This privacy notice explains how your personal information is used if you take part in the Smarter Network Upgrades (SNUG) project, led by UK Power Networks. The Centre for Sustainable Energy (CSE) administers this notice on behalf of UK Power Networks and the other project partners because CSE manages the tenant onboarding process.

SNUG is a project looking at how energy efficiency improvements in social housing may affect household energy use and peak electricity demand. The project is intended to help develop new ways for social housing providers, electricity network operators and other partners to plan energy efficiency upgrades and flexibility services more effectively, including for households who may otherwise be left behind in the energy transition. This notice applies to personal information collected from tenants who accept the invitation to take part in the tenant research and home monitoring elements of the project.

Taking part is completely voluntary. If you decide not to take part, this will not affect your tenancy, your retrofit measures, or any services you receive. If you agree to take part, you can later withdraw your consent at any time. This will not affect any processing we carried out before you withdrew consent.

Getting in touch

We’re happy to answer any questions you have about how we are using your data. You can ask us to:

• Tell you what data we have about you.
• Stop using your data in a certain way.
• Withdraw your consent for us to use your data.
• Delete your data.
• Correct your data.

You can contact CSE about information collected through this project at privacy@cse.org.uk or on the main switchboard on 0117 934 1400. We won’t charge you for this service. If you aren’t happy about how we have used your data, you can make a complaint via these contact details. You can also contact the Information Commissioner’s Office if you aren’t satisfied with our response. See www.ico.org.uk/make-a-complaint.

Who we are

Project lead and overall data controller

UK Power Networks.

UK Power Networks (Operations) Limited is registered as a data controller with the Information Commissioner’s Office:

Company name – UK Power Networks (Operations) Limited
Company registration number (Companies House) – 03870728
Companies registration number (ICO) – Z7057514

UK Power Networks’ nominated Data Protection Officer is Nick Zentner, who can be contacted at DPO@ukpowernetworks.co.uk

For UK Power Networks full Privacy Notice, please visit the Privacy Notice page

Privacy notice administrator and joint data controller for onboarding information

Centre for Sustainable Energy
Address: St James Court, St James Parade, Bristol, BS1 3LH
Telephone: 0117 934 1400
Email: info@cse.org.uk

Data processor for monitoring-device and smart-meter data

University of Strathclyde, working through PNDC
Address: 62 Napier Road, Wardpark, Glasgow G68 0EF
Email: pndc@strath.ac.uk

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK General Data Protection Regulations (GDPR). You can find out more about lawful bases on the Information Commissioner’s Office (ICO)’s website.

Our lawful basis for collecting or using personal information in this project is consent – we received permission from you after we gave you all the relevant information. All of your data protection rights apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

What information we have received

We may have received your contact information from your social landlord, either the London Borough of Hammersmith & Fulham or Norwich City Council. The information shared with us for this purpose is limited to your:

• Home address
• Metre Point Administration Number (MPAN) – this is the unique address for your electricity supply, which tells your energy network where the power is flowing
• A summary of the proposed retrofit measures being installed in your home

These are used to contact you about taking part in the project. You can contact the Data Protection Officer at either of the local authorities below:

Hammersmith and Fulham

dpo@lbhf.gov.uk

Write to Hammersmith and Fulham’s Data Protection Officer, Hammersmith Town Hall, King Street, Hammersmith, London W6 9JU

Norwich City Council

DPO@norwich.gov.uk

Call 0344 980 3333

What information we collect and use, and why

Depending on your involvement in the project, CSE or PNDC may collect the following categories of personal information about you.

A. Information you give us directly via the onboarding questionnaire

This may include:

• Your name.
• Your address.
• Your contact details (such as phone number and email address).
• Your questionnaire responses, including demographic information (age, gender, etc.). This includes some special category data (ethnicity and health). This data is collected only to ensure we invite a diverse range of participants to follow-up research. This special category data will not be shared with other project partners.
• Details about your household, such as number of adults and children living in your home.
• Information about your energy habits, how you use heating and household appliances.
• Your views about the information you were given and your experience of the project.
• Any information you choose to provide in free text answers or support requests.

B. Monitoring and property-related data

If you choose to take part, we will arrange for a small monitoring device(s) to be installed in your home to help understand how energy efficiency measures affect energy use. These devices are provided by Hildebrand and include the Glow Delta Consumer Access Device (CAD) and the Glow Temperature and Humidity Sensor. If you agree to home monitoring, the University of Strathclyde, working through its innovation centre PNDC, will collect data from these devices. This may include:

• Half-hourly electrical energy consumption.
• Half-hourly gas energy consumption.
• Indoor temperature and relative humidity in up to two locations per property collected approximately every five minutes from three locations in the property.

