Privacy Policy
Citizens Advice Wirral Privacy Policy
At Citizens Advice Wirral, 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 Wirral. Citizens Advice Wirral 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
How we handle your personal information depends on how you interact with us.
We need to record information about you to help with your enquiry. We have a legitimate interest to do this.
We collect information about you through the following:
- Telephone or face to face appointment
- A partner referral form – where you have given permission for a third party to share your information with us in order to help you with an enquiry. This may be sent via our website enquiry form or directly from one of our partners via an encrypted email.
- Email or call back enquiry form via one of our terminal points.
- Our CAWbot
What we use your information for
The information you provide will be used to:
- give you advice
- help us gather data to improve our service
- support our research in a way that you can’t be identified
What information we collect
We’ll only ask for information that’s relevant to your problem. Depending on what you want help with, this might include:
- your name and contact details – so we can keep in touch with you about your case
- personal information – for example about family, work, or financial circumstances, or if you’re vulnerable or at risk of harm
- details about services you get that are causing you problems – like energy or post
- details of items or services you’ve bought and traders you’ve dealt with
- information like your gender, ethnicity, religion or sexual orientation
- Information on your health conditions if relevant to your enquiry
We occasionally ask for details about someone else like a neighbour or your partner so we can deal with an enquiry. We’ll only do this if we have a legitimate interest in the information, or we need it to protect someone’s life.
If you don’t want to give us certain information, you don’t have to. For example, if you want to stay anonymous we’ll only record information about your problem and make sure you’re not identified.
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
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 or support, if relevant
- help you access certain services – for example food banks or Trading Standards
- monitor the quality of our services
Organisations we share your data with must store and use your data in line with data protection law. They’ll have their own privacy policies for how they handle your information and keep it safe.
There might be specific organisations we share your information with, depending on what service you access. Our Ask Us Wirral partnership consists of Age UK Wirral, Wirral Mind, Involve Northwest, Wirral Mencap, Wirral Change.
Our lawful basis for using your information
When Citizens Advice Wirral processes your information, the lawful basis generally falls under the following principles:
Article 6(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(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.
In addition, for some services provided by Citizens Advice Wirral we may rely on the following:
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.
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
With your permission we might contact you for help with research, campaigns or media work. We’ll collect information from you by either:
- talking with you over the phone, face to face or by email
- accessing your records on our case management system – if you’ve got advice from us before
What information we collect
We only ask for the information we need to tell your story or inform our research. Depending on how we want you to help us, this might include information about:
- your situation like family, work or financial circumstances – and how it affects you
- how you use Citizens Advice Wirral and other organisations’ services – and what you thought about them
- your name and contact details – so we can keep in touch with you
- demographic information like your gender, ethnicity or sexual orientation
If you don’t want to give us some personal details, you don’t have to.
You can withdraw your permission for us to store your personal information at any time – known legally as withdrawing consent. Tell us what personal information you don’t want us to store and we’ll delete it.
We’ll always tell you how we’ll use your information and ask your permission. For example, by signing a paper consent form, giving agreement over the phone or ticking a box online.
If we want to record an interview with you, we’ll ask.
What we use your information for
When we contact you we’ll explain how we want to use your information – for example, we might want to:
- ask you to share your story with the media
- include your information in a report or blog as part of our research and campaigns work or in a summary of statistics about the impact of our services
- use your information to improve our services
If we’re sharing your story publicly, you can stay anonymous if you want to – we’ll change some details of your story to make sure you can’t be identified.
We might share your information with local commissioners, government or industry regulators as part of our campaigns and policy work.
Organisations we share your data with must store and use it in line with data protection law – they can’t pass it on or sell it without your permission.
We only access your information for other reasons if we really need to – for example, to investigate complaints.
All staff accessing data have done data protection training to make sure your information is handled sensitively and securely.
Our lawful basis for using your information
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.
We may also rely on Article 6(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.
How we use your data when applying to work or volunteer
How we collect your information
When you apply for a voluntary or paid position at Citizens Advice Wirral we collect your personal information through your application form, interview or references so we can process your application.
We have a ‘legitimate interest’ to do this under data protection law. This means it lets us carry out our aims and goals as an organisation. We need to use your personal information to recruit people and make sure our recruitment processes are inclusive.
If you applied for paid employment at Citizens Advice Wirral, we collect your details through a third party online recruitment system called Be Applied. Be Applied is the ‘data processor’ but Citizens Advice Wirral is responsible for keeping your personal information safe and making sure we follow data protection law. This means we’re the ‘data controller’ for your personal information.
