Warm Homes: Local Grant Eligibility Assessment Privacy Notice
This privacy notice explains how Cheshire West and Chester Council uses your personal information when assessing your eligibility for support through the Warm Homes: Local Grant scheme.
The Warm Homes: Local Grant is funded by the Department for Energy Security and Net Zero and provides energy-efficiency improvements and low-carbon heating measures for eligible households. Cheshire East Council is the lead authority for the grant across Cheshire East, Cheshire West and Chester, and Warrington.
Cheshire West and Chester Council is responsible for assessing applications from residents living within the Cheshire West and Chester area. This includes contacting potential applicants, collecting and verifying supporting evidence, deciding whether the scheme’s eligibility criteria have been met, recording the outcome and passing successful applications to Cheshire East Council so that the next stage of the scheme can be arranged.
As part of the eligibility assessment, we may ask you to provide evidence of your identity, address, income, benefits and household circumstances. We may also collect information about any disability, health condition or additional need where this is relevant to the assessment, the delivery of the scheme or a reasonable adjustment you require.
What information we collect, use, and why
Whenever you contact us about the Warm Homes: Local Grant scheme, whether through a referral from the national application process, by email, by telephone or through direct contact with the Council, we need to collect certain information to assess your eligibility and deliver the service.
This information helps us identify you, verify your eligibility, prevent fraud and error, arrange any support you may need during the assessment process, and ensure public funding is awarded correctly.
We categorise the information we collect into two main types: personal data and special category data.
Personal data
We may collect and use the following personal data:
- Name, address, telephone number and email address
To identify you, communicate with you throughout the application process and record the outcome of your eligibility assessment. - Date of birth
To verify your identity and confirm eligibility where age-related criteria apply. - National Insurance number
To verify eligibility and support fraud prevention checks where required. - Proof of identity
Such as a passport, driving licence or other approved identification document, to confirm that the applicant is the person applying for support and to reduce the risk of fraud and error. - Proof of address
Such as a Council Tax bill, utility bill or other evidence of residence, to confirm that the property falls within the eligible area and meets scheme requirements. - Household income and employment information
To assess whether the household meets the financial eligibility criteria of the scheme. - Benefits information
To determine eligibility under benefit-based qualifying routes and ensure public funding is awarded correctly. - Property information
Including property address, tenure status, EPC information, heating arrangements and other details required to assess whether the property meets the scheme criteria. - Landlord information
Where the property is privately rented, we may collect information relating to the landlord, ownership arrangements and subsidy control declarations. - Correspondence and application records
Including information provided by you during enquiries, applications and assessments, together with records of decisions and actions taken by the Council. - Eligibility assessment records
Including evidence reviewed, eligibility routes applied, assessment outcomes and audit information required to demonstrate compliance with scheme requirements.
Special Category data
In some circumstances, we may collect and use limited special category data where this is relevant to the application, delivery of the scheme or support we provide.
This may include:
- Physical or mental health information
Where you tell us about a disability, health condition or medical need which may affect your ability to engage with the application process or require us to make reasonable adjustments. - Accessibility and support requirements
Such as language requirements, communication needs, caring responsibilities or information provided through the Get to Know You (GTKY) questionnaire. - Religious or cultural information
Where voluntarily provided by you and necessary to ensure that support is delivered appropriately and respectfully.
We only collect special category information where it is relevant and necessary for the assessment process, delivery of the scheme, fraud prevention requirements, or to ensure that appropriate support and reasonable adjustments can be provided.
Criminal Offence data
The Warm Homes: Local Grant eligibility assessment process does not routinely collect or process criminal offence data.
However, information relating to fraud investigations, fraud prevention activities, or non-compliance with scheme requirements may be processed where this becomes necessary as part of audit, assurance, fraud, error or compliance activity associated with the scheme.
Sources of information
We primarily collect information directly from you when you make an enquiry about the Warm Homes: Local Grant scheme, provide supporting evidence, complete application forms, respond to requests for information, or communicate with us during the eligibility assessment process.