Data collected through the monitoring devices will be processed directly by PNDC. CSE will not collect, access or use the monitoring-device data itself.

C. Smart meter data

If you agree, PNDC will also collect smart meter data about the energy used at your home through software platform n3rgy. This typically includes electricity and gas meter readings showing the total amount of energy used at the property, together with the date and time of each reading. Smart meters can record this information at different levels of frequency, such as monthly, daily or half-hourly readings. Smart meter data shows the overall energy use of the property, rather than identifying exactly which individual appliances are being used.

Who can access the data and who we share information with

The data will be accessed only by specific partners within the SNUG project team. We only share personal information where this is necessary for delivery of the SNUG project and where appropriate safeguards are in place.

Monitoring device installers

If you agree to have a monitor installed, CSE will share your name, address and contact details with social landlord trusted installers so that monitoring equipment installation can be arranged. Installers will then share the details of tenants who have a confirmed installation appointment with CSE, who will be your first point of contact, and will administer the monetary incentives and prize draws.

PNDC

We will share pseudonymised household-composition and relevant questionnaire information with PNDC for analysis and model development within the SNUG project. This means PNDC can connect the information to a coded property but will not receive the tenant’s name. CSE will not share special category information, such as ethnicity and health information, with other project partners. Your name and data on gender and employment status will also not be shared. PNDC will store monitoring data and smart meter data securely within University of Strathclyde private computer systems. Data will only be shared with University of Strathclyde (Energy Systems Research Unit) for the purpose of validating the home thermal model predictions produced for the SNUG project by the ESRU team.  Data will be aggregated and processed for this validation using generalised property archetypes, and at this stage the project monitoring data will be fully anonymised.

UK Power Networks

We may share aggregated or anonymised project information with UK Power Networks in their role as project manager. This may include high-level reporting about project activity and participation, such as overall recruitment numbers or anonymised demographic summaries. We do not share information with UK Power Networks that directly identifies you for these reporting purposes.

What we will do with your information

We use your information for two main purposes. First, CSE uses onboarding information to choose a range of tenants for follow-up interviews, so that different types of homes and households are included. Second, the University of Strathclyde’s Energy Systems Research Unit will use monitoring, smart-meter, household and property information to test and refine models of common types of home. The models will be used to estimate how energy-efficiency improvements may affect energy use where similar comfort levels are maintained, including at peak times. We will not use your name, address or any other directly identifiable information in reports, publications or presentations arising from the project.

The data will also be further anonymised and aggregated following the UK Power Networks’ Open Data Portal triage process to enable only useful and appropriate data to be shared on the portal.

We will not:

• Use data collected through this project for automated decision making or profiling.
• Transfer or store data outside of the UK.

How long we keep information

For this project we will securely remove personal data from project systems by 31 December 2028 to allow a period for amendments after project completion. At the end of the retention period, we will securely delete or anonymise your information unless we are required to keep it for longer by law. Genuinely anonymised information that forms part of generalised property archetypes may be retained after this date.

Data deletion if you withdraw from the project

Participation in the trial is entirely voluntary. You may withdraw your consent and leave the trial at any time. This also applies if you move home during the project and can no longer take part.

We will contact you directly to find out what you would like done with the data already collected through the project. If you ask for your data to be withdrawn, CSE will notify the relevant project partners so that consent is withdrawn on both the Hildebrand and n3rgy platforms and no new information is collected about you for the project. We will securely delete, or permanently anonymise, the personal information we hold about you that is linked to your participation in the trial within six weeks of receiving notice of your withdrawal. This includes, where applicable:

• Information collected through the onboarding questionnaire.
• Your contact details and participant records.
• Monitoring and smart meter data that can still be linked to you or your household.

However, we may not be able to remove information that has already been anonymised, aggregated or incorporated into statistical analysis, research findings, reports or models before your withdrawal. For example, if information from your household has already contributed to a published statistic such as “X% of participating households reported a health condition”, it may not be possible to identify and remove your contribution from that result.

Any information retained in this way will no longer identify you and will not be used to make decisions about you.

How we keep your information secure

We take appropriate technical and organisational measures to protect your personal information. These include:

• Restricting access to staff and partners who need it.
• Using secure systems and access controls.
• Storing data in secure environments.
• Using contracts with processors and data sharing arrangements where required.
• Applying pseudonymisation or aggregation where appropriate.

Monitoring data will be stored in UK-based private computing facilities within the University of Strathclyde IT network. The database will be encrypted and password protected.

Changes to this Notice

Because this project will run over several years, we may need to update this privacy notice from time to time. If we make important changes to how your personal information is collected, used or shared, we will let you know using the contact details we hold for you, for example by email or post. We will also update the version date at the bottom of this notice.

Version

Last updated: 20/10/2026, Version 4.0