How we use your information

At Citizens Advice Cheshire West we are committed to protecting and respecting your privacy.  This policy has been devised to help you understand what data we collect, why we collect it and what we do with it.  It applies to the information we collect about:

    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 - Meadow Court, Meadow Street, Northwich, Cheshire CW9 8WS

    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 affects 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 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

    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.

    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.

    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.  This information is always anonymised - you can’t be identified. See Anonymised data

    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.

    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

    Meadow Court

    Meadow Street

    Northwich

    CW9 5FP

    Or by email:  [email protected]

    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 to help solve your problem or to monitor the quality of our services.

    Organisations we share your data with must store and use your data in line with data protection law.

    Sharing information to solve your problem

    If you ask us to act on your behalf we might need to share some of your information with other organisations - we'll always tell you when we do this. For example if we contact your creditors about your debts, we might need to share your name, address and financial details with them.

    If we refer you to another organisation for more advice, we might share information about your problem with them so they can help you more quickly.

     

    Monitoring our quality of service

    With your permission, we'll share your contact details with our trusted research partner so they can contact you for feedback on your experience with us. We use different research partners depending on how you accessed our services.

    Where you got advice

    Research partner

    Citizens Advice Cheshire West office

    Maru/edr

    If you use the consumer service

    We share your records with Ofgem, Ofcom, the Financial Conduct Authority, Competition and Markets Authority or Trading Standards, to help their work to protect consumers. You can ask us to anonymise your records - this means you can't be identified.

    If you don't want your information shared in this way, tell the adviser you speak to on the phone or make it clear in your online advice request form.

    Your information is sent securely to our partners via a Secure Post Office system provided by US firm Datamotion.

     

    If we're concerned about yours 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.

     

    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.

    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.

    If you contact us for Web chat or email advice

    In most cases, as well as logging your email advice request form and webchat transcripts in our case management systems, copies are also stored in an online system run by our trusted partner Agilisys. It's stored for 3 months before being deleted.

    Agilisys keep anonymised statistics on webchat data in an archive so they can track webchat usage and performance. This data doesn't contain your personal information.

    Agilisys store their data securely within the European Economic Area (EEA) in line with data protection law.

    Requests for advice from the consumer service via the online webform are stored on a secure mail system run by Datamotion for 30 days.

    Our advisers work for Citizens Advice Cheshire West and use Citizens Advice Cheshire West email addresses.  They’ll need to move your information out of the national Citizens Advice secure system if they email advice to you.

    If you want a copy of your web chat you’ll need to ask an adviser to email it to you during the chat.  By doing this you give the adviser permission to email the web chat to you, including any personal or sensitive information you’ve given.

    If web chat isn’t available we’ll sometimes give you the option to ask an adviser to contact you using email.  You’ll need to fill out a webform to do this. By ticking the consent box on the webform you give the adviser permission to include your personal or sensitive information in their email to you.  They could also include your personal or sensitive information in any replies to further emails from you.

    Read more about how we guard your privacy on our website and our use of cookies.

    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.

    What information we ask for

    We only record information that will help us give you the right guidance about your pension options.

    During the booking stage we ask for your name, date of birth, address and telephone number.

    During your Pension Wise appointment, we'll ask you about your pension pots, financial and family situation, and your health.

    How we use your information

    The main reason we need your information is to give you guidance about your pension options. Your information will be used to produce a document which summarises what was discussed in the appointment - you can take this away with you or have it sent to you by email.

    We'll 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

    Understanding people's pension queries

    We use some information to create statistics about who we're helping and what pension queries are the most common. This information is always anonymised - you can't be identified.

    This helps us improve our service. We might share these statistics with funders, regulators, government departments and publicly on our blogs, reports, social media and press releases.

    When we share your information externally

    Sometimes we share your personal information with other organisations - we only do this to help you with your query, or to monitor the quality of our services. We'll get your permission before doing this.

    Organisations we share your data with must store and use it in line with data protection law - they can't pass it on or sell it without your permission.

    Who we share your information with

    We'll share some of your personal data with the Department for Work and Pensions (DWP). This includes your name, email, address, age and appointment date. Details you discuss during the appointment won't be shared, unless we're investigating a complaint.

    If you ask for a digital version of your Pension Wise appointment summary, we'll share your name and email address with the Government Digital Service so they can send you a copy.

    If you've given us permission, we'll share your contact details with our research partner, Ipsos Mori. They might ask you to take part in some research about your experience of our service or what actions you took afterwards.



    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

    Meadow Court

    Meadow Street

    Northwich

    CW9 5FP

    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

    Meadow Court

    Meadow Street

    Northwich

    CW9 5FP

    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).

    https://ico.org.uk/concerns/handling/