Privacy Policy

INTRODUCTION

The Energy Company Obligation (ECO) scheme requires large energy suppliers to provide funding towards energy efficiency measure installations in domestic homes. In order for you to have a measure installed into your home under the ECO scheme we will need to collect some of your personal information and share this with other organisations. We will only collect and use personal data in ways that are described here, in a way that is consistent with our obligations and your rights under the law.

THIS PRIVACY POLICY

Thank you for visiting www.e4less.co.uk ("we," "us," "our," or "www.e4less.co.uk"). Your privacy is important to us, and we are committed to protecting your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you use our website.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law, including GDPR, protects you.

The purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of the E4LESS website, including any data you may provide through this website when you apply for any energy saving measures under the ECO4 grants scheme via this website.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Specifically, within E4LESS you will be asked to provide your personal data in respect of an application you may complete to apply for a grant under the ECO4 grants scheme.

Data controller

BRIGHT SPARK ENERGY SOLUTIONS LIMITED is a company registered in England and Wales under registration number 15029600. Our registered office is at 71-75 Shelton Street, London WC2H 9JQ.

For the purposes of data protection laws, we are the controller and responsible for your personal data. We are registered with the Information Commissioner’s Office (ICO) and our ICO registration number is ZB579294 .

PERSONAL DATA WE COLLECT

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the ICO’s website .

We may collect, use, store and transfer different kinds of personal data about you and this may include:

Identity Data:- Your name, address, and in some cases your date of birth and proof of identity (so we can check you are eligible for the scheme).
Contact Data:- Your phone number and email address (so you can be contacted as necessary for the Purpose outlined in this notice)
Property, Financial & Benefits Data:- Your residential address, what you are looking for, whether you are a homeowner, landlord or tenant, details about your property, number of bedrooms, what type of heating you use, the type of boiler or boiling system you have, what benefits you receive or are entitled to, proof of benefits and other information evidencing your eligibility e.g. copies of documents showing proof of benefits and income supplied to you by the Department for Work and Pensions and HMRC (this will be limited to information showing you are eligible for the scheme);

We will tell you if providing some of your personal data is optional. In all other cases you must provide your personal data or we will be unable to install a measure into your home under the ECO scheme.

HOW WE USE YOUR PERSONAL DATA

We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract:- As necessary to fulfil our contract with you, eg. to manage and undertake the contract (including the installation of a measure into your property).

Legitimate Interest:- As necessary to pursue our legitimate interests, eg. to check you are eligible for the ECO scheme; to share your data with third parties who administer, support or enforce the ECO scheme (as specified under ‘Sharing your personal data’).

Comply with a legal or regulatory obligation:- As necessary to comply with a legal obligation, eg. where you exercise your rights to make requests under data protection law.

In some circumstance we may need to process special categories of data (eg. Information related to your health as evidence you are eligible for the scheme). In these cases, will provide you with separate information showing you how we will process your data and the legal basis under which we are processing it.

Except for when we seek to share your information with an approved installer (further information on this is provided below),

we do not rely on consent as a legal basis for processing your personal data. However, we rely on your consent for the following:

sharing your information with an accredited installation company within the E4LESS network
sending direct marketing communications to you via email or text message;
non-essential cookies and in particular for marketing cookies to display personalized advertisements – for information about the cookies we use, please see our Cookie Policy.

SHARING YOUR PERSONAL DATA

We will share your personal data with:

An installer within our accredited installer network (however we shall not do so without your prior consent).
Third parties who act on our behalf on a contractual basis and provide you or us with relevant services such as the conducting of surveys on our behalf.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
if necessary the Department for Work and Pensions will profile your data in order to provide a YES/NO response via the Energy Saving Trust1 to verify whether or not you receive the relevant benefits to be eligible for the scheme;
The Office of Gas and Electricity Markets (Ofgem)2 to use and share your information in order to fulfil it’s statutory duties
Anyone else where it is required by law, or we have your consent.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share your personal data including call recordings with regulators (including the Information Commissioner’s Office) or as required by law or regulation or the order or any court or tribunal.
The information you provide may be transferred to 3rd parties outside of the European Union. However, this will only take place where this is necessary for the Purpose outlined above. We will ensure all appropriate safeguards, including those set out by the ICO5, are in place to protect your data before any transfer takes place.
Your data will only be processed for purposes relating to ECO, unless you have specifically consented otherwise.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to interact with it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for such as satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We retain your Identity, Contact and Property, Financial & Benefits Data, for the maximum period of 7 years from the end of the ECO scheme to which you are entitled.

Call recordings are kept securely and are confidentially deleted after 13 months.

YOUR RIGHTS IN REGARDS TO YOUR DATA

You have certain rights regarding information held about you by the Controller (these do not apply in all circumstances). These include the right:

Your right of access - the right to request a copy of the personal data which we hold about you. This right always applies. However, there are some exemptions, which means you may not always receive all the information we process.
Your right to rectification - the right to request that we correct any personal data if it is found to be inaccurate or out of date;
Your right to erasure - the right in certain circumstances to request that your personal data is erased where it is no longer necessary to retain such data;
Your right to withdraw your consent – you have the right to withdraw your consent to processing at any time, where consent was the lawful basis for processing your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent (for example, when we have already shared your information with an approved installer with your consent);
Your right to data portability - the right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable (i.e. where our processing is based on consent or is necessary for the performance of your contract or where we process your data by automated means);
Your right to restriction of processing - the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
Your right to object to processing - the right to object to our processing of personal data, where the processing is based on our legitimate interests or is for direct marketing purposes.

Exercising your rights

If you wish to exercise any of the rights set out above, please contact us using the contact details provided above in the ‘Contacting us’ section of this privacy notice.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with your request altogether in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you if necessary to ask you for further information in relation to your request to speed up our response.

If you have made a grant application, then we may ask you to confirm the Memorable Word that you will have provided so as to validate your identity.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.