Privacy Policy
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At Citizens Advice Cheshire East, 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 explains how we use your information and what your rights are. We handle and store your personal information in line with data protection law and our confidentiality policy. The following pages tell you more about how we use your information in more detail.
Our network
Citizens Advice is a membership organisation made up of the national Citizens Advice charity and many local offices across England and Wales, including Citizens Advice. Citizens Advice Cheshire East is an independent charity and a member of the national Citizens Advice charity.
All members of the Citizens Advice network are responsible for keeping your personal information safe and making sure data protection law is followed.
Members of the network also run some jointly designed services and use some of the same systems to process your personal data. In these instances we are joint data controllers for these activities.
Jointly controlled data
All offices in the Citizens Advice network use some joint systems to carry out our activities. These include joint case management systems, telephony platforms and more.
Staff from a different local Citizens Advice can only access your personal information in a joint system if they have a good reason. For example when:
● you go to a different office to seek advice
● more than one office is working together in partnership
● they need to investigate a complaint or incident
We have rules and controls in place to stop people accessing or using your information when they shouldn’t.
Tell an adviser if you’re worried about your details being on a national system. We’ll work with you to take extra steps to protect your information - for example by recording your problem without using your name.
National Citizens Advice has a privacy notice available on their website that covers general advice and nationally managed systems, including our case management systems. This policy covers the processing we carry out in our office.
How we use your data for advice
This section covers how we use your data to provide you with advice.
For general advice and nationally funded advice programmes please see the national Citizens Advice privacy notice.
How we collect your information
The national Citizens Advice charity and your local Citizens Advice operate a system called Casebook to keep your personal information safe. This means they’re a ‘joint data controller’ for your personal information that’s stored in our Casebook system.
In addition, Citizens Advice Cheshire East uses Google Workspace as its productivity suite and some of your personal data may be stored there while your case is active. Our policy is to minimise all data collected and we aim to transfer all personal information to casebook during the course of your case.
What information we collect
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, or if you're vulnerable or at risk of harm
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 age, gender, health and ethnicity or sexual orientation
What we use your information for
We collect and use your personal information in our general, specialist and project advice services to help you solve your problems.
Our confidentiality policy
At Citizens Advice we have a confidentiality policy which states that anything you tell us as part of advice will not be shared outside of the Citizens Advice network unless you provide your permission for us to do so.
There are some exceptions to this such as needing to share:
● to prevent an immediate risk of harm to an individual
● In select circumstances if it is in the best interests of the client
● where we are compelled to do so by law (e.g. a court order or meeting statutory disclosures)
● where there is an overriding public interest such as to prevent harm against someone or to investigate a crime
● to defend against a complaint or legal claim
● to protect our name and reputation for example to provide our side of a story reported in the press
Who we share your information with
Cheshire East Council who fund our general advice service-for the purpose of quality checking and referrals to certain departments e.g. housing (with your permission).
Local food banks-when we make referrals to them.
Health and social care professionals who refer clients to us such as Macmillan nurses to let them know the progress of the cases they refer.
Third Parties, when acting on your behalf e.g. DWP, Jobcentre+, Local Authority departments
Our lawful basis for using your information
Article 6(f) - Legitimate interests
Where processing is not based on any public function. We have carried out a Legitimate Interests Assessment for this processing.
Article 6(e) - Public task
Where processing is based on official authority laid down by law or a statutory function. For example in relation to our consumer service functions.
Article 9(2)(f) - establishment, exercise or defence of legal claims
Where the processing relates to the establishment or defence of legal claims including legal rights including but not limited to those such as those in relation to benefits, debt, energy and housing. For criminal offence data the same provision is outlined in Data Protection Act 2018, Schedule 1, Part 3 (33).
Article 9(2)(g) - substantial public interest (statutory)
Where our advice, information or guidance relates to a statutory function, such as in our consumer service we rely on Data Protection Act 2018, Schedule 1, (6) ‘Statutory etc and government purposes’. This condition also applies to criminal offence data
Article 9(2)(g) - substantial public interest (counselling)
Where our advice, information or guidance relates to confidential wellbeing support. For example if supporting a client with issues relating to loneliness. The specific substantial public interest condition we rely on is in Data Protection Act 2018, Schedule 1, (17) ‘Counselling etc’. This condition also applies to special category data and criminal offence data.
