How your personal information is used
LEAP is a free of charge service offering energy efficiency advice, support and free energy saving measures, offered by Agility Eco Services Limited (“we” or “us”). This Privacy Notice applies between you and/or the user of our LEAP services and AgilityEco.
AgilityEco Services Ltd (‘AgilityEco’) acts as a Data Controller under the General Data Protection Regulation (‘GDPR’). We are registered with the Information Commissioner’s Office (‘ICO’) as a Data Controller under registration number ZA000042.
We take the privacy of your information very seriously. Here are the simple principles which we abide by to protect your privacy:
- We only ask you for and process information which we genuinely need in order to provide you with an excellent service; and
- Where you do enquire about our services and consent to provide us with more than one method of contacting you, for example an e-mail address and telephone number, we will use both methods for correspondence with you, until such time as you withdraw your consent (which may be done at any time) for any or all of those methods of contact; and
- Unless legally obliged to do so we won’t share your information with anyone, other than for the standard running of LEAP
This Privacy Notice applies to our use of any and all data collected by us or provided by you in relation to the provision of our services to you under the LEAP service. We aim to make our collection and use of your data as clear and as transparent as possible, but for brevity it has not been possible to list every circumstance in which we will use your data. We recommend that you read this Privacy Notice carefully. Any questions or queries you may have can be sent directly to us at:
email@example.com or: AgilityEco, Suite 5, Mid-Day Court, 20-24 Brighton Rd, Sutton, Surrey SM2 5BN
AgilityEco operates LEAP in conjunction with a wide variety of partners, details of whom can be provided to you at your request. Our partners include, but are not limited to:
- Local Authorities and Social Housing Providers;
- Bierce Surveying Ltd, our subsidiary company; and
- Third party service providers, for example central heating installers.
Your local council, housing association or other local agency may have referred you to us, in which case you will have been asked by them to give your consent for your contact details and other personal information to be provided to us so that we can assess whether you qualify for LEAP and where you do, for us to contact you directly. You do not have to disclose any information to us that you feel uncomfortable sharing with us at any stage during the LEAP service.
If you have previously consented to us contacting you, but have changed your mind, you may withdraw this consent at any time by contacting us using the information given in this Privacy Notice.
Data Requested From You
In line with our principles, in order to provide you with a service or to respond to any questions or queries you may have, we may request and collect the following data from you:
- Your name; and
- Your contact Information such as email addresses and telephone numbers.
Data provided to us through our application form, or where you e-mail us, is processed by us with your consent. You may remove your consent at any time by contacting us using the information given in this Privacy Notice.
When we receive your enquiry, we will contact you by telephone using the number(s) you have provided and will then seek your consent to collect further information about your personal and household circumstances in order to establish whether you are eligible for the LEAP service and to ensure that we provide you with the best service that we can. This information may include:
- Household income information
- Names of any state benefits you receive
- Relevant information about health problems
If you agree to energy advice support from one of our Energy Advisors, he/she will be sent, via our secure contact management system, a summary of information about you and your circumstances. During the call/visit, the Energy Advisor will ask you more personal questions about your household circumstances such as your energy bills in order to establish whether they can assist you during the call/visit, or whether they recommend that you are referred on into an additional service, such as our telephone-based Income Maximisation service, or for a major energy efficiency measure such as loft insulation. Your information will not be sent to any third party after the call/home visit except with your explicit consent. A full explanation will be given to you during the call/home visit. You can withdraw consent at any stage of the process.
How do we use (process) your personal data?
Where you have requested we provide you with a service, we will keep your data for the purposes of evidencing that you were eligible to receive the service, and to ensure we tailor the service to your needs or for other closely related purposes. Where you have consented during the call to be referred into a related service provided by one of our service partners, only the bare minimum of your information will be shared, sufficient for that third party to be able to contact you directly to explain their service to you.
We will never rent or sell any of the data you provide to us, and any third parties we use will only ever process your information for us on a need to know basis and in accordance with this Privacy Notice.