To assess eligibility and administer the scheme, we may also receive information from the following sources:
- Department for Energy Security and Net Zero (DESNZ)
Information submitted through the national Warm Homes application process, including referral details, contact information, household information, property information and self-declared eligibility details. - Cheshire East Council
As the lead authority and Grant Recipient for the scheme, Cheshire East Council may provide information necessary for the administration of the Warm Homes programme and to support eligibility assessment activities. - You and members of your household
Information and supporting evidence provided directly by applicants, household members, landlords or authorised representatives acting on your behalf. - Landlords and property owners
Where a property is privately rented, we may receive information relating to property ownership, tenancy arrangements and landlord eligibility requirements. - Government departments and public bodies
Where necessary to verify eligibility, prevent fraud, investigate errors, meet audit requirements or comply with scheme conditions. - Other Cheshire West and Chester Council services
Where relevant and lawful to do so, we may access information already provided to other Council services to help verify information, avoid duplication and improve service delivery. - Other local authorities
Where applications have been submitted to the wrong authority, where cross-boundary enquiries are received, or where information needs to be transferred to ensure the application is handled by the correct organisation. - Publicly available information sources
Including property and energy-efficiency related information from sources such as the Energy Performance Certificate (EPC) Register, Land Registry and Companies House, where this information is necessary to assess eligibility or comply with scheme requirements. - Professional advisers, contractors and delivery partners
Where they are acting on behalf of Cheshire East Council, DESNZ or the scheme and have lawfully obtained information relevant to the delivery, administration, audit or assurance requirements of the programme.
We only obtain information from these sources where it is relevant, necessary and proportionate for assessing eligibility, administering the scheme, preventing fraud and error, complying with audit requirements, or ensuring public funds are used appropriately.
What is your personal information used for?
We use your personal information to administer the Warm Homes: Local Grant eligibility assessment process and to ensure that public funding is awarded fairly, consistently and in accordance with the scheme requirements.
Your information may be used to:
- assess whether you and your property meet the eligibility criteria for the Warm Homes: Local Grant scheme
- verify your identity, address, income, benefits status and other eligibility requirements
- contact you regarding your enquiry, application, supporting evidence, eligibility assessment or the outcome of your application
- record, manage and review eligibility decisions and maintain an audit trail of assessments undertaken
- arrange and provide reasonable adjustments, additional support or assistance where required to enable you to access the service
- transfer successful applications to Cheshire East Council so that the next stage of the scheme can be delivered
- coordinate with delivery partners, contractors and other organisations involved in delivering approved home energy efficiency improvements
- prevent, detect, investigate and respond to fraud, error, misuse of public funds and non-compliance with scheme requirements
- undertake quality assurance, compliance checks, audits and reviews of eligibility decisions
- respond to complaints, appeals, enquiries, requests for information and the exercise of data protection rights
- comply with legal, regulatory, funding, governance and reporting requirements associated with the scheme
- share information with the Department for Energy Security and Net Zero (DESNZ) and other authorised organisations where this is necessary for scheme administration, audit, evaluation, assurance, fraud prevention or compliance purposes
- monitor the performance and effectiveness of the scheme and help inform future energy efficiency, fuel poverty and climate change programmes
- produce management information, statistical information and report -wherever possible, this information will be anonymised or aggregated so that individuals cannot be identified
- maintain records in accordance with the scheme’s audit, assurance, fraud prevention and retention requirements
We will only use your personal information where it is necessary, proportionate and relevant to delivering the Warm Homes: Local Grant scheme and associated statutory, funding, audit and assurance obligations.
Who do we share your information with?
We only share your personal information where it is necessary to deliver the Warm Homes: Local Grant scheme, meet funding and audit requirements, prevent fraud and error, comply with the law, or protect public funds.
