Prepared 06/06/2018

reviewed 18/10/19, 21/12/21, 15/07/22, 30/10/23

Citizens Advice Canterbury District Privacy Policy

At 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.

We only ask for the information we need. We always let you decide what you’re comfortable telling us, explain why we need it and treat it as confidential.

When we record and use your personal information we:

only access it when we have a good reason
only share what is necessary and relevant
don’t sell it to anyone

At times we might use or share your information without your permission. If we do, we’ll always make sure 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 - for example, if a court orders us to share information. This is called ‘legal obligation’
to protect someone’s life - for example, sharing information with a paramedic if a client was unwell at our office. This is called ‘vital interests’
to carry out our legitimate aims and goals as a charity - for example, to create statistics for our national research. This is called ‘legitimate interests’

for us to carry out a task where we’re meeting the aims of a public body in the public interest - for example, delivering a government or local authority service. This is called ‘public task’
to carry out a contract we have with you - for example, if you’re an employee we might need to store your bank details so we can pay you. This is called ‘contract’

to defend our legal rights - for example, sharing information with our legal advisors if there was a complaint that we gave the wrong advice

We handle and store your personal information in line with the law - including the General Data Protection Regulation and the Data Protection Act 2018.

You can check the National Citizens Advice Privacy Policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information for how we handle most of your personal information.

This page covers how we, as your local charity, handle your information locally in our offices. This is in addition to the processes described in the main Citizens Advice policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information for how we handle most of your personal information.

How Citizens Advice Canterbury District collect your data

We will get your permission for collecting Special Category information by signing our revised 'client permission and consent form' if you come in face to face or obtain verbal consent over the phone. We will ask you to tick a box to give consent if advised via e-mail or webchat.

In addition to the general rules covered by the main Citizens Advice policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

If you require advice from our Macmillan Welfare Benefits Service

We will collect your data over the telephone, during face to face interviews, from e-mails you send us, from secure emails or referral forms sent to us by other agencies like the local hospital trust.

to comply with the law - for example, if a court orders us to share information. This is called ‘legal obligation’
to protect someone’s life - for example, sharing information with a paramedic if a client was unwell at our office. This is called ‘vital interests’
to carry out our legitimate aims and goals as a charity - for example, to obtain feedback for Macmillan to monitor the quality of our service to you This is called ‘legitimate interests’
to defend our legal rights - for example, sharing information with our legal advisors if there was a complaint that we gave the wrong advice

Special Category Information:

We will get your explicit consent for processing Special Category information (e.g. about your health, such as obtaining details of your medical condition in relation to cancer from the NHS to process your benefit claim) by asking you to sign our revised 'client permission and consent form' if you come in face to face or by obtaining verbal consent over the phone.

If you apply for a job or to be a volunteer including a trustee

We will collect your data through a paper or e-mailed application form or gather information from the on-line application form provided by Citizens Advice if you have applied via the national Citizens Advice public website.

to comply with the law - for example, if a court orders us to share information. This is called ‘legal obligation’
to protect someone’s life - for example, sharing information with a paramedic if a volunteer or staff member was unwell at our office. This is called ‘vital interests’
to carry out our legitimate aims and goals as a charity or a company- for example, to enter Trustee’s details with the Charity Commission’s Register. This is called ‘legitimate interests’
for us to carry out a task where we’re meeting the aims of a public body in the public interest - for example, delivering a government or local authority service. This is called ‘public task’
to carry out a contract we have with you - for example, if you’re an employee we might need to store your bank details so we can pay you. This is called ‘contract’

to defend our legal rights - for example, sharing staff information with our legal advisors in event of an employment tribunal

Special Category information will be processed on the basis of explicit consent which may be written or verbal.

If you are a Friend of Canterbury District Citizens Advice we will ask you to complete an application form either on paper or sent by email. We will ask you to give explicit consent in writing or by e-mail for us to store and use this data.

to comply with the law - for example, if a court orders us to share information. This is called ‘legal obligation’
to protect someone’s life - for example, sharing information with a paramedic if someone was unwell at one of our events. This is called ‘vital interests’
to carry out our legitimate aims and goals as a charity - for example, to claim gift aid from HMRC.. This is called ‘legitimate interests’
to defend our legal rights - for example, sharing information with our legal advisors if there was a tax investigation

If you are referred for our Money and Mental Health Advice Service

We will collect your data over the telephone, during face to face interviews, from emails you send us, from secure emails or referral forms sent to us by other agencies like Citizens Advice NW Kent or a Mental Health Professional.

to comply with the law - for example, if a court orders us to share information. This is called ‘legal obligation’
to protect someone’s life - for example, sharing information with a paramedic if a client was unwell at our office. This is called ‘vital interests’
to carry out our legitimate aims and goals as a charity - for example, to obtain feedback for Macmillan to monitor the quality of our service to you This is called ‘legitimate interests’
to defend our legal rights - for example, sharing information with our legal advisors if there was a complaint that we gave the wrong advice

Special Category Information:

We will get your explicit consent for processing Special Category information (e.g. about your health, such as obtaining details of your medical condition from the NHS or Social Services to process your benefit claim or to give debt advice) by asking you to sign our revised 'client permission and consent form' if you come in face to face or by obtaining verbal consent over the phone.