How we use your data for research, feedback and statistics
This section covers how we use your data to carry out our research, feedback and statistical work.
National Citizens Advice covers their use of data for this purpose in their privacy notice.
How we collect your information
The national Citizens Advice charity and your local Citizens Advice operate a system called Casebook to keep your personal information safe. This means they’re a ‘joint data controller’ for your personal information that’s stored in our Casebook system.
What information we collect
We periodically collect feedback data regarding your experience of using our services.
What we use your information for
Improving our services.
Who we share your information with
Any feedback data shared with third parties is anonymised.
Our lawful basis for using your information
Article 6(f) - Legitimate interests
We have a legitimate interest to carry out statistical analysis and research using our client data. We have carried out a legitimate interest assessment for statistical processing, research and policy formation. We may also keep pseudonymised data for archival purposes.
Article 9(2)(j) Archiving, research and statistics
As per the A6 condition.
How we use your data when using our website
What information we collect
We use Google Analytics to monitor our website traffic. The information that we collect is as follows: -
Number of users
Session statistics
Approximate geolocation
Browser and device information
We also have enhanced data collection these are as follows: -
Page views
Scrolls
Outbound clicks
Site search
Video engagement
File downloads
Form interactions
What we use your information for
We use your information to help us improve our services.
Who we share your information with
We will share your information with your permission with external agencies and Local authorities.
Our lawful basis for using your information
Statistical purposes and research (including feedback)
Article 6(f) - Legitimate interests
We have a legitimate interest to carry out statistical analysis and research using our client data. We have carried out a legitimate interest assessment for statistical processing, research and policy formation. We may also keep pseudonymised data for archival purposes.
Article 9(2)(j) Archiving, research and statistics
As per the A6 condition.
How long we keep your data for
National Citizens Advice is responsible for managing any data in joint client case records. For more information please see their privacy notice.t
Personal details e.g. name, address, date of birth and contact details
To further your advice issue
6 years from closure of the case.
Special category data e.g. information about your health, race, religion, sexual orientation or Trade Union membership
Only in relation to your advice issue
6 years from closure of your file
Third party processors
Third party processors are other organisations that carry out data processing on our behalf. Third party processors don’t use data for their own purposes and we have agreements in line with data protection law.e
Seriun IT Services: Provides remote monitoring software for our IT Infrastructure and their data centre is in Europe
Anywhere SIM: Hosted phone system for incoming and outgoing landline calls and their data centre is in Europe
SCG Together: O2 SIMS provided by SCG for mobile phone communications and their data centre is in Europe
Apogee: Provides printer and copier support and their data centre is in Europe
Shire Pay Services: to process staff pay and their data centre is in Europe
Google Workspace: File and document creation/management services and their data centre is in Europe
Microsoft 365: File and document creation/management services and their data centre is in Europe
Your data protection rights
You have rights in relation to your personal data that we hold. Your rights include being able to request:
● Access to copies of your data
● Corrections are made to inaccurate data
● Deletion of your personal data
● Object to how we use your personal data
These rights are not absolute and may not apply in every circumstance. For more information about your rights you can visit the ICO website.
To make a data protection rights request you can do so by emailing admin@citizensadvicece.org.uk.
Raising a concern about how we use your information
If you are concerned about how we have handled your personal information please contact us at admin@citizensadvicece.org.uk.
You can also contact the national charity if you are unhappy with how we have used your personal data or wish to raise a concern about how a local office has handled your personal data. To do so you can email us at DPO@citizensadvice.org.uk
Contacting the Information Commissioner's Office (ICO)
You can also raise your concern with the Information Commissioner's Office which regulates data protection law in the UK. if you are unhappy with how we have used your personal information. They will normally expect you to have made a complaint to us directly in the first instance.
● Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
● Helpline number: 0303 123 1113