Your information may be shared with the following organisations:
- Cheshire East Council
As the lead authority and Grant Recipient for the Warm Homes: Local Grant scheme. We share information necessary to administer successful applications, arrange delivery of approved works, undertake quality assurance activities and meet scheme reporting requirements. - Department for Energy Security and Net Zero (DESNZ)
To administer, monitor, evaluate and audit the scheme, prevent and detect fraud, error and non-compliance, and ensure public funds are used appropriately. - DESNZ appointed contractors, auditors and assurance providers
Where they are acting on behalf of DESNZ to undertake monitoring, evaluation, fraud prevention, compliance reviews, audit activity or scheme assurance. - Delivery partners, retrofit contractors and installers
Where an application is successful and information is required to arrange surveys, property assessments, installation work, customer engagement or other activities associated with delivering approved improvements. These organisations will only receive the information necessary to carry out their role. - Domestic energy assessment providers and surveyors
To undertake property assessments, retrofit assessments, energy performance reviews and technical surveys required as part of the scheme. - Other local authorities participating in the scheme
Including Cheshire East Council and Warrington Borough Council where information sharing is necessary to administer the scheme, manage enquiries, support audit activity or ensure applications are handled by the correct authority. - Government departments, public authorities and regulatory bodies
Where information is required to verify eligibility, prevent fraud, investigate potential misuse of public funds, comply with legal obligations or support audit and assurance requirements. - TrustMark, Microgeneration Certification Scheme (MCS), Ofgem and other accreditation bodies
Where information needs to be shared to demonstrate compliance with industry standards, certification requirements or scheme rules. - Professional advisers and specialist contractors
Such as structural engineers, surveyors, technical advisers or other appointed professionals where their involvement is required to support delivery of the scheme. - Other organisations administering government-funded energy efficiency schemes
Where sharing is necessary to prevent duplicate funding, investigate fraud or error, or comply with scheme governance requirements. - Cheshire West and Chester Council services
Where information needs to be shared internally to support delivery of the scheme, respond to a query, investigate a complaint, comply with legal obligations or protect public funds.
We do not routinely share original identity documents, bank statements or other supporting eligibility evidence with delivery contractors or installers.
Original eligibility evidence will only be shared where this is necessary for authorised audit, fraud, error, compliance or assurance activity and will be transferred using approved secure methods.
We may also share information where we are required to do so by law, including where disclosure is necessary for the prevention or detection of crime, safeguarding purposes, court proceedings, statutory investigations or to comply with a legal obligation.
Data Processors
We use a number of trusted suppliers and technology providers to help us deliver the Warm Homes: Local Grant eligibility assessment process. These organisations act on behalf of Cheshire West and Chester Council and only process personal information under our instructions and in accordance with contractual data protection requirements.
Data processors used to support the service may include:
- Microsoft 365 and Council IT infrastructure providers
To securely store emails, documents, spreadsheets, correspondence and other records associated with the administration of the scheme. - Secure email and file-sharing services
To enable the secure transfer of information between Cheshire West and Chester Council, Cheshire East Council, DESNZ and authorised auditors where required. - Document storage and records management systems
To securely manage eligibility evidence, assessment records, audit records and supporting information. - Case management and administrative systems
To record enquiries, eligibility assessments, application outcomes, audit activity and communications relating to the scheme. - DESNZ-approved digital services and portals
Where information is exchanged as part of the administration, monitoring, audit or assurance arrangements associated with the scheme. - Information technology support providers
To maintain the security, availability and resilience of the Council's networks, systems and applications used in delivering the service. - Backup, disaster recovery and cyber-security service providers
To ensure information is protected, recoverable and secure against unauthorised access, loss, corruption or cyber threats.
All organisations acting as data processors are required to:
- process information only on our instructions
- maintain appropriate technical and organisational security measures
- protect the confidentiality of the information they process
- comply with UK data protection legislation
- only use the information for the specific purposes for which they have been engaged
We do not permit our data processors to use your personal information for their own purposes. They may only process it to support the delivery, administration, security and operation of the Warm Homes: Local Grant service.
