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Updated July 2021
Contents:
- Coronavirus: Test and Trace if you get advice in person
- How we use your information
- The role of the data controller
- Our commitment
- Who are we?
- Our promise when we ask you for personal information
- Our promise when we record and use your personal information
- When can we use your information without permission
- Anonymised data
- When you get advice from an adviser
- How we’ll use your information
- How to withdraw your consent
- Giving consent without your real name
- When we share your information with other organisations
- Storing your information – if you contact us online, by phone…
- When you have a Pension Wise appointment
- Get in touch with us about your data
- If you want to make a complaint
How we use your information
At Citizens Advice we collect and use your personal information to help solve your problems, improve our services and tackle wider issues in society that affect people’s lives.
We only ask for the information we need. We always let you decide what you’re comfortable telling us, explain why we need it and treat it as confidential.
When we record and use your personal information we:
- only access it when we have a good reason
- only share what is necessary and relevant
- don’t sell it to anyone
We collect and use the details you give us so we can help you. We have a ‘legitimate interest’ to do this under data protection law. This means it lets us carry out our aims and goals as an organisation. We’ll always explain how we use your information.
The role of the data controller
A data controller is responsible for your data and must make sure that your data is processed in accordance with the law.
For the purposes of the General Data Protection Regulation, Citizens Advice are data controllers ‘in common’ with the rest of the service for the client data held in our electronic case systems and are jointly responsible for client data.
For the purposes of the General Data Protection Regulation, Citizens Advice Cheshire West is the data controller for all other personal and sensitive data processed and held within the organization unless otherwise stated.
Citizens Advice and Citizens Advice Cheshire West are the data controllers for the information you provide and are jointly responsible for your data unless otherwise stated.
Citizens Advice Cheshire West is an independent charity, and a member of the national Citizens Advice charity.
Who are we?
Citizens Advice Cheshire West is a registered charity (charity number 1128367) and a company limited by guarantee (Company number 06783496). We can be contacted at our registered office – Wyvern House, The Drumber, Winsford, Cheshire, CW7 1AD.
Our commitment
At Citizens Advice Cheshire West we collect and use your personal information to help solve your problems, improve our services and tackle wider issues in society that affect people’s lives.
This privacy policy sets out the standards you can expect when we ask for or record your personal information, and explains how we’ll use it.
When we ask you for personal information we promise to:
- Explain why we need it
- Only ask for what we need
- Treat it as confidential
When we record and use your personal information we promise to:
- Only access it when we have a valid reason to do so
- Only share what is necessary and relevant
- Protect it and make sure nobody has access to it who shouldn’t
- Not sell it to commercial organizations
When we handle and store your personal information we follow the law, including the General Data Protection Regulation 2018.
When can we use your information without permission
At times we might use or share your information without your permission. We’ll only do this if there’s a legal basis for it. This could include situations where we have to use or share your information:
- To comply with the law, called ‘legal obligation’ – for example, if a court orders us to share information
- To protect someone’s life, called ‘vital interests’ – for example, sharing information with a paramedic if a client was unwell at our office
- To carry out our aims and goals as an organisation, called ‘legitimate interests’ – for example, to create anonymous case studies and statistics for our national research (Anonymised data).
- For us to carry out a task in the public interest or for our official functions, and the task or function has a clear basis in law, called ‘public task’ – for example the Consumer Service
- To carry out a contract we have with you, called ‘contract’ – for example, if you’re an employee we might need to store your bank details so we can pay you
- To defend our legal rights – for example, to resolve a complaint that we gave wrong advice
Coronavirus: Test and Trace if you get advice in person
- If you get advice in person we’ll ask for your:
- name
- email address or telephone number
We’ll keep this information in our secure case management system.
We might be asked to share your name, contact details and the date of your visit with Test and Trace or local public health organisations. This is to help track cases of coronavirus. They might contact you if they think you’re at risk after your visit. For example because someone getting advice at the same time has tested positive for coronavirus. You can find out more about Test and Trace in England on GOV.UK or Test and Trace in Wales on GOV.WALES.
We’ll never share information about the reason for your visit.
If you can’t give contact details, for example if it’s not safe for you to do so, we’ll still be able to give you advice in person.
