HUG 2 is a government scheme awarding grants to local authorities (LAs) for energy efficiency and clean heating upgrades in owner occupied and private rented sector fuel-poor homes off the gas grid. The HUG 2 Scheme aims to deliver two main objectives:

  • to deliver progress towards the statutory fuel poverty target for England, by improving as many fuel-poor homes (of energy efficiency rating Band D, E, F and G) as reasonably practicable to Band C by 2030;
  • to progress the UK’s target to reach Net Zero by 2050, by supporting the phase out of off-gas grid fossil fuels and transition to low-carbon heating systems.

The HUG 2 Scheme launched by the Department for Business, Energy and Industrial Strategy (BEIS) to help local authorities provide energy efficiency upgrades and clean heating systems to low-income households.

We use the HUG 2 Scheme funding to set up arrangements for consumer engagement and the delivery of installations in homes and aim to improve the standard of private sector properties through grant assistance, enforcement action, education and advice. 

The purposes for which BEIS and/or BEIS delivery partners/agents are processing your personal data is to support the delivery and administration of the HUG 2 Scheme. This includes the assessment of applications by us for the funding of installations at the property, monitoring the use of the BEIS funding and creating a record of installations.

Most of the personal information we hold about you is provided by you. If you choose not to provide us with the information, we ask for, in many cases, we will not be able to provide you with the service.

Processing activity/purpose - we will process personal information relating to supporting the delivery and administration of the HUG 2 Scheme.

Information requirements – processing activities may include:


  • Your name
  • Email address
  • Phone number [optional]
  • Address and details of property receiving the HUG 2 Scheme’s  energy efficiency or low-carbon heating installation(s)
  • Contact address (if not the property receiving the HUG 2 Scheme’s installation(s)
  • Details about the installation(s) applied for or installed at the property under the HUG 2 Scheme, including type, size and cost and installer details
  • HUG 2 Scheme awarded grant amount and any financial contribution you or others have made towards the installation(s) under the HUG 2 Scheme
  • Customer referral source or customer source for initial awareness of the HUG 2 Scheme
  • Other HUG 2 scheme participation information, such as the local authority, scheme reference number, unique property reference, property type and characteristics including EPC rating
  • Information of previous access to government grant schemes

Delivery Partner - Installer:

  • Your name, contact business address, email address and phone number
  • Trustmark/MCS accreditation details and any other relevant certification information
  • Business information, including name, type of business and number of employees
  • Details of installations delivered under the Scheme, including type, size and cost and details of the properties at which the installations are installed
  • Whether directly contracted or sub-contracted to install installations under the Scheme

Lawful bases[1] - our lawful bases for processing your personal information are:

  • UK GDPR Article 6(1)(e)) and DPA 2018 section 8(c)  - that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, pursuant to section 111 Local Government Act 1972, in combination with sections 2 and 4 of the Home Energy Conservation Act 1995, Warm Homes and Energy Conservation Act 2000, the Climate Change Act 2008 and the Fuel Poverty (England) Regulations 2014
  • UK GDPR Articles 9(1) and 9(2)(g) the processing by us of special category personal data, namely health data and DPA 2018, section 10(3) & Schedule 1, part 2, para.6(2)(a), justified by the above legislation

We have a Data Protection Policy that sets out how this information will be handled.

BEIS lawful basis - The specific public task is the delivery, administration, audit and evaluation of the Scheme, as well as statistical, research and fraud prevention purposes relating to the HUG 2 Scheme aiming to improve the energy performance of off gas grid homes in England rated at EPC Band D, E, F or G.

Data Processor – Aran Construction Services (the appointed contractor for this Scheme) processes personal information on our behalf in accordance with our written instructions.

Data sharing – delivery and administration of the HUG 2 Scheme may require linking your data to other data sets held by us or BEIS and sharing with  or receiving (as applicable) your data from:

  • appointed contractor(s), suppliers and their sub-processors
  • BEIS or with a contractor or organisation appointed by BEIS to act on its behalf in connection with the HUG 2 scheme (BEIS delivery partners/agents)
  • Trustmark, Ofgem and other government departments and organisations administering central or local government schemes that support energy efficiency or low-carbon heating measures
  • HM Treasury and the Department for Levelling Up, Housing, and Communities, where necessary

Your personal data may be shared with Trustmark for the purpose of upholding installation standards under the HUG 2 Scheme.

Your data may also be used by us and/or BEIS for statistical, research and fraud prevention purposes.

We and/or BEIS may share your data if we are required to do so by law, for example by court order or to prevent fraud or other crime.

BEIS  may undertake data matching between the data shared by us and other datasets to check that relevant blending or duplication of funding has not taken place. Where a potential case of such blending or duplication of funding is identified, BEIS will notify us and we will share personal data.

BEIS will be conducting an evaluation of the HUG 2 Scheme. This may include you being contacted by BEIS or its delivery partners/agents to take part in further research. Where the research involves processing of personal data in addition to that already collected for delivery of the scheme, you will be given the opportunity to opt-in to that research at the point of contact.

Personal data shared may be stored on the BEIS’s IT infrastructure and may therefore be shared with BEIS’s data processors Microsoft and Amazon Web Services. This means your data may be transferred and stored securely outside the UK or European Economic Area. Where that is the case, it will be subject to equivalent legal protection through the use of Model Contract Clauses.

We may rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent & Medway Information Agreement for further details on our sharing arrangements.

Retention period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be maintained for 6 years after 31 March 2025. We may choose to store anonymised data beyond this period. All information will be held securely and disposed of confidentially.

Your personal data will be stored securely by BEIS for a maximum period of 25 years following the close of the HUG 2 Scheme. BEIS may choose to store anonymised data beyond this period.

Anonymisation- your personal information may be converted ('anonymised') by us into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports. Anonymised data may be shared with relevant government departments.

Right to object – where processing your personal information is required for the performance of a public interest task (see our lawful basis above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.

Changes to this Privacy Notice – we review this Privacy Notice regularly and will place updates on our website.

Please refer to our Corporate Privacy Notice for further details of how we process your personal information and your rights.

BEIS: Once your personal data has been shared with BEIS or with its delivery partners/agents, BEIS will become a data controller for that personal data.

  • You have the right to request information about how your personal data are processed, and to request a copy of that personal data
  • You have the right to request that any inaccuracies in your personal data are rectified without delay
  • You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement
  • You have the right to request that your personal data are erased if there is no longer a justification for them to be processed
  • You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
  • You have the right to object to the processing of your personal data

If you wish to make a request associated with any of the rights listed above and in relation to personal data shared with BEIS or with BEIS delivery partners/agents, you may contact BEIS using the following contact details:

BEIS Data Protection Officer, Department for Business, Energy, and Industrial Strategy, 1 Victoria Street, London W1H 0ET: Email:

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

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

Tel:0303 123 1113 Email:

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.


[1]Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information