Data Controller
The Warm Homes: Local Grant scheme involves a number of organisations that are responsible for different parts of the application, assessment, delivery, audit and assurance process.
For the purposes of the eligibility assessment carried out for residents of Cheshire West and Chester, we are the Data Controller. This means we are responsible for deciding how and why your personal information is processed as part of:
- assessing eligibility for the scheme
- collecting and reviewing supporting evidence
- recording eligibility decisions
- responding to requests relating to your personal information
- retaining records held by Cheshire West and Chester Council
- ensuring that personal information is processed in accordance with data protection legislation
The Department for Energy Security and Net Zero (DESNZ) is a separate Data Controller for information processed through the national Warm Homes scheme, including information collected through the national application process, scheme monitoring, audit, evaluation, fraud prevention and compliance activities.
Cheshire East Council, as the lead authority and Grant Recipient for the scheme, is also a separate Data Controller for the information it processes when managing the delivery of approved works, coordinating retrofit activity, engaging with installers and fulfilling its responsibilities under the grant arrangements.
Each organisation is responsible for the personal information it processes and for complying with its own obligations under data protection legislation.
The lawful basis for processing
Most of the personal information we process for the Warm Homes: Local Grant eligibility assessment is provided directly by you, or is received through the national Warm Homes referral process.
Under Article 6 of the UK General Data Protection Regulation (UK GDPR), Cheshire West and Chester Council processes personal information under the following lawful basis:
UK GDPR 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 Council.
We use your personal information to:
- assess whether you are eligible for support under the Warm Homes: Local Grant scheme
- verify the information and evidence provided in support of your application
- prevent and detect fraud, error and misuse of public funds
- administer government-funded energy efficiency and fuel poverty reduction programmes
- record and audit eligibility decisions
- support the delivery of approved grant-funded improvements
- comply with scheme governance, assurance, audit and reporting requirements
The Council's public task is supported by its statutory functions relating to improving housing conditions, reducing fuel poverty, supporting residents and delivering publicly funded environmental and energy efficiency programmes.
Special Category data
In limited circumstances, we may process special category data, such as information relating to a disability, health condition or additional support requirement.
Where special category data is processed, Cheshire West and Chester Council relies upon:
UK GDPR Article 9(2)(g) – Substantial Public Interest
Data Protection Act 2018, Schedule 1, Part 2, Paragraph 16 – Support for Individuals with a Particular Disability or Medical Condition
This allows the Council to process relevant health and disability information where it is necessary to:
- identify and provide reasonable adjustments
- support individuals with disabilities or health conditions
- remove barriers to accessing the scheme
- ensure residents can participate fairly in the eligibility assessment process
- support the safe and effective delivery of approved works
We only collect and process this information where it is necessary and relevant to your circumstances.
Legislation supporting the processing
The Council's processing is supported by legislation and government powers relating to fuel poverty, energy efficiency and the delivery of publicly funded assistance programmes, including:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Home Energy Conservation Act 1995
- Local Government Act 2003
- Climate Change Act 2008
- Fuel Poverty (England) Regulations 2014
- Warm Homes: Local Grant Memorandum of Understanding
- Warm Homes: Local Grant Data Sharing Agreement
These legal and governance arrangements enable the Council, Cheshire East Council and the Department for Energy Security and Net Zero (DESNZ) to administer the scheme, assess eligibility, deliver support, prevent fraud and ensure public funds are used appropriately.
International data transfers
The Warm Homes: Local Grant eligibility assessment service is primarily delivered within the United Kingdom and Cheshire West and Chester Council does not routinely transfer personal information outside of the UK as part of its eligibility assessment activities.
Personal information processed by Cheshire West and Chester Council is stored and managed using Council-approved systems and services that are subject to appropriate security, access control and data protection requirements.