Unlike most situations, we won’t ask for your consent before we share your contact details. If you don’t want us to share this information you can tell your local office you want to opt out.
We’re doing this to help keep you and the public safe, This is a ‘legitimate interest’ of Citizens Advice.
We won’t share your contact details with anyone other than Test and Trace or a local public health organisation.
If we share your information we’ll let you know, and offer further support.
If you want to know more about changes to our face to face services or how your information will be used, please contact us.
Anonymised data
We use anonymised data for statistical purposes and funding applications. This data is anonymised effectively and no living individual can be identified from this data or the data combined with other information. We do this to enable us to:
- meet our funders requirements,
- help improve our service
- ensure the service we provide is meeting the needs of our local community
- enable us to secure funding to provide the services to our community
If you are unhappy with the way we record and use your information you should follow the Citizens Advice complaints procedure Feedback and complaints.
You can also contact Citizens Advice Cheshire West to ask for a copy of the Citizens Advice complaints leaflet.
The accuracy of your personal data is important to us, please let us know as soon as possible if anything relating to your contact details or issue changes, which may affect the information we hold.
When you get advice from an adviser
We collect and use the details you give us so we can help you. We have a ‘legitimate interest’ to do this under data protection law. This means it lets us carry out our aims and goals as an organisation. We’ll always explain how we use your information.
We’ll get your permission by asking you to either:
- Sign a paper consent form
- Tick a box online
- Give agreement over the phone
Before we ask your permission, we’ll always explain how we use your information.
If you have been referred to us from another organisation, they’ll send us your information using a referral form. They’ll get your permission before sending us your information.
What information we ask for:
We’ll only ask for information that’s relevant to your problem. Depending on what you want help with, this might include:
- Your name and contact details – so we can keep in touch with you about your case
- Personal information – for example about family, work or financial circumstances
- Details about services you get that are causing you problems – like energy or post
- Details of items or services you’ve bought, and traders you’ve dealt with
- Information like your gender, ethnicity or sexual orientation.
We occasionally ask for details about someone else like a neighbour or your partner so we can deal with an enquiry. We’ll only do this if we have a legitimate interest in the information, or we need it to protect someone’s life.
If you don’t want to give us certain information, you don’t have to. For example, if you want to stay anonymous we’ll only record information about your problem and make sure you’re not identified.
We’ll always ask for your permission to store information about your:
- Health conditions
- Ethnic origin
- Religion
- Trade union membership
- Sexual orientation
You can withdraw your permission at any time – known legally as withdrawing consent. Tell us what personal information you don’t want us to store and we’ll delete it.
How we’ll use your information
The main reason we ask for your information is to help solve your problem. We only access your information for other reasons if we really need to – for example:
- For training and quality purposes
- To investigate complaints
- To get feedback from you about our services
- To help us improve our services
All our advisers and staff accessing data have had data protection training to make sure your information is handled sensitively and securely.
Understanding people’s problems
We use some information to create statistics about who we’re helping and what problems are the most common. We might use the information you’ve told us and your answers to the Client Experience survey. This information is always anonymised – you can’t be identified.
We share these with funders, regulators, government departments and publicly on our blogs, reports, social media and press releases.
The statistics also inform our policy research, campaigns, or media work.
We might use a research company to help us analyse the information. We have an agreement with them to make sure they store data securely and follow data protection laws. We’re still responsible for keeping your personal information safe and making sure we follow data protection law. This means we’re the ‘data controller’ for your information.
How to withdraw your consent
You have the right to withdraw your consent for us to process or store your personal data at any time.
If you have changed your mind about consent you’ve already given, contact Citizens Advice Cheshire West either in person or in writing to:
Chief Executive
Citizens Advice Cheshire West
Wyvern House
The Drumber
Winsford
Cheshire
CW7 1AD
Or by email: jason.bishop@citizensadvicecw.org.uk
Giving consent without your real name
You can consent without using your real name, but we can’t advise you unless we create an unnamed record of your case, which we need for quality assurance purposes. Other personal information might be recorded if you choose to give it to us. Choosing not to use your real name will not affect the level of service or advice you receive, and we’ll never try and identify you if you’re an unnamed client.
