Privacy Policy
At Citizens Advice Harlow, 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 Harlow. Citizens Advice Harlow 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
You can find out how we collect your data for our core advice services, see our national Citizens Advice privacy page.
What information we collect
To find out what information we collect, see the national Citizens Advice privacy page.
What we use your information for
To find out what we use your information for, see the national Citizens Advice privacy page.
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 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.
Working on your behalf
When you give us authority to act on your behalf we’ll need to share information with that third party. Examples may include Harlow Council, DWP, your housing association, our pro bono solicitor, your creditors, or the local food bank.
In addition to our joint controlled data, Citizens Advice Harlow uses MS365 as its productivity suite and your personal data may be stored there while your case is active. Our policy is to minimize all data collected and we aim to transfer all personal information to casebook during the course of your case. For more information read General Data Protection Regulation (GDPR) | Microsoft Learn
Our lawful basis for using your information
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 advisers 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 national Citizens Advice privacy page for how we handle most of your personal information.
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
To find out how we collect your information, please see our national Citizens Advice privacy page.
What information we collect
To find out what information we collect, please see our national Citizens Advice privacy page.
What we use your information for
To find out what we use your information for, please see our national Citizens Advice privacy page.
Who we share your information with
To find out who we share your information with, please see our national Citizens Advice privacy page
How we use your data when using our website
What information we collect
When you visit our website, we may collect the following data:
· Your IP address.
· Your contact information and email address.
· Other information such as interests and preferences.
· Data profile regarding your online behaviour on our website.
How we collect your information
Please see our Cookie Policy.
What we use your information for
We use your information for several reasons:
· To better understand your needs.
· To improve our services and products.
· To contact you in response to any forms you have filled out.
· To customize our website according to your online behaviour and personal preferences.
Who we share your information with
Our website contains links that lead to other websites. If you click on these links, Citizens Advice Harlow is not held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy policy agreement. Make sure to read the privacy policy documentation of the website you go to from our website.
Our lawful basis for using your information
You can find out our lawful basis for using your information here:
How we use cookies on our website
Our Cookie Policy
Once you agree to allow our website to use cookies, you also agree to use the data it collects regarding your online behaviour (analyze web traffic, web pages you visit and spend the most time on).
The data we collect by using cookies is used to customize our website to your needs. After we use the data for statistical analysis, the data is completely removed from our systems.
Please note that cookies don't allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you.
If you want to disable cookies, you can do it by accessing the settings of your internet browser. You can visit https://www.internetcookies.com, which contains comprehensive information on how to do this on a wide variety of browsers and devices. For further information, please see national Citizens Advice Cookie Policy
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
Purpose: Advice provision and insurance
Retention: 6 years from last substantive action such as updating a case note or debt assessment
Data: Individual reason
Purpose:
Safeguarding
Increased risk of legal claim of a particular type
Groups or classes of cases of historical or societal importance.
Records that form part of an active inquiry
Funder specified
Retention: 16 years
For further information about our data retention, please contact us.
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.
MS365
In addition to our joint controlled data, Citizens Advice Harlow uses MS365 as its productivity suite and your personal data may be stored there while your case is active. Our policy is to minimize all data collected and we aim to transfer all personal information to casebook during the course of your case. For more information read General Data Protection Regulation (GDPR) | Microsoft Learn
TTNC
We use SMS message platform TTNC to send appointment reminders and important updates about your case. When using TTNC our policy is to minimize all data collected and we aim to transfer all personal information to casebook during the course of your case. TTNC store your data in accordance with their Privacy Notice. We always ensure we have your consent before contacting you via TTNC. If you would like to discuss this further, please contact us.
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 sadie.crocker@harlowcitizensadvice.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 sadie.crocker@harlowcitizensadvice.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.
● Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
● Helpline number: 0303 123 1113At Harlow Citizens Advice, we collect and use your personal information to help us solve your problems, communicate with you and improve our service.
We only ask for the information that we need at the time and we will always let you decide what you feel comfortable telling is, explain to you why we need it and treat your personal information as confidential. When we do this, we will only access the information when we have a good reason to do so, only share it when it is necessary and relevant and we will never sell your information to anyone.
We handle and store your personal information in line with data protection law.
Who are we?
We are Citizens Advice Harlow, a registered charity number: 1135235. Company number: 7013193
If you wish to contact us directly regarding a privacy or data protection issue, email sadie.crocker@harlowcitizensadvice.org.uk
Who is responsible for keeping your information safe?
Citizens Advice Harlow is the Data Controller
Our Senior Information Risk Officer is Beatriz Brett
Your Rights
You can contact us at any time and ask us:
what information we've stored about you
to change or update your details
to delete your details from our records
You can withdraw your consent for the processing of your personal data at any time. To do so, please contact us at sadie.crocker@harlowcitizensadvice.org.uk