Privacy Policy

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and 14 of the UK General Data Protection Regulation (“UK GDPR”).

It is important that you read this notice, together with any other privacy notice that is provided to you on specific occasions when we are collecting or processing your personal data, so that you are aware of how and why we are using it.

This notice does not form part of any contract. This notice can be updated at any time; we will inform you if the way we handle your personal data changes.

Personal data is any information that can be used to identify a living individual, either on its own, or in combination with other pieces of data. Examples of personal data include your name and address.

The term ‘processing’ in relation to personal data, means any operation or set of operations which is performed on personal data or on sets of personal data (whether or not by automated means, such as collection, recording, organisation, structuring, storage, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction).

This Privacy Policy relates to personal data processed as part of the delivery of the Green Heat Network Fund (“GHNF”), a capital grant fund managed by a consortium of entities for the provision of funding for the commercialisation and construction of low and zero carbon (LZC) heat networks. For the avoidance of doubt, Gemserv Limited are the data controller and will have full access to all data that you submit when enquiring about the GHNF, within your GHNF application form, supplementary information, the GHNF application process, GHNF communication activities and data collected through cookies on GHNF websites for the purposes set out in this privacy policy.

Gemserv have entered into a joint controller relationship with the parties listed in the ‘Who are we’ section for the delivery of the GHNF.

The Department for Energy Security and Net Zero, Triple Point Heat Investments Limited, AECOM, Amberside Advisors, Asteros Advisers, Lux Nova Partners, the UK Infrastructure Bank (UKIB) and the Delivery Partner of BHIVE will be able to access all information you submit when enquiring about the GHNF, within your GHNF application form, supplementary information and the GHNF application process. The Department for Energy Security and Net Zero, Triple Point Heat Investments Limited, and Amberside Advisors will be able to access the personal data for GHNF communication activities. In addition, the above-mentioned parties, including the UKIB and BHIVE Delivery Partner, will have access to monitoring and reporting data of GHNF-funded projects.
We are committed to ensuring that your personal data is protected and will make sure to use it only in accordance with this privacy policy.

This website is not intended for children, and we do not knowingly collect data relating to children. This website is also not intended to cover personal data processed for recruitment or employment purposes.

We keep this privacy policy under regular review to make sure it is up to date and accurate. We may change it at any time and will inform you if any substantial changes take place.
This policy is effective from 10th October 2022.

Who are we?

Full company details of Gemserv are as follows:

Name: Gemserv Limited, Company number 04419878
Registered office address: 77 Gracechurch Street, London, EC3V 0AS

If you have any questions about this privacy policy or our privacy practices, please email us at dataprivacy@gemserv.com.

Gemserv are joint data controllers with the following parties:

• Department for Energy Security and Net Zero located at 1 Victoria St, Westminster, London SW1H OET
• Triple Point Investment Management LLP – company number OC321250 located at 1 King William St, London EC4N 7AF
• AECOM Ltd – company number 1846493 located at Aldgate Tower, 2 Leman Street, London E1 8FA
• Amberside Advisors Ltd – company number 6078852 located at Clubfinance House, 64-66 Queensway, Hemel Hempstead, Hertfordshire, HP2 5HA
• Asteros Advisors Ltd – company number 11914766 located at 20-22 Wenlock Road, London, England, N1 7GU.
• Lux Nova Partners LLP – company number 5510349 located at The Stanley Building, 7 Pancras Square, Kings Cross, London N1C 4AG

As part of these joint data controller arrangements, the parties process personal data in relation to the delivery and management of the GHNF. The arrangements cover the following processing activities:

• The processing of names and business contact details of staff of Applicants and prospective Applicants to GHNF to deliver GHNF funding and to undertake contract and performance management
• The processing of names and business contact details of interested individuals to provide send news, updates, invites to events or other communications
• The processing of names and business contact details of individuals responding to surveys for evaluation and research purposes.

