Salford Citizens Advice Privacy Policy
At Salford 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.
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 Salford Citizens Advice. Salford Citizens Advice 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
When we provide advice we either collect this data directly from you or receive it through a referral from a partner organisation.
We will collect this data in different ways depending on how you approach our service, including:
- 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 our adviceline
We also receive information 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.
What information we collect
To support your enquiry we collect information about you and your circumstances. You can choose which information you give us, but not providing certain information may limit the advice we can give you. This may include:
- 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
- details of any discrimination you face
If you contact us by phone we will 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.
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
We may also record any unacceptable behaviour from clients 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
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
If we operate a service with a partner whereby we share information with them to help us progress your case – we will ask you whether you are happy with this and show you a Data Collection Notice explaining more about the service. You can tell us if you do not want us to share information this way.
Who we share your information with
Referral partners
If we refer you to another organisation who we think will be able to provide you with more support we will ask your permission to make any such referral.
If we share any information with a party that has referred you to us we will ask your permission for this.
Funders
We share information 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.
Regulators
We are legally required to provide information to regulatory bodies in some circumstances. These include but are not limited to:
- Ofgem – the regulator for gas and electricity
- Ofcom – the regulator for the broadcasting, telecoms and postal industry
- the Financial Conduct Authority – the regulator for financial and banking services
- the Competition and Markets Authority
- the Food Standards Agency
- the Legal Services Board
- Trading Standards
Auditors
We share information 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 organisation.
Banks, credit reference agencies and creditors
We may also share your information 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
Employers or benefit providers
We may also contact your employer or benefit provider to understand more about your income, we will only do this with your permission.
Translation and interpretation services
We may share your information with a translation or interpretation service to enable us to communicate with clients who prefer communication in different languages.
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
We may contact you to conduct a survey about the impact of the advice we provide.
What information we collect
We may conduct a telephone interview with you and ask what specific impact our advice had on your health and wellbeing.
What we use your information for
Any information you provide to us will only be shared to funders and commissioners in a de-identified manner unless you give us permission to provide identifiable information.
Who we share your information with
Our lawful basis for using your information
| Purpose | Personal data
(UK GDPR Article 6 requirement) |
Special category and criminal offence data (UK GDPR Article 9 or 10 requirement) | Opt in/out required? |
|---|---|---|---|
| Advice, information and guidance provision | 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. |
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 (confidential counselling, advice or support) 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. NB: there may be locally managed services which could rely on alternative lawful conditions for processing. The IG Team can assist with considerations on a case by case basis. |
No, though clients may have the option of being unnamed |
| Witness support | Article 6(1)(f) – Legitimate interests
We have carried out a Legitimate Interests Assessment for this processing. |
Article 9(2)(g) – substantial public interest
Collection of SCD or criminal offence data is not usually necessary for this purpose but where it is we rely on the following provisions: For the purpose of administration of justice we rely on Data Protection Act 2018, Schedule 1, (7). Where we are providing emotional or wellbeing support we rely on is in Data Protection Act 2018, Schedule 1, (17) ‘Counselling etc’. This condition also applies to criminal offence data. |
No |
| Funder sharing | This will be dependent on the purpose the funder is processing data for and will need to be determined on a case by case basis.