What Citizens Advice Canterbury District ask for

For advice clients, including for our Macmillan and Money and Mental Health Advice Service To find out what information we ask for, see our national Citizens Advice privacy policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

For our Macmillan clients, in addition to the information asked of General Advice clients, we will ask for details of your cancer diagnosis and prognosis, and contact details of your Clinical Nurse Specialist or Consultant.

If you are referred to the Pro Bono Family Legal Rota run by Canterbury District Citizens Advice in addition to the general information relevant to your case we will ask for the name and address of any third party relevant to your case.

For staff and volunteer applications we ask for personal details such as name and address and some special category data such as gender, ethnicity, nationality, religion and sexual orientation

For Friends of Canterbury District Citizens Advice we will ask details such as your name, address, e-mail, telephone number, bank details and tax status.

For our Money and Mental Health Advice Service in addition to the information asked of General Advice clients, we will ask for details of your Mental Health condition and how it affects your day to day living.

How Citizens Advice Canterbury District use your information

To find out how we use your information, see our national Citizens Advice privacy policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

For Macmillan Welfare Benefits clients in addition to the general advice provisions- see our national Citizens Advice privacy policy https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

We may share your data with Macmillan Cancer Support if we refer you for a Macmillan Grant, or if they need to address a complaint from you about our service, and we may share anonymous data for research and policy issues. We will rely on our ‘legitimate interest’ in delivering benefits advice as a charity funded by Macmillan to do this. If we use Special Category information, e.g. about your health we will do this on the basis of explicit consent.

If you are referred to the Pro Bono Family Legal Rota run by Canterbury District Citizens Advice we will send a copy of your case details, including contact details to the Pro Bono solicitors firm or barristers chambers who will be delivering the advice. They will use this to prepare for your case and to check no conflict of interest arises. We will get your explicit consent to share these details. Special category information will be processed on the basis of explicit consent.

If you apply to be a volunteer or employee we will use your information to assess and select you for voluntary/paid positions (whichever is relevant), for training purposes, to monitor the equality characteristics of our workforce or to process wage, pension, tax and National Insurance payments (where relevant). Special category information will be processed on the basis of consent.

If you are a Friend of Canterbury District Citizens Advice we will use your information to contact you to give you news about Canterbury District Citizens Advice and about our fundraising events. We will not sell your information to other organisations. We will use it to collect gift aid from HMRC if you have agreed to this.

Working on your behalf

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, for example, with the Jobcentre.

How Citizens Advice Canterbury District store your information

To find out how we store your information, see https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

Locally we may store information on paper (e.g. on client permission and consent forms or copies of your paperwork), in our g-mail (encrypted) accounts, in the ‘Refernet’ on-line referral system if you have been referred to or from another local organisation via this system, or on the CLOCK Participant Administrative System if referred by the Christchurch Legal Companions Scheme CLOCK. Limited data is also stored on computers within the office.

How Citizens Advice Canterbury District share your information

.To find out how we share your information, see https://www.citizensadvice.org.uk/about-us/about-us1/citizens-advice-privacy-policy/your-information

For Macmillan or Pro Bono Legal Rota clients If we share information with Macmillan under the Macmillan Welfare Benefits Service or with local pro bono solicitors for the legal rota we will share any personally identifiable data via encrypted word attachments to email. We will get your explicit consent either written or verbal before we share personal data with these organisations. We will obtain this consent before we share the data and it will usually be during the course of your advice interview.

Contact Citizens Advice Canterbury District about your information

If you have any questions about how your information is collected or used, you can contact our office.

The Chief Officer

Telephone: 01227 364725, open Monday to Friday 9am-5pm

Email: distman@canterburycab.cabnet.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

Who’s responsible for looking after your personal 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.

Each local Citizens Advice is an independent charity, and a member of the national Citizens Advice charity. The Citizens Advice membership agreement also requires that the use of your information complies with data protection law.

You can find out more about your data rights on the Information Commissioner’s website.

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