With these arrangements, the following responsibilities will apply:

• Delivery and maintenance of Privacy Notice referenced in the GHNF Application Form and provided on the GHNF website: Department for Energy Security and Net Zero and Gemserv
• Due diligence of software providers which Parties use to process the GHNF Personal Data locally and appropriate contractual data processing arrangements in place: Department for Energy Security and Net Zero and Gemserv
• Maintaining a single point of contact for data subject requests: Gemserv
• Notification of a personal data breach originating from or affecting the usage of GHNF databases to the Information Commissioner’s Office and, in appropriate, Data Subjects: Department for Energy Security and Net Zero and Gemserv
• Establishing retention periods for personal data processed for GHNF purposes: Department for Energy Security and Net Zero and Gemserv
• Conducting Data Protection Impact Assessments on relevant GHNF databases: Department for Energy Security and Net Zero and Gemserv

The UKIB and BHIVE Delivery Partner will be given access to application data as well as monitoring and reporting data submitted to the joint data controllers by GHNF-funded projects.

The data we collect

The data to be collected will include different types of personal information that is defined as personal data under the UK General Data Protection Regulation and Data Protection Act 2018 and any other relevant legislation (together “Data Protection Legislation”). It does not include aggregated data where your identity details have been removed and the data cannot be attributed to you any longer.

We may collect the following personal information from you, either via your application for GHNF funding for your project, through information gathering channels deployed at events and online, as collected through the GHNF website, as provided through enquiries, or as otherwise voluntarily provided:

We may also conduct data processing to comply with a legal obligation, when for example, we need to retain your data for a certain time for financial obligations, or where requested by law enforcement or other public authorities.

We will neither collect, nor process any special categories of personal data in the GHNF application form.

Should you provide any special category data to us through any additional information supplied either to support your application, or for the purpose of accessing our events and resources it will only be processed for the specific purpose that it was supplied.

We may also collect personal data through cookies. Please see the Cookie notice for more information, as well as our cookie banner.

How we use your data

We require the information covered in the “The data we collect” section above for the following purposes:

• Evaluating projects for GHNF funding
• Processing GHNF applications
• Evaluation, development and continuous improvement of GHNF and heat network policies e.g., the application process, assessment process, engaging with third party investors etc
• Sending press releases, news and invites to events in relation to GHNF and Department for Energy Security and Net Zero heat decarbonisation policy
• Providing reporting to Department for Energy Security and Net Zero
• Fulfilling statutory and regulatory reporting obligations
• Responding to your enquiries and assisting with handling them
• Creating sampling frameworks and contacting for further evaluation and research purposes
• Evaluating or researching the effectiveness of the GHNF as a whole
• Carrying out surveys in relation to GHNF funding and application process

Legal basis for processing

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use it for a new purpose, we will notify you and we will explain the legal grounds which allows us to do so.

We will only use your personal data when the law allows us to. We process the data covered in the “The data we collect” section above primarily to allow us:

• to perform a task carried out in the public interest, including processing applications for, and responding to enquiries and claims in relation to, GHNF funding within the UK’s decarbonisation policy
• with your consent, as received from each party
• to comply with a legal obligation, when for example, we need to retain your data for a certain time for financial obligations, or where requested by law enforcement or other public authorities

Automated decision making

We will not use your personal data in any automated decision making (making a decision solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

When we will share your personal data

We will share your personal data information with third-party service providers, where they are contracted by us to provide specific services in order to facilitate delivery of our services for the purposes set out in the “How we use your data” section.

We will allow the following third parties to process your personal data:

• back-office service providers for data storage services, including Microsoft SharePoint and Microsoft Dynamics
• the web hosting provider for the GHNF website
• email management providers for assisting with email queries, including Microsoft
• research organisations for research, evaluation and statistical archiving purposes – including for the construction of sample frames
• the GHNF organisations and entities, which include Gemserv Limited, the Department for Energy Security and Net Zero, Triple Point Heat Investments Limited, AECOM, Amberside Advisors, Asteros Advisers, Lux Nova Partners
• the UKIB for the purpose of assessing GHNF applications for UKIB loan eligibility
• BHIVE Delivery Partner for the purpose of assessing GHNF applications for third-party funding.

We require our third-party service providers to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. This includes our instruction to the UKIB and BHIVE Delivery Partner to process your data, including personal data, for the purpose of considering the suitability of your project for a UKIB loan or other third-party funding, offering you a loan /third-party funding and the monitoring of compliance with the terms of that loan /funding offer if it is agreed.