Check with the funder and the relevant guidance. |
As per A.6 requirement | Case by case depending on purpose the funder is using the data for – check with funder |
| EDI monitoring | Article 6(1)(f) – Legitimate interests
We have a legitimate interest in processing EDI data to ensure we are promoting equity and diversity in our service. We have a full legitimate interest assessment for this processing. |
Article 9(2)(g) – substantial public interest
Processing of information relating to race or ethnicity, religious or philosophical beliefs, health (including disability), and sexual orientation for the purpose of enabling , promoting or maintaining equality of treatment. Specifically we rely on is in the Data Protection Act 2018, Schedule 1, (8) ‘equality of opportunity or treatment’. This substantial public interest category only applies to specific SCD criteria listed above and does not extend to criminal offence data. However criminal offence data is not processed for EDI monitoring. |
Yes, clients and witnesses should be given the option of providing this data including ‘prefer not to say’ options |
| Accessibility and reasonable adjustments | Article 6(1)(c) – Legal obligation
We have legal obligations in accordance with the Equality Act 2010. |
Article 9(2)(g) – substantial public interest
Specifically we rely on Data Protection Act 2018, Schedule 1, (6) ‘statutory and governmental purposes’ in accordance with the Equality Act 2010. This will only apply to special category data and will not extend to criminal offence data but such data is not processed for this purpose. |
Yes, clients can choose whether they provide this data or not |
| Statistical purposes and research (including feedback) | Article 6(1)(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. |
Generally not required unless it involves client contact in which case an opt in should be offered |
| Direct marketing of Citizens Advice Services | Article 6(1)(f) – Legitimate interests
We have a legitimate interest to carry out marketing of our services to clients provided the service is in their best interest and we have been transparent and have provided opt outs unless this involves direct electronic marketing. Article 6(1)(a) – Consent If direct electronic marketing is involved we must get the client’s consent with a genuinely free and fair choice. |
SCD should generally not be processed for this purpose. | Yes, or consent |
| Publication of client stories | Article 6(1)(a) – Consent
Where we seek to publish client stories in an identifiable format, we will always get client consent. Clients will always be given a genuinely free and fair choice. NB: If fully deidentified a lawful basis is not required for publication itself – care must be taken to ensure they cannot be re-identified. |
Article 8(a)(a) – Explicit Consent
As per the A6 condition. |
Consent should be used if clients are identifiable |
| Maintaining quality and standards | Article 6(1)(f) – Legitimate interests
We have a legitimate interest as an organisation to ensure that we are meeting appropriate quality and standards in our advice to clients. |
Article 9(2)(f) – establishment, exercise or defence of legal claims
Citizens Advice needs to be able to provide evidence that certain standards and quality measures are being met so as to defend against claims of malpractice or negligence. Article 9(2)(g) – substantial public interest Specifically we rely on is in Data Protection Act 2018, Schedule 1, (11) Protecting the public against dishonesty etc where we are carrying out functions to protect against:
|
No |
| Complaints | Article 6(1)(f) – Legitimate interests
We have a legitimate interest to investigate complaints and to implement lessons learned from them. |
Article 9(2)(f) – establishment, exercise or defence of legal claims
Citizens Advice needs to be able to investigate complaints to defend against claims of malpractice or negligence. Article 9(2)(g) – substantial public interest Specifically we rely on is in Data Protection Act 2018, Schedule 1, (11) Protecting the public against dishonesty etc where we are investigating complaints in order to protect against:
|
No |
| Legal claims | Article 6(1)(f) – Legitimate interests
We have a legitimate interest in defending our organisation against legal claims. |
Article 9(2)(f) – establishment, exercise or defence of legal claims
We need to be able to adequately defend our organisation against legal claims. |
No |
| Individual rights requests | Article 6(1)(c) – Legal obligation
We have a legal obligation to carry our individual rights requests in accordance with data protection law. |
Article 9(2)(g) – substantial public interest
Specifically we rely on is Data Protection Act 2018, Schedule 1 (6) ‘statutory and governmental purposes’ to comply with the UK GDPR and Data Protection Act 2018. |
No |
| Safeguarding | Article 6(1)(e) – Public task
The legislation covering safeguarding is the Care Act 2014 (England) and the Social Services and Wellbeing (Wales) Act 2014. These acts put duties on local authorities in relation to adult safeguarding and while they don’t apply to us directly as a charity, we acknowledge Citizens Advice may receive their funding or are contracted to deliver services on their behalf and therefore it’s essential that we understand our role in protecting adults at risk. |
Article 9(2)(g) – substantial public interest
This condition is met when the processing is necessary for the safeguarding of children and of individuals at risk in accordance with Data Protection Act 2018, Schedule 1, (18) ‘Safeguarding of children and of individuals at risk’ |
No |
| Fraud prevention | Article 6(1)(f) – Legitimate interests
We have a legitimate interest in defending against fraudulent activity. Article 6(1)(c) – Legal obligation In some circumstances there are legal obligations to disclose actual or suspected cases of fraud. |
Article 9(2)(g) – substantial public interest
We rely on three separate substantial public interest conditions as follows: Data Protection Act 2018, Schedule 1, (10): ‘preventing and detecting unlawful acts’ – where we process data to prevent or detect such activity Data Protection Act 2018, Schedule 1, (14) : ‘Preventing Fraud’ where we disclose fraudulent activity to anti-fraud organisations Data Protection Act 2018, Schedule 1, (15) : ‘Suspicion of terrorist financing or money laundering’ to comply with certain requirements under Terrorism Act 2000 and Proceeds of Crime Act 2002 |
No |
| Responding to an life threatening emergency | Article 6(1)(d) – Vital interests
Where a person’s life may be in danger |
Article 9(2)(g) – Vital interests
Where a person’s life may be in danger and use of special category data is necessary. Data Protection Act 2018, Schedule 1, (30): ‘Protecting individual’s vital interests’ also enables criminal offence data for this purpose. |
No – should only be used where a person cannot consent to this processing |
How we use your data for fundraising and donations
This section covers how we use your data to carry out our fundraising activities.