Our data processing activities conducted on the lawful basis of ‘legitimate interests’ are:
- To assess your eligibility for the support, services or solutions you are looking for
- Where eligible, to offer you support, services or solutions you are looking for
- To send notifications on subjects you have subscribed to, or otherwise asked us to keep you informed of
- To improve the quality of the services we offer, and to better understand our customers’ needs by requesting feedback, or requesting you review the services we have provided, or we may send survey forms that we ask you to complete
- To notify you of any changes to any goods and/or services we provide, or have provided, that may affect you
- To recognise when customers re-engage with our services
- To provide reference information to third party organisations where requested or where necessary.
We may also process your personal data for LEAP to comply with our various legal obligations; this might include:
- Complying with industry regulatory requirements and any self-regulatory schemes
- Cooperating with relevant authorities for reporting criminal activity, or to detect and prevent fraud.
Where we have received your consent to do so we will process your personal data to inform you of the goods and services provided by our partners or other third-party organisations.
You may withdraw your consent for us to process your personal data for these purposes at any time. After a withdrawal of consent request is received, we may contact you to verify the request. Withdrawing your consent for us to process your personal data will not affect the lawfulness of the processing beforehand.
How long will we keep your data for?
Other than data we are legally obliged to keep for longer periods, e.g. taxation records, we will retain any data you submit to us for between 18-24 months in order to comply with requirements laid down by our Funder. This includes e-mail correspondence. All of your data which we collect is stored securely with appropriate physical, managerial and electronic safeguards in accordance with the principles of the General Data Protection Regulation and any other applicable legislation.
Who might we share your information with?
We strive to keep third party access to your data to a minimum. However, data provided by you to us may in some circumstances need to be passed to third parties which we use for the running of our scheme, for example:
- to the hosting provider of our website;
- to Zoho Corporation who host our cloud based data;
- to the Lead Delivery Partner, the Funder, your local authority, housing association or other charity partner for the purposes of monthly reporting, where your data will be anonymised.
- to third party suppliers working for the LEAP service;
Information passed to third parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties for us will be processed within the terms of this Privacy Notice and in accordance with the General Data Protection Regulation.
Your Access to Your Data which is Held by Us
Under the General Data Protection Regulation you have certain rights as regards the personal data we hold on you. Where you would like to exercise these rights, you can do so by using a Subject Access Request or (‘SAR’).
In a SAR you can ask us if we hold personal data on you, and if so, request a copy of that data. We will also give you a description of the data, tell you why we are holding it and tell you who we could have disclosed it to. We do not charge for the provision of this information.
You can also use a SAR to:
- ask us to rectify data on you which is incorrect;
- ask us to stop processing data on you;
- ask us to delete the data we hold on you;
- ask us to stop processing your data;
- ask us to transfer your data to another Data Controller/provide you with your data in a machine readable format;
- object to us processing your data (including for use in direct marketing); and
- exert rights in relation to automated decision making and profiling.
We will reply to all requests as soon as possible, and in no event later than one month. Not all of these rights may be available to you, and will depend on the lawful basis we process your information.
For more information on your rights under The General Data Protection Regulation, please see the ICO website.
Transfers outside the European Economic Area (‘EEA’)
Some of our third-party service providers may be located out-with the EEA, including Zoho Corporation who we use for cloud based data storage. Therefore personal data which we collect from you may be stored, processed in and transferred to such countries, which may not have as stringent data protection laws as found in the EEA. If we transfer your data outside the EEA in this way, we will ensure that the third party provider which we use is compliant with the GDPR and that your privacy continues to be protected as outlined in this Privacy Notice.
Changes to Our Privacy Notice
Although any changes are likely to be minor, we reserve the right to change and update this Privacy Notice as we may deem necessary from time to time or as may be required by law. Your continued use of this website after any changes means you are deemed to have accepted any change to the terms of this Privacy Notice. As and when any changes occur, they will be set out on a change log. There are currently no changes.
Right to Lodge a Complaint
We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. In order that we can achieve this we do request that any complaints be first brought to our attention so we can properly investigate matters; if however you would like to complain about LEAP to a supervisory authority you may do so by contacting the Information Commissioner’s Office on 0303 123 1113, or anyone of the other reporting methods listed on their website – https://ico.org.uk/concerns
Governing Law and Jurisdiction
This Privacy Notice is governed by English law and any disputes will be subject to the exclusive jurisdiction of the English courts.
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