Energy Performance of Buildings (Scotland) Regulations 2025: data protection impact assessment

The purpose(s) of the processing

Energy Performance of Buildings Regulations

The data is processed for the purpose of generating an EPC when required to do so by the regulations, and for the purpose of maintaining a publicly-accessible Register of EPCs when they are lodged.

Other uses of EPCs

Production of a valid EPC may be required to gain access to Scottish Government or UK Government funding programmes. The private sector may require an EPC, for example, finance providers may offer certain products based upon a property demonstrating that it has achieved a particular EPC rating. Government programmes or third parties using any EPC data must do so in accordance with all relevant data protection legislation.

EPC Data Sharing

Regulations 16 – 20 provide for the sharing of EPC data. The regulations have a general presumption in favour of release of the data used in the preparation of an EPC and Property Report, with specific exclusions to prevent the release of personal data, or data relating to excluded properties.

We want to ensure that publicly-accessible EPC data (i.e. lodgement data from the EPC Register) can be shared widely. This is to help to support the Scottish Government’s wider strategic priorities of:

• Tackling the climate emergency by investing in green energy and infrastructure, since introducing the new EPC rating system will ensure that consumers have better information on the steps they can make to improve their property for net zero through investment in clean heating and energy efficiency; and the new operational framework will ensure higher quality EPC assessments that consumers can trust; these reforms will underpin proposed regulatory standards that will drive emissions reduction through decarbonisation of heating; and
• Eradicating child poverty, since the new EPC rating system will directly assess the contribution that poor energy efficiency makes towards fuel poverty specifically, and child poverty more widely, helping to inform the Scottish Government’s statutory fuel poverty strategy and to better-target government programmes and funding towards improving those properties which are hardest to heat.

Sharing the EPC data will enable more efficient delivery of the Scottish Government’s Heat in Buildings programme, and other initiatives that support our policy aims of improving the energy efficiency and decarbonising the heating systems of the building stock in Scotland. These include:

• Promoting energy efficiency improvements and decarbonisation of heat in buildings.
• Enabling analysis and research in relation to the energy efficiency of buildings.
• Informed analysis of government targets and activities and underpinning other programmes.
• Identifying geographic areas where the energy efficiency of buildings is low relative to other areas, or conducting research into the extent, causes or consequences of such lower levels of efficiency.
• Identifying and analysing the impact of carbon emissions on the environment resulting from buildings
• Conducting research, carrying out statistical analysis or providing information in respect of the characteristics of buildings or building units.