Data Protection and Privacy

Citizens Advice Westminster complies with the Data Protection Act 2018 (the “Act”). For the purposes of the Act, Citizens Advice Westminster is the Data Controller.

Citizens Advice Westminster is committed to safeguarding your privacy, while providing a high quality of service. Citizens Advice Westminster will treat your personal information as confidential and your details will not be given or sold to anyone.

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.

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 Westminster. Citizens Advice Westminster 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.

When we handle and store our clients’ personal information we follow the law, including the Data Protection Act 1998.

When we ask you for personal information we will:

explain why we need it
only ask for what we need
treat it as confidential

When we record and use your personal information we will:

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 organisations

When we share your personal information with another organisation we will:

ensure that this is only done with your permission, or if we’re required to do so by law
follow the ICO Data Sharing Code of Practice to ensure the other organisation treats your information with the same level of care that we do

All staff and volunteers who handle personal information are given training and we take it very seriously if someone fails to use or protect it properly.

If you’re unhappy with how we record and use your information you should follow our complaints procedure. Full details of the procedure are available on request.

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.

How we use your data for advice

This section covers how we use your data to provide you with advice.

First and foremost your information will be used to provide you with advice. We also use information in a way that doesn’t directly identify you, to understand how different problems are affecting society and to take action to tackle these problems. As this is used for research it is kept separate from your case record.

Where you have given us your permission and contact details, we, or in some instances a trusted research partner, may contact you to ask you for feedback on the service you received and your overall experience of Citizens Advice.

How we collect your information

We collect information in a number of ways, including:

When you contact us directly for advice by telephone, email, webform, video call or in person.
When you complete forms, surveys, feedback questionnaires or other documents provided by us.
When another organisation refers you to our service, where it is appropriate and lawful to do so.
When you provide documents or evidence to support your case, such as letters, bills, benefit decisions, tenancy agreements or financial information.
When you communicate with us during the course of your case, including updates, correspondence and supporting information.

We only collect information that is relevant to the advice, support or service we are providing.

What information we collect

The information we collect will depend on the service you receive and the nature of your enquiry. This may include:

Personal details such as your name, date of birth, address, postcode, email address and telephone number.
Information about your household and personal circumstances, including employment, housing, financial or family circumstances where relevant to your case.
Details of the issue or problem you need help with and any action taken to resolve it.
Equality and diversity information, where you choose to provide it, such as age, ethnicity, disability, gender or other protected characteristics.
Documents and evidence you provide to support your case.
Feedback about the service you have received.
Information about your interactions with us, including appointments, referrals and communications.

In some cases, we may collect special category information (such as information about your health, disability, ethnicity or other sensitive personal information) where this is necessary to provide advice, support your case, or meet our legal obligations.

What we use your information for

We use your information to:

Provide advice, information, advocacy and support tailored to your circumstances.
Communicate with you about your case, appointments and services.
Maintain accurate records of the advice and support we provide.
Make referrals or work with other organisations where you have given your consent, or where we are otherwise permitted or required by law to do so.
Monitor, evaluate and improve the quality of our services.
Meet our contractual, legal, regulatory and funding requirements.
Produce anonymised statistics and reports to better understand the issues affecting our community and to help influence policy and improve services.
Conduct client satisfaction surveys and research, where you have agreed to be contacted.
Safeguard clients, staff, volunteers and members of the public where there is a legal or safeguarding obligation to do so.

Wherever possible, information used for statistical analysis, reporting and research is anonymised so that individuals cannot be identified.

Our confidentiality policy

At Citizens Advice Westminster 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

We will generally not share information without your permission, unless required to do so by law or in some very limited situations, like to protect you or someone else from serious harm. If a particular service involves sharing your data without your permission, we will always let you know upfront that it isn’t confidential.

Our lawful basis for using your information

We’ll use the information because we have a ‘legitimate interest’ to do so for the purpose of providing you with advice and carrying out research. You can decide exactly what information you are happy to tell us.

Where we will store your data

The record of your case will be stored securely in an electronic case management system used jointly by all of the Citizens Advice service. We are responsible for keeping it safe. As part of solving your problem, we might make written notes, download copies of your case or send e-mails containing your information. We will make sure any information is stored securely and only accessed when there’s a good reason by staff and volunteers by the Citizens Advice service.

If you are a money advice client being seen by our project funded through Debt Free Advice, your case record will be stored electronically on a secure case management system used by the Debt Free London service. A copy of their privacy policy can be accessed via their website.

National Citizens Advice is responsible for managing any data in joint client case records. For more information please see their privacy notice.

Email security and website forms

When you provide Citizens Advice Westminster with personal information, for example, when using the feedback form or referral form, we take steps to ensure that your information is processed securely.

Citizens Advice Westminster makes every effort to ensure the security and integrity of emails on our systems. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information after we’ve received it, Citizens Advice Westminster cannot ensure or guarantee the security of information when it is being transmitted.

Note: This privacy policy section only covers this website westminstercab.org.uk and it’s subdomains; other websites linked from this website are not covered by this policy. Once you have accessed another website via one of our links you will be subject to the security and privacy policy of that site.

How we use your data when applying to work or volunteer

This section explains how we collect, use and store your personal information when you apply for a paid role or volunteer opportunity with Citizens Advice Westminster.

What information we collect

As part of the recruitment process, we may collect:

Your contact details, including your name, address, email address and telephone number.
Information contained within your application form, CV, covering letter and any supporting documents you provide.
Equality, diversity and inclusion information, where you choose to provide it.
Details of your qualifications, skills, employment history and experience.
References and background check information, where applicable.
Information required to assess your suitability for the role.