Some information associated with the wider Warm Homes: Local Grant scheme may be processed by the Department for Energy Security and Net Zero (DESNZ) and its appointed contractors as part of the national administration, monitoring, assurance, evaluation, audit and fraud prevention arrangements associated with the scheme. DESNZ acts as a separate Data Controller for this processing and is responsible for ensuring any international transfers carried out under its arrangements comply with UK data protection legislation and that appropriate safeguards are in place.
Where personal information is transferred outside the United Kingdom, appropriate protections will be applied. These may include:
- Adequacy Regulations
Transfers to countries recognised by the UK Government as providing an adequate level of data protection. - Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs)
Legally binding safeguards designed to protect personal information when transferred internationally. - Technical and Organisational Security Measures
Including encryption, access controls, secure storage arrangements and contractual restrictions on the use of personal information.
We will keep any international transfer arrangements under review and ensure that appropriate safeguards remain in place to protect your personal information and your rights.
Retention period
We will only keep your personal information for as long as it is necessary to assess your eligibility, administer the Warm Homes: Local Grant scheme, support its delivery, respond to queries or complaints, and meet audit, fraud, error and compliance requirements.
Different retention periods apply depending on the outcome of your application and the type of information held.
Successful applications
If your application is successful, the following information will be retained for eight years after the scheme closes, currently until 31 March 2036:
- your contact and application details
- eligibility assessment and decision records
- copies of identity documents used to confirm your identity
- bank statements, benefits evidence and other financial information used to assess eligibility
- records showing what evidence was checked and how the eligibility decision was reached
- grant administration and audit records.
Original eligibility evidence is retained because it may be required by Cheshire East Council, the Department for Energy Security and Net Zero, or authorised auditors to undertake audit, fraud, error and non-compliance checks. These checks may require an independent review of the original evidence used to determine eligibility rather than relying only on an officer’s record that the evidence was checked.
Unsuccessful or withdrawn applications
If your application is unsuccessful or you withdraw before receiving support:
- identity documents, bank statements, benefits evidence and other supporting documents will normally be deleted within 30 calendar days of the decision or withdrawal
- we may retain a limited record of the application and its outcome where this is necessary to respond to a complaint, review a challenge, demonstrate how the application was handled, or prevent duplicate applications.
We will not retain full supporting evidence for an unsuccessful or withdrawn application unless there is a specific reason to do so, such as an ongoing complaint, investigation, fraud concern or legal requirement.
Health, disability and reasonable-adjustment information
Information about a disability, health condition, communication need or reasonable adjustment will only be retained for as long as it is needed to support your application or the delivery of approved work.
Where this information needs to be passed to Cheshire East Council or an authorised delivery partner to support you during the next stage of the scheme, only the information necessary for that purpose will be shared.
Unnecessary or excessive information
If you provide information that is not required for the eligibility assessment, scheme delivery, reasonable adjustments, audit or fraud prevention, we will delete it as soon as it is identified and normally within two working days.
Information held by other organisations
Cheshire East Council and the Department for Energy Security and Net Zero are separate Data Controllers for the information they process. They may apply different retention periods to information held for scheme administration, audit, evaluation, fraud prevention and compliance purposes.
Certain information held by the Department for Energy Security and Net Zero may be retained for longer where this is necessary to prevent duplicate funding, investigate fraud or maintain records about energy-efficiency measures installed at a property.
At the end of the relevant retention period, personal information held by Cheshire West and Chester Council will be securely deleted in accordance with the Council’s records management and information disposal procedures.
Your rights
The UK GDPR provides you with a several rights to control what personal information is used by us and how it is used by us. Further guidance about these rights can be accessed from the Information Commissioner’s Office (ICO) website.
If you are not happy about the way your personal data is being used, or you require further information about how we process your personal data, you can contact our Data Protection Team
- Contact the DPO
- By post: Data Protection Officer, The Portal, Wellington Road, Ellesmere Port, CH65 0BA
You also have the right to complain to the Information Commissioner’s Office using the following details:
- Information Commissioner's Office (ICO)
- By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Phone: 0303 123 1113