When we share your information with other organisations
With your permission, we might share your information with other organisations so we can:
- help solve your problem – for example, if you ask us to contact your creditors we might need to share your name, address and financial details with them
- refer you quickly to another organisation for more advice or support, if relevant
- help you access certain services – for example food banks or Trading Standards
- monitor the quality of our services
Organisations we share your data with must store and use your data in line with data protection law. They’ll have their own privacy policies for how they handle your information and keep it safe.
There might be specific organisations we share your information with, depending on what service you access.
If you’re in Wales, we’ll use a system called Refernet if we need to refer you to another organisation – or if another organisation refers you to us.
If you’re referred through Refernet, your information will be stored securely on the Refernet system. We keep your information on Refernet for a year from the date you’re referred. After a year, your information is deleted.
If you get advice in person
NHS Test and Trace or local public health organisations might ask us to share your name, contact details and the date of your visit. This is to help track cases of coronavirus. We have a legitimate interest to share this information under data protection law.
We won’t:
- share information about the reason for your visit
- share your contact details with anyone other than Test and Trace or a local public health organisation
Unlike most situations, we won’t ask for your consent before we share your contact details. If you don’t want us to share this information you can tell your local office you want to opt out. If you don’t want to give us your contact details at all, we’ll still be able to give you advice in person.
NHS Test and Trace might contact you if you visited at the same time as someone who tested positive for coronavirus. You can:
- find out more about Test and Trace in England on GOV.UK
- find out more about Test and Trace in Wales on the Welsh Government website
If you have the NHS Test and Trace app on your phone you can ‘check in’ at some of our local Citizens Advice offices. You can still get advice even if you don’t check in on the app. You can:
- find out how the NHS Test and Trace app will use your information on GOV.UK
- download the NHS Test and Trace app from NHS.UK
If you need a food bank voucher
We’ll ask your permission to share your information with the Trussell Trust – they run food banks across the country. You can check the Trussell Trust’s privacy policy on their website.
If your adviser applies for ‘breathing Space’ scheme to protect you from your creditors
We’ll share your information with the Insolvency Service if you decide to enter a Breathing Space. The Insolvency Service will store your contact details and information about your debts on their online Breathing Space system. Your creditors will be able to see your information on the system, but only for debts you owe to them.
If you’re the client of a different advice charity and used the Debt Advice Project
Your personal information is shared securely with us from the charity you got advice from. They should get your permission then send us the information. We then share some information with the Money and Pensions Service, our funder, as part of our regular reporting.
This information includes:
- your name, contact details and postcode
- your demographic information – like your age, gender and ethnicity
- your employment and housing status
- your income and debts
- what kind of advice you got and the outcome
- if you were referred to another organisation
The charity you got advice from will have their own policy on how they use, store and share your data.
If we’re concerned about your or someone else’s safety
If something you’ve told us makes us think you or someone you know might be at serious risk of harm, we could tell the police or social services – for example if we think you might hurt yourself or someone else.
Storing your information – if you contact us online, by phone or face to face
Whether you get advice face to face, over the phone, by email or chat, our adviser will log all your information, correspondence, and notes about your problem into our secure case management systems. We have a ‘legitimate interest’ to do this under data protection law. This means it lets us carry out our aims and goals as an organisation.
Some of your information might also be kept within our secure email and IT systems.
We keep your information for 6 years. If your case has been subject to a serious complaint, insurance claim or other dispute we keep the data for 16 years.
Our case management systems are hosted within the EEA and wherever possible, the UK.
Most of our trusted partners store their data securely within the European Economic Area (EEA) in line with data protection law.
There might be other places we store your information, depending on how you accessed our advice.
If you contact us for chat or email advice
We’ll store your chat transcript or email advice request form in our case management systems – this is kept for 6 years.
In most cases, the transcript or email form’s also stored in an online system run by Citizens Advice’s trusted partner LivePerson.
LivePerson will delete all the data after 13 months.
Our chat advisers can see this information when they chat with you, but it isn’t copied to your case record.
We use this data to improve the advice we give you. We also use it to research the needs of our users. This helps us make sure people in different areas and using different devices and systems can use our website and chat service.
Our chat system records anonymised statistics so we can track chat usage and performance. This data doesn’t contain your personal information.
