Privacy Policy

This Privacy Notice explains how Harrow Citizens Advice Bureau Services Limited also known as Citizens Advice Harrow (“CAH”) (“we”, “our” or “us”) collects, uses, and discloses your personal data, and your rights in relation to the personal data it holds.

CAH is the data controller of your personal data and is subject to the Data Protection Act 2018 and the United Kingdom General Data Protection Regulation. Our Privacy Officer can be contacted at the following email address:

Email: privacy.officer@citizensadviceharrow.org.uk
Tel: 07903 459 518

We may amend this Privacy Notice from time to time, to reflect any changes in the way that we process your personal data. This Privacy Notice supersedes any previous version of this notice with which you may have been provided, or had sight of, before the date stated below, as well as anything to the contrary contained in any agreement with us.

Your Rights

You have the following rights:

  • To obtain access to, and copies of, the personal data that we hold about you.
  • To require that we cease processing your personal data if the processing is causing you damage or distress.
  • To require us not to send you marketing communications.
  • To require us to erase your personal data.
  • To require us to restrict our data processing activities.
  • To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller.
  • To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights under data protection legislation at www.ico.org.uk

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer.

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner (www.ico.org.uk).

How we collect your data

We may collect your personal data in a number of ways, for example:

  • face to face – for example by discussing your situation with an advisor
  • completing a form – this could be a digital form or paper form
  • over the phone – for example by calling Adviceline or a local office directly
  • email
  • webchat
  • from partner organisations through referral mechanisms. Where you are referred to us, you should be advised that you are being referred as well as what information we will be provided by our referral partners
  • from publicly available sources, or from third parties, where this is required to assist you

What information we collect

We may collect the following categories of personal data about you:

  • your name – you can ask to remain unnamed but this may limit the advice we are able to provide
  • contact details such as your address, phone number and email address
  • profile information such as your date of birth and whether you have any accessibility requirements

We will also collect any information about your issue which could help us provide you with advice which can include:

  • information about your finances – for example your income, expenditure, debts, benefits or pension
  • credit reports – we may get copies of your credit history with your permission
  • details of the products or services you are having issues with
  • details of your housing such as your rent, mortgage and housing conditions
  • information about your health or disability  where you have consented and this is relevant to the services we provide to you. For example, if you are a Macmillan client we will ask for details of your cancer diagnosis and prognosis and contact details of your Clinical Nurse Specialist or Consultant
  • details of any discrimination you face

If you contact us by phone we may  also record the phone call for training and monitoring purposes.

You may also be asked to provide demographic information at your advice session. This will not affect the advice you receive and will be used to understand more about our service. For more information see the section on statistical processing.

We may also gather information about you if you aren’t one of our clients. We will do this if it is relevant to provide a client with advice. For example, to assist a client with a debt assessment we will need relevant financial information about members of their household.

What we use your information for

We use the information you give us to:

  • provide you with advice, guidance and information
  • stay in touch with you about the advice we are providing
  • help with applications such as a debt recovery order or benefit claim
  • training our staff and volunteers
  • assess the quality of our advice
  • investigate complaints or claims
  • get feedback from you about our services
  • help us improve our services
  • address the root causes of the issue you are experiencing
  • share stories about your experience with Citizens Advice, with your permission
  • make sure we are delivering our services in an equitable way and not excluding any groups from our services

We may also record any unacceptable behaviour from you if we deem this to cause disruption to our service or threaten the wellbeing of our staff, volunteers or any other person.

In some circumstances we may also use your information to carry out legal obligations, including for:

  • safeguarding
  • fraud prevention
  • regulatory compliance

Who we share your information with

We may share your personal data:

  • with banks or creditors to help get information to assist in our advice. We will only do this with your permission or where we are legally required to do so. Information we share will be used for purposes including:
    • getting a credit report to assist with financial enquiries
    • understanding more about your income and expenditure
    • understanding more about the debts you owe
  • with your employer or benefit provider to understand more about your income, we will only do this with your permission
  • with a translation or interpretation service where this is necessary to enable us to communicate with you.
  • if we make a referral, for example to Foodbank, if you need a food voucher
  • another organisation to whom we have referred you who we think will be able to provide you with more support. We will ask your permission to make any such referral
  • with our funders in order to demonstrate that we are meeting the funding requirements. Information will normally only be shared in a de-identified manner unless you give us your permission to do so or we need to in order to investigate a quality issue, complaint or claim
  • with regulatory bodies when required to do so
  • with our internal and external auditors to allow them to carry out audits to ensure that we are complying with our legal obligations and standards of best practice in how we run the charity

The lawful basis for using your information

Activity
Lawful basis for collecting personal data
Lawful basis for collecting
special category or criminal convictions data
General advice provision (unless listed below) Legitimate interests – we have a legitimate interest to provide advice to our clients Establishment, exercise or defence of legal claims –  where we are helping clients establish their legal rights

Substantial public interest (provision of confidential counselling, advice or support) – where we are providing advice to clients which doesn’t relate to their legal rights
Consumer service and energy advice Public task – we have a statutory obligation to provide consumer and energy advice Substantial public interest (statutory obligation) – we have a statutory obligation to provide consumer and energy advice
Debt advice Public task – we have a public task through our funder the Money and Pensions Service to deliver pension advice Establishment, exercise or defence of legal claims – where we are helping clients establish their legal pension rights
Debt relief orders Public task – we have a public task through our funder the Money and Pensions Service to assist with debt relief orders Establishment, exercise or defence of legal claims – where we are helping clients establish their legal pension rights
Accessibility requirements Legal obligation – we have legal obligations in accordance with the equalities legislation Substantial public interest (statutory obligation) – obligations under equalities legislation
Marketing new advice services Legitimate interests – we have a legitimate interest in promoting advice services which could benefit our clients

Consent – where marketing rules require consent to do so

 N/A
Maintaining quality and standards Legitimate interests – we have a legitimate interest in ensuring that our service is run properly and that standards are maintained Establishment, exercise or defence of legal claims

Substantial public interest (protecting the public against dishonesty etc.) – where we are carrying out functions to protect against:
– dishonesty, malpractice or other seriously improper conduct
– unfitness or incompetence
– mismanagement in administration
Safeguarding Public task – in complying with safeguarding obligations Substantial public interest (safeguarding of children and of individuals at risk)
Fraud prevention Legitimate interests – we have a legitimate interest in defending against fraudulent activity

Legal obligation – in some circumstances there are legal obligations to disclose actual or suspected cases of fraud

 Substantial public interest (preventing and detecting unlawful acts, preventing fraud, suspicion of terrorist financing or money laundering)

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. We use the following third-party processors:

Processor name
Activities
Vijay Akshar & Company Processes charity grants
Moocow Media Ltd Maintains our website which includes the on-line enquiry forms and application forms
Aspira Cloud Ltd Provides IT support

How long we keep your data for

We may retain your personal data for a period of six years after the termination of our relationship with you.