National Citizens Advice covers their use of data for fundraising in their privacy notice.
How we collect your information
We gather information about donors directly and through third parties. For example you may choose to donate directly through our website or through a third party such as Charities Aid Foundation, Charities Trust or other online donation platform.
If we run a fundraising campaign on social media platforms, we use a cookie (also known as a pixel) on a very small number of fundraising-related pages on our website to help us run the campaign effectively. See our cookie statement for more about how we use this technology.
What information we collect
- your contact details and identifiers such as name, address, email address, postal address etc
- financial data, such as your bank or card details
- Contact preferences and permissions
- Your interests and reasons for donating
- Details about your donations
What we use your information for
We use your information in order to:
- Process donations you have made to us
- Stay in contact and ask about future donations
- Ensuring compliance and preventing fraud
Who we share your information with
We will not share your information outside of our service unless we are required to do so to:
- to assist police enquiries
- legally obliged to do so
- to prevent fraud
- to protect your safety or the safety of others
This includes providing tax and gift aid information to HMRC.
With your permission Citizens Advice may share your details with local Citizens Advice offices to allow them to contact you about donations and fundraising.
Activity |
Our lawful basis for collecting personal data |
Our lawful basis for collecting special category or criminal convictions data |
| Making contact about fundraising and donations | Legitimate interests – we have a legitimate interest to raise funds for the organisation, you will have the right to opt out of any contact
Consent – where we are carrying out electronic marketing we will gather consent where necessary to comply with marketing regulations |
N/A |
| Processing donations | Contract – where you have entered a donation contract with us
Legitimate interest – we have a legitimate interest to raise funds for the organisation Legal obligations where we are legally obliged to process personal data. For example, providing tax and gift aid information to HMRC in the UK |
N/A |
How we use your data when applying to work or volunteer
How we collect your information
We collect information about you through your job or volunteer application form. These are completed online via our website.
Depending on the role we may also collect information through a Disclosure and Barring Service (DBS) check. You will be informed if such a check will be required for the role at application stage.
What information we collect
We’ll collect personal information such as name, address, telephone number and email address, previous job history and experience, qualifications, and any support needs you may have.
We’ll also ask for diversity information like your gender, ethnicity and sexual orientation. You don’t have to tell us this.
Where it’s needed for the role, we might contact the DBS for a criminal record check. Once the DBS check is completed and you’ve received your certificate, we’d expect you to share this information with us as part of the background check process.
We may also ask for:
- references for your previous and current work
- proof of your right to work in the UK, like a valid UK passport or visa
- your national insurance number and P45
- your bank details, so we can pay you
- details of your student loan if you’re paying one back
What we use your information for
The main reasons we ask for your personal information are to:
- check you’ve got the right skills for a role when you apply
- arrange an interview
- contact you to tell you the result of your application
- do checks when we make an offer, for example contacting your references or checking your right to work in the UK
- send you an offer letter or contract
We’ll treat any diversity information you give us as strictly confidential. We’ll anonymise this information and only use it to look at trends. This means we won’t look at your information individually or compare it to other people and we won’t use it as part of the recruitment selection process.
Who we share your information with
If you accept an offer to work for us we’ll:
- get your permission to share your information with your references
We won’t usually share your personal information with anyone else in a way that could identify you. In some rare situations we have to share your information, for example if:
- we’re investigating a safeguarding issue
- the police ask for the information to help them investigate a crime
- a court orders us to share the information
We sometimes share anonymous statistics with organisations we trust so they can analyse the information.
Our lawful basis for using your information
| Activity | Our lawful basis for collecting personal data | Our lawful basis for collecting special category or criminal convictions data |
| Recruitment of staff | Legitimate interests – for assessing suitability of candidates
Contract – for entering an employment contract Legal obligation – for carrying out legal checks as part of employment screening |
Employment, social security, and social protection – for complying with legal requirements as an employer including DBS checks |
| Recruitment of volunteers | Legitimate interests – for assessing suitability of candidates
Legal obligation – for carrying out legal checks as part of employment screening |
Employment, social security, and social protection – carrying out DBS checks |
The ICO has more information on employment processing.]
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