The data in our chat system is stored securely within the European Economic Area (EEA) in line with data protection law.
You can ask for a copy of your chat to be securely emailed to you. The sender of the email will be transcripts@citizensadvice.org.uk
Any emails directly between you and your adviser are stored within the Citizens Advice Cheshire West system. Any email that you send is copied into our secure electronic case recording system and then deleted from GMail.
If you tell us sensitive details about yourself, we’ll ask for your permission to use and store them. This includes your:
- health conditions
- ethnic origin
- religion
- trade union membership
If you get advice over the phone
If you call us, we’ll record the conversation for training and monitoring purposes.
When you call, you’ll hear a recorded message telling you how we use and store your information – you can let the adviser know if you disagree.
Calls are recorded by our trusted partner, KCOM. They’ll be deleted after 6 months.
If you agree to get appointment reminders by text message (SMS)
If you give us permission, we might send you text messages (SMS) to remind you when you’ve got an appointment soon.
If we send you a message it will contain the date, time and location of your appointment. It might also include some personal details about you, like your first name, so you know the message is from Citizens Advice.
We use a system called Notify to send text messages. Notify stores any messages it sends for 7 days then deletes them automatically. You can check how Notify keeps your data secure on GOV.UK.
We’re responsible for keeping your personal information safe and making sure we follow data protection law. This means we’re the ‘data controller’ for your information.
If you get advice by Skype or an app like WhatsApp
Your local Citizens Advice should have their own policy that covers how they store your information through these channels. Contact your local Citizens Advice and ask to see the policy – or check their website.
How we’ll store your information
Whether you get advice face to face, over the phone, by email or webchat, our adviser will log all your information, correspondence, and notes about your problem into our secure case management systems.
Paper copies of your information may also be stored securely where necessary and accessed by staff and advisers of Citizens Advice Cheshire West.
Some of your information might also be kept within our secure email and IT systems.
We keep your information for 6 years. If your case has been subject to a serious complaint, insurance claim or other dispute we keep the data for 16 years.
If you use the consumer service, we keep your information for 6 years and then anonymise it. This means that you can no longer be identified from it. Please see the nationa Citizens Advice policy for more information: https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/using-our-consumer-service-our-privacy-policy/
Our case management systems are hosted within the EEA and wherever possible, the UK.
Most of our trusted partners store their data securely within the European Economic Area (EEA) in line with data protection law.
Why we record phone calls
Phone calls are recorded for training and quality purposes. Calls are recorded by our trusted partner, KCOM. The recordings are stored for 6 months then automatically deleted.
When you have a Pension Wise appointment
When you use Pension Wise, Citizens Advice collect personal information about you so we can give you the right guidance about your pension options.
When you ask for a Pension Wise appointment using the GOV.UK website, the national Pension Wise contact centre, local Citizens Advice office or your employer, your personal details are passed to the nearest Pension Wise service so they can book your appointment.
We then collect more information from you during your Pension Wise appointment. Please see the national Citizens Advice policy for more information: https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/when-you-have-a-pension-wise-appointment/
Get in touch with us about your data
You can contact us at any time and ask us:
- What information we’ve stored about you
- To change or update your details
- To delete your details from our records
You have the right to request access to any of your personal data held by Citizens Advice Cheshire West. This is known as a Subject Access Request (SAR) and is free of charge. We will normally provide the information within 1 month of receipt of your request. To ensure compliance with the one month deadline, any such request should be addressed to:
Chief Executive
Citizens Advice Cheshire West
Wyvern House
The Drumber
Winsford
Cheshire
CW7 1AD
You also have the right to withdraw consent, request that your data is updated or corrected, you have a right to have your data deleted or processing restricted and to object to the processing of your data. Please click on the link below to read more about your individual rights.
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-General Data Protection Regulation/individual-rights/
If you want to make a complaint
If you wish to raise a complaint on how we have handled your personal data, you should contact us at:
Citizens Advice Cheshire West
Wyvern House
The Drumber
Winsford
Cheshire
CW7 1AD
You also have the right to complain to the Information Commissioner’s office. More information can be found here:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-General Data Protection Regulation/individual-rights/
If you are not satisfied with our response or believe we are processing your data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).