What we use your information for

We use your information to:

Assess your application and suitability for employment or volunteering opportunities.
Communicate with you throughout the recruitment and selection process.
Arrange interviews, assessments and induction activities.
Carry out reference checks and other pre-engagement checks where required.
Meet our legal, regulatory and safeguarding obligations.
Monitor the fairness and effectiveness of our recruitment processes through the use of anonymised statistical information.

If your application is unsuccessful

Your information will only be accessible to staff involved in the recruitment process and will be stored securely.

We will normally retain unsuccessful application records for up to 12 months from the date of the recruitment decision, after which they will be securely deleted unless we are required to retain them for legal or regulatory purposes.

If you join us as an employee or volunteer

If your application is successful, we will create a personnel or volunteer record and retain information necessary to support your role with us. This may include:

Emergency contact or next of kin details.
Training and development records.
Supervision, support and performance-related records.
Role-related correspondence and administrative information.
Records required to meet legal, safeguarding, health and safety, insurance or regulatory obligations.

We may use this information to:

Manage and support your involvement with Citizens Advice Westminster.
Contact you regarding your role, training, meetings and organisational updates.
Make reasonable adjustments and improve accessibility where required.
Monitor service quality and compliance.
Investigate concerns, complaints or disciplinary matters where necessary.
Meet our legal, contractual and regulatory obligations.

Your rights

You have rights under UK data protection law, including the right to:

Access the personal information we hold about you.
Request that inaccurate information is corrected.
Request that the processing of your information is restricted in certain circumstances.
Request deletion of your information where applicable.
Object to certain types of processing.

Further information about your rights is available from the Information Commissioner’s Office at www.ico.org.uk

Contact us

If you have any questions about how we use your personal information for recruitment, employment or volunteering purposes, please contact:

volunteering@westminstercab.org.uk (for volunteering enquiries)

recruitment@westminstercab.org.uk (for employment enquiries).

How we use your data when using our website

What information we collect

When you visit our website, we may collect:

Technical information about your visit, such as your IP address, browser type, device information and pages visited.
Information submitted through online forms, including contact details and details of your enquiry.
Information you provide when requesting advice, making a referral, applying for a role or volunteer opportunity, signing up for updates, or providing feedback.
Information collected through cookies and similar technologies. Further information can be found in our Cookie Policy.

How we collect your information

We collect information in a number of ways, including:

When you browse and interact with our website.
Through cookies and similar technologies that help our website function effectively and help us understand how it is used.
When you complete and submit online forms.
When you contact us through website forms, email links or other online services.
Through accessibility, performance and analytical tools used to improve the user experience of our website.

What we use your information for

We use information collected through our website to:

Respond to enquiries, advice requests and referrals.
Provide information, services and support requested by you.
Improve the performance, accessibility and security of our website.
Monitor website usage and understand how visitors use our online services.
Prevent fraud, misuse and unauthorised access to our systems.
Meet our legal, regulatory and reporting obligations.
Produce anonymised statistics to help us improve our services and understand the needs of our community.

Who we share your information with

We do not sell your personal information to third parties.

Information submitted through our website may be shared with:

Members of the Citizens Advice network where necessary to provide advice or support.
Trusted service providers who help us operate and maintain our website and online systems.
Organisations to whom you have asked us to make a referral.
Regulators, law enforcement agencies or other bodies where we are required to do so by law or where there is a safeguarding or public protection concern.

Any third parties processing information on our behalf are required to keep your information secure and only use it for authorised purposes.

Our lawful basis for using your information

Our lawful basis for processing information collected through our website will depend on the purpose for which it is collected. In most cases, we process information because:

It is necessary for our legitimate interests in operating and improving our website and services.
It is necessary to respond to your enquiry or take steps at your request before providing a service.
You have provided consent, for example where non-essential cookies are used or where you have opted to receive communications from us.
We have a legal obligation to process or retain information.

Where we rely on your consent, you can withdraw it at any time.

Cookies:

By using the Citizens Advice Westminster website you are confirming that you are happy to accept our use of cookies. Here you can find out more about how we use them.

What are cookies?

Cookies are small, harmless files placed on your computer’s hard drive or in your browser memory when you visit a website.

What do cookies do?

Cookies help to make the interaction between users and websites faster and easier. For example, they can remember your preferences for selected text resizing style, contrasts and even language selection. What cookies don’t do is store any personal or confidential information about you.

Are cookies safe?

Yes, cookies are harmless text files. They can’t look into your computer or read any personal information or other material on your hard drive. Cookies can’t carry viruses or install anything harmful on your computer.

We use track aspects of user visits, including the length of a user’s visit, their browser, geographic location and the use of the search facility on this website. Below is a list of the cookies we use:

Cookie category	Cookie owners	Purpose
Website visit information	Google Analytics Yoast SEO	Google Analytics and Yoast SEO uses cookies to help us to track which pages are accessed. This allows us to understand how popular our site is and record visitor trends over time. The cookies contain no personally identifiable information but some of them do use your IP address to help determine where in the world you are accessing the site from and to track pages you visit within the site.
Social media	Facebook Twitter	Enables users to share our webpages across Facebook and Twitter.
E-privacy	Citizens Advice Westminster	To help our site remember not to re-show the cookie message once a visitor has clicked ‘Don’t show this message again’. The cookie is currently set for 12 months, after which the message will reappear. Turns the cookie message off when a visitor clicks through to another Citizens Advice Westminster page. If a visitor closes their browser session and then returns to the site, the message will reappear.

For more information on Google Analytics tracking: http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html

How you can manage or delete cookies

If you don’t want to receive cookies, you can change settings in your web browser so that your browser tells you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies, the Help function within your browser should tell you how. Alternatively, these sites can provide more information on how to do this:

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 [insert relevant email address].

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 sar@westminstercab.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