
- E-mail address

Why do we ask for this information?

We collect and maintain this information to notify you about forthcoming SPREEE meetings and to share any other SPREEE related information.

Sharing information about you

- We share the role of secretary with Scottish Renewables and as such we jointly have access to and maintain the data we collect from you
- For security purposes we share the names of members who have registered to attend each meeting with relevant parliamentary staff
- Members who attend SPREEE meetings are listed (by name only) on the minutes of each meeting  
- The minutes are then published on the Scottish Parliament’s website 

Retention and Disposal

The personal information we collect (listed in "Why do we ask for this information?") from members of SPREEE will be retained for as long as membership of the group is held. When notification is received from an individual that they wish to leave the group this information is deleted.

Security

- An information technology policy has been implemented with which all of our employees must comply
- All data will be protected in accordance with applicable legislation
- Access to the buildings and servers in which the data is stored is controlled via electronic pass
- Laptops and other devices access central systems through a suitable secure gateway. Laptops employ encrypted hard-drives
- Data exchanged between devices is encrypted
- Access to files and folders is controlled via user authentication and permissions, according to the employee's role. Email is restricted by user's account
- Backup data is encrypted
- Clear policies and procedures are in place for reporting managing and resolving security breaches associated with the data
- Data exchanged is retained or disposed of in line with agreed retention policy

14. Changes to our privacy policy

We regularly review our privacy policy to keep it up-to-date. Any changes that we make will be posted on our website. This privacy policy was last updated 28/09/2018.