The Warmfront Team Ltd Privacy Policy

We are committed to maintaining privacy, confidentiality and respecting your rights in regard to the information we hold about you.  We understand this is important and we want to ensure that this is only gathered as necessary and used for a specific purpose and in a transparent manner. 

This privacy policy tells you what to expect when The Warmfront Team (“the Company”) collects personal information about you. It applies to all employees, ex-employees, agency staff, contractors, sub-contractors, and any other people working with the Company.  However, the information we will process about you will vary depending on your specific role and personal circumstances.

It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we process your personal data, we are regulated under the General Data Protection Regulation (GDPR), the Data Protection Act 2018.  Under this legislation we are considered as a Data Controller and Data Processor. 

We are considered as a Data Controller and Data Processor under the data protection legislation. 

Our contact details

Name: The Warmfront Team Ltd

Address:  Hellier House, Two Woods Lane, Brierley Hill DY5 1TA

Phone Number: 0800 0328322

E-mail: info@warmfrontteam.co.uk

The type of personal information we collect

We currently collect and process the following information:

• Identity Data including first name, middle name(s), last name, title, date of birth,
• Contact Data including your home address, email address and telephone numbers.
• Financial information, including what your income is, and what benefits your household receives to ascertain whether you are eligible for services to be carried out at your home under the eligibility of a particular scheme.
• Information about dates we are able to attend at your property to carry out pre-work surveys.
• Details of any discussions we have with you, for example in regard to when it is suitable to attend your property because of work commitments.
• Details of any special arrangements that we need to make to attend your property.
• Details of the work to be carried out at your property, to include results of any survey carried out at your property, what this indicates and what we base our decision on.
• Dates of attendance at your property.
• What work we have carried out at your property.
• Details of products we have used at your property to fulfil our obligations.
• Information in respect of any queries you make, and what information we provide you in response.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and systems.
• Profile Data including your username and password, purchases or orders made by you or with you, your interests, preferences, feedback and survey responses.
• Data in regard to how you use our website
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• To provide you with a service or services at your home address.
• To monitor when the work has been carried out.
• To ensure that the work carried out has met the required standard.
• To follow up any work in the case of any defect.

We also receive personal information indirectly, from the following sources in the following scenarios:

• From Social Landlords so they can fulfil their obligations in regard to making their properties as energy efficient as possible.
• From energy companies in accordance with their Energy Efficiency Obligations.
• From our energy assessors and or fitters if for example you have provided any further information that we need to evaluate.

We use the information that you have given us in order to:

• Carry out a survey at your property in regard to our services.
• To carry out the work that is required at your property.
• To follow up any work that is carried out.
• To provide details to your Social Landlord or energy provider.
• To ensure we comply with our regulators and accreditation bodies.

We may share this information with:

• Your social housing Landlord to enable them to make informed decisions about the measures they wish to undertake at your property.
• Your energy company to enable them to make informed decisions about the measures they wish to undertake at your property.
• Our regulators such as Ofgem, where we are obliged to do so by legislation.   
• Our accreditation bodies such as Trustmark to enable them to ensure that we are adhering to our accreditation criteria.
• Any other people you have authorised us to share data with such as a family member.
• Our appointed surveyor and or fitter so that they can carry out the work that has been commissioned.

Other circumstances when data is collected and how this is used

We may also collect data about from automate technologies or interactions, as you interact with our website technical data is automatically collected in respect to your equipment, how you browse our site.  This may be collected by using cookies, server logs and other similar technologies. 

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data whilst potentially being derived from your personal data, is not considered personal data in law as this data does not directly or indirectly reveal your identity.  One example of how we use aggregated data is usage data to calculate the percentage of users accessing a specific feature on our website and in order to help us to develop our website and services in the future. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy policy.

How we use your data - the legal basis and purpose

Under the UK General Data Protection Regulation (UK GDPR), those regulations require that where we use your personal information, we must have the required legal basis to do so.  We have considered the legal basis and the ones we rely on for processing your information are:

the lawful bases we rely on for processing this information are:

We have a contractual obligation.

We help Social Landlords fulfill their obligations in making homes as energy efficient as possible.  We also help energy companies fulfill their legal obligations under Government legislation. 

As such we contract with them to provide the services that improve your home’s energy efficiency and therefore save you money on your energy bills. 

Some examples are:

• To assess what services can improve the properties energy efficiency and agree what steps can be taken to achieve them.

Consent

Where you have provided us with your contact details we will rely on that to process the information to move forward with the energy efficiency improvements.  You can change your consent at any time by contacting us at:

Address: Hellier House, Two Woods Lane, Brierley Hill DY5 1TA

Phone Number: 0800 0328322

E-mail: info@warmfrontteam.co.uk

This right is subject to some conditions, which are set out below. 

Legal obligations

We have various rules and obligations which we must abide by, including reporting to our regulators and or accreditation bodies-for example we would be expected to provide information about work we have carried out to Trustmark-the only Government endorsed quality scheme for work carried out in and around your home. 

Legitimate interest

Where we do have a legitimate interest we will balance that against your rights. 

Examples of legitimate interest may be that we process your data:

• We may pass your details on to our self employed contractors to carry out work on our behalf at your property.
• We may use your information in the governance of our business including accounting managing and auditing our operations so that our business remains effective and performs well.
• Monitoring and recording our dealing with you, with a view to providing training to members of our team.
• For research purpose to provide products and services that are appropriate and to ascertain whether we need to make any improvements in our customer service. As part of this we or a third party we may have instructed, may contact you to seek your views and opinions of our service to ensure we continue to provide a high level of customer service. 

How we store your personal information

Your information is securely stored via Sharepoint, which is a secure system with a two step authentication process for accessing it. 

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

We keep your personal information as set out above for only as long as it necessary for dealing with your matter and in any event, for a maximum of 6 years.  We will then dispose of all of your data by securely deleting it entirely. 

Where we have any paper documentation that is relevant to you, the timescales above will apply and following that period, this will be shredded securely. 

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at

Address:  Hellier House, Two Woods Lane, Brierley Hill DY5 1TA

Phone Number: 0800 0328322

E-mail: info@warmfrontteam.co.uk

if you wish to make a request.

Other rights you have

If you have provided us with consent to process your personal data, you have the right to withdraw that consent at any time.  Should you wish to do so, please contact us as set out above. 

Whilst you can make a request for us to stop processing your information, we may not always be required to do so, for example where we have started to carry out work at your property under a contract with your Social Housing Landlord and we need to still process your data to ensure that the work is carried out satisfactorily. 

We will of course advise you accordingly if this is the case. 

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at:

Address:  Hellier House, Two Woods Lane, Brierley Hill DY5 1TA

Phone Number: 0800 0328322

E-mail: info@warmfrontteam.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk