Citizens Advice Lincoln & Lindsey Privacy Policy

At Citizens Advice Lincoln & Lindsey, 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 Lincoln & Lindsey. Citizens Advice Lincoln & Lindsey 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

To find out what information we ask for, see our national Citizens Advice privacy policy

What information we collect

 To find out what information we ask for, see our national Citizens Advice privacy policy

What we use your information for

To find out how we use your information, see our national Citizens Advice privacy policy’

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

When you give us authority to act on your behalf, for example to help you with a Universal Credit claim, we’ll need to share information with that third party.

We will only share your information if you give permission for us to do so, other than in exceptional circumstances including:

• To comply with the law (legal obligation) - for example, if a court orders us to share the information

• To protect someone’s life (vital interests) - for example, sharing information with a paramedic if a client is unwell

• To defend our legal rights - for example, to resolve a complaint that we gave the wrong advice

Our lawful basis for using your information

Purpose: 

Advice, information and guidance provision 

Personal data (UK GDPR Article 6 requirement): 

Article 6(1)(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(1)(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.

Special category and criminal offence data (UK GDPR Article 9 or 10 requirement):

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

Opt in/out required? 

No, though clients may have the option of being unnamed 

How Citizens Advice Lincoln & Lindsey store your information 

We store your information on a secure, cloud based management system. In some circumstances we hold paper files, if information is kept in a paper file it is kept locked at all times. Other than Casebook, management information systems we use include;

Cloud Based System - Google Drive

Consumer Data Warehouse CIVICA (Flare21)

East Midlands Money Advice portal

How Citizens Advice share your information

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, if relevant

Monitor the quality of our services

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

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 use your data when applying to work or volunteer

How we collect your information

We use indeed to advertise our paid roles and an online form to capture contact details for volunteers. We shortlist based on CV’s and covering letters uploaded to indeed by candidates. We then invite for interview via indeed

Volunteers complete an online form on our website  and capture contact details for volunteers. Volunteers  are sent application forms to complete and then invited for an interview

What information we collect

We shortlist based on CV’s and covering letters uploaded to indeed by candidates and a response to key screening questions.

Volunteers complete an online form with their contact details and the role they are interested in. We send applications form which request contact details, previous employment information , availability and reasons for volunteering.

What we use your information for

For paid roles we use your CV, covering letter and responses to screening questions to aid with our shortlisting processes and to invite for an interview.

For volunteering we use the contact details provided on the online form to make contact and arrange for an application to be sent. We use the completed application form to determine if you're suitable to be invited to interview. 

Who we share your information with

We share information with our HR department to request references and the hiring managers.

Our lawful basis for using your information

Personal data - (UK GDPR Article 6 requirement)

Article 6(1)(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(1)(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.

How we use your data when using our website

What information we collect

We collect your name and contact details on our self referral form which is accessed from our website.

How we collect your information

We use an on-line form to collect your name and contact details.

What we use your information for

We use your contact  information to allow our admin staff to contact you to make an appointment.

Who we share your information with

We do not share your information with any third party unless we have your permission to do so.

Our lawful basis for using your information

Purpose - Advice, information and guidance provision

Personal data - (UK GDPR Article 6 requirement)

Article 6(1)(f) - Legitimate interests

Where processing is not based on any public function. We have carried out a Legitimate Interests Assessment for this processing.

How we use cookies on our website

Our cookies policies can be found here

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.

Data:

Client record and Case record (including all attachments)

Purpose:

Advice provision

In order to provide our advice services to new clients and returning clients it is necessary to retain the categories of information we collect or create as part of their interactions with us. 

Although the accuracy of information such as their contact details will be frequently updated, cases may be resumed when clients return after a long time or cases may be relevant to new issues raised. 

Retention:

6 years from last substantive action such as updating a case note or debt assessment 

Data: 

Recruitment Information

Purpose: 

Application forms/interview notes for paid and volunteer staff (including unsuccessful applications) are help on file for future recruitment opportunities 

Retention:

12 months

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.

Currently we have none.

Contact Citizens Advice Lincoln & Lindsey about your information

If you have any questions about how your information is collected or used, you can

Contact: Jenny Barnett

Telephone: 01427 810914, Monday to Friday 9am to 5pm
Email: jenny.barnett@citizensadvicelincolandlindsey.org.uk

You can contact us to:

• find out what personal information we hold about you

• correct your information if it’s wrong, out of date or incomplete

• request we delete your information

• ask us to limit what we do with your data - for example, ask us not to share it if you haven’t asked us already

• ask us to give you a copy of the data we hold in a format you can use to transfer it to another service

• ask us stop using your information

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 jenny.barnett@citizensadvicelincolandlindsey.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 jenny.barnett@citizensadvicelincolandlindsey.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.

• Visit the ICO website.

• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

• Helpline number: 0303 123 1113