As your personal data is stored on our IT infrastructure and shared with our data processors, including Microsoft, it may be transferred and stored securely in the UK and European Economic Area. Where it is the case that your personal data is stored outside the UK and EEA it will be subject to equivalent legal protection through the use of the ICO’s International Data Transfer Agreement.

We will not otherwise transfer the personal information we collect about you to the service providers located outside the UK, EU and EEA, unless they ensure that your personal information receives an adequate level of protection. We will take steps to ensure your privacy rights are protected and your personal information is treated in a way that is consistent with and which respects Data Protection Legislation, by putting in place appropriate measures, including requiring appropriate security measures.

We may also need to share your personal data with Public Authorities (e.g., the police) or to otherwise comply with the law.

How long do we retain your personal information?

We will only retain your personal information as for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal or reporting requirements.

These retention periods are provided in accordance with the “The data we collect” section above. For most GHNF application data, this would be seven years following the end of a project’s reporting obligations (as an applicant or successful project).

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Controlling your personal information

It is important that the personal information we hold about you is accurate and current. If you believe that any information, we are holding about you is incorrect or incomplete, please email dataprivacy@gemserv.com.

In accordance with the Data Protection Legislation, under certain circumstances, you have the right to:

• Request access to your personal data – This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data – This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data – This enables you to object to the processing of your personal data in certain circumstances, including where data is processed under public task or legitimate interests.
• Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in specific circumstances.
• Request transfer of your personal data to you or to a third party – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent, where consent has been given to the processing.

You will not have to pay a fee to exercise any of your rights. However, we may charge a ’reasonable fee’ for the administrative costs of complying with a request if it is manifestly unfounded or excessive, or if an individual requests further copies of their data. If we refuse your access to personal data, we will explain the reasons in our response to you. If you wish to exercise any of your rights, please contact us at dataprivacy@gemserv.com.

Additionally, you can opt-out to emails from us at any time by contacting dataprivacy@gemserv.com.

Cookie notice

Use of cookies in connection with the websites and our Cookie Policy 

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of our website. Cookies allow us to store your preferences to correctly present content, options or functions throughout our website. They also enable us to see information like how many people use our website and what pages they tend to visit.

Cookies have different durations. Temporary cookies, such as those only valid for your browsing session, expire when you close your browser.  Permanent cookies, however, will remain on your computer for a longer period until you delete them.  We may also use the information gathered from Cookies to compile reports to improve the functionality and user experience of our website.

Cookies can be set by different actors. Typically, this occurs in two cases:

• First-party cookies: These are cookies set by this website for our visitors.
• Third-party cookies: These which are typically set by other websites whose features run on our website (such as social media plugins). We do no use third party cookies on the GHNF website.

Cookies have different purposes. We typically use the following cookies:

• Functional Cookies: Cookies that are strictly necessary to enable you to move around our websites or to provide certain basic features. This includes basic features such as playing videos, and storing information already entered (e.g., username, language, location, consent preferences). These include:
  • Complianz cookies (cmplz_stats, cmplz_choice, cmplz_id, cmplz_marketing, cmplz_policy_id): These record which cookies you consent to. Max duration: 365 days
• Statistics: These are cookies that monitor the popularity of sections of our website. We do not deploy Statistics cookies on the GHNF website.
• Marketing: These cookies may track users and display advertisements relevant to them but can also include some otherwise functional cookies. We do not deploy Marketing cookies on the GHNF website.

Your rights in relation to cookies

We generally only place Functional cookies, which are mandatory for this website to operate. We conduct this under the performance of a task in the public interest, for the website to function. You may also set your browser settings to attempt to reject all cookies or manually delete the Cookies and may still use this website.

Contact details of the data controller

The data controller for your personal data is Gemserv Limited.

If you have any questions about this privacy policy or our privacy practices, please email us at dataprivacy@gemserv.com. You can also contact us at:

Complaints

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.

Make a complaint

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

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial changes. We will also notify you in other ways from time to time about the processing of your personal data.

Change of purpose

We will process your personal data for the purpose for which we collected it. If we process your personal data for another purpose that we reasonably consider to be compatible with the original purpose, we will notify you and explain the legal basis which allows us to do so.