Who we share your information with
If you accept an offer to work or volunteer for us we’ll:
- get your permission to share your information with your references
- Add your contact information to our HR system (currently Breathe HR)
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.
We might collect other information depending on whether you’ve applied for a staff or volunteer role.
If we offer you a paid position, we’ll 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
Where it’s needed for the role, we will 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.
This information would include your name, date of birth, place of birth, gender, position applied for and anything else disclosed on your DBS check.
What we use your information for
The main reasons we ask for your personal information are to:
- send you job alerts if you sign up for them
- 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.
We run a guaranteed interview scheme for people with disabilities. The recruitment team will see on your application if you applied using this scheme. They will treat this information as strictly confidential and they won’t be able to see the rest of your diversity information.
Our lawful basis for using your information
Under UK data protection law (GDPR and the Data Protection Act 2018), employers must have a valid lawful basis for processing staff information. At Citizens Advice Wirral we rely on the following lawful bases:
- Contractual Necessity: Data processing required to fulfill employment contracts, such as payroll, benefits administration, and providing resources or services to employees.
- Legal Obligation: Data processing required to comply with legal obligations, including tax reporting, health and safety regulations, and other statutory requirements.
- Legitimate Interests: Processing based on the employer’s legitimate interests, provided these are not overridden by the employee’s rights. This may include internal communications, training, and workplace security.
- Vital Interests: In emergency situations where processing is necessary to protect the life or safety of the employee or others.
How we use your data when using our website
What information we collect
You can unsubscribe at any time – click on the ‘unsubscribe’ link in your newsletter or email.
Partner referral form
When you or a third party completes a referral/enquiry using the partner referral form, we collect personal information so we can contact you to assist you with your enquiry.
Cost of Living newsletters
When you subscribe, you give us permission to process your information and contact you. You might do this by:
- ticking a consent box on a sign-up form
- completing a form or survey on our website
- asking Citizens Advice Wirral’s staff to add you to a mailing list
What we use your information for
We use the information you provide through our website to either support you with your enquiry or to subscribe you to our cost of living newsletter.
Who we share your information with
We use a third party data management system called Brevo to process subscriptions to our newsletter. Any organisation that we share your data with must store and use it in line with data protection law – they can’t pass it on or sell it without your permission.
Our lawful basis for using your information
When Citizens Advice Wirral processes web information, the lawful basis generally falls under the following principles:
- Legitimate Interests: we access web data to answer your enquiry
- Consent: where you directly share information with us, you have initiated the request and agreed to share relevant information.
How we use cookies on our website
See our cookies policy on our website for detail on how we use cookies (https://citizensadvicewirral.org.uk/about-us/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.
Whether you get advice face to face, over the phone, by email or chat, our adviser will log all your information, correspondence, and notes about your problem into our secure case management systems. We have a ‘legitimate interest’ to do this under data protection law. This means it lets us carry out our aims and goals as an organisation.
Some of your information might also be kept within our secure email and IT systems.
If an adviser needs to see your documents, they might tell you how to upload copies of the documents to a secure online system. The adviser will then move the documents from the online system to our case management system.
We keep your information for 6 years. If your case has been subject to a serious complaint, insurance claim or other dispute we keep the data for 16 years.
If you call us, we’ll record the conversation for training and monitoring purposes. When you call, you’ll hear a recorded message telling you how we use and store your information – you can let the adviser know if you disagree.
Calls are recorded by our trusted partner, stored within the UK or EEA, and processed in line with UK data protection law. Recordings are usually held for 6 months and then deleted.
You may be asked to leave a voicemail. We have a legitimate interest to collect and store this information. If you leave any sensitive information, for example, details of your health, we will always ask you if you want this information stored when we get back to you.
| Data | Retention |
|---|---|
| All client records apart from the high risk categories below. | 6 years |
| Any case that has been subject to a serious complaint, insurance claim or other dispute. | 16 years |
| Any case relating to building works or surveyors’ reports on the purchase of property or relating to property. | 16 years |
| Any case which Citizens Advice Wirral considers to be a substantial risk, where the sums of money involved are, for example, in excess of £10,000 or where the advice given was especially complex, or where Citizens Advice Wirral are otherwise concerned that the case is unusual. | 16 years |
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 contact@citizensasdvicewirral.org.uk
If you have any concerns about how your information is collected or used, you can contact the following:
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 contact@citizensasdvicewirral.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