Citizens Advice Eastbourne
Privacy Policy
At Citizens Advice Eastbourne , 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 Eastbourne . Citizens Advice Eastbourne 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:
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you go to a different office to seek advice
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more than one office is working together in partnership
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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
We ask you for information about you
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when you speak to us on the phone
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When you complete an online form to send us a message
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By email when advice has started
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:
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your name and contact details - so we can keep in touch with you about your case
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personal information - for example about family, work, or financial circumstances, or if you're vulnerable or at risk of harm
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details about services you get that are causing you problems - like energy or post
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details of items or services you've bought and traders you've dealt with
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information like your gender, ethnicity or sexual orientation
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.
We might ask your permission to contact you later with an online survey about your experience getting help from us. This is called the ‘Client Experience’ survey.
What we use your information for
The main reason we ask for your information is to help solve your problem.We only access your information for other reasons if we really need to. For example we have a legitimate interest to access your data:
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for training and quality purposes
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to investigate complaints
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to get feedback from you about our services
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to help us improve our services
All advisers and staff accessing data have had data protection training to make sure your information is handled sensitively and securely.
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:
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to prevent an immediate risk of harm to an individual
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In select circumstances if it is in the best interests of the client
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where we are compelled to do so by law (e.g. a court order or meeting statutory disclosures)
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where there is an overriding public interest such as to prevent harm against someone or to investigate a crime
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to defend against a complaint or legal claim
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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:
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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
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refer you quickly to another organisation for more advice or support, if relevant
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help you access certain services - for example food banks or Trading Standards
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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. These include:
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BHT Eastbourne Advice for Housing matters
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CA1066 for Energy Advice
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Eastbourne Borough Council
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East Sussex County Council
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The Department of Work and Pensions
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Eastbourne Foodbank
We will always ask for your agreement to share information with these agencies before doing so unless there is a safety concern.
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(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.
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 (counselling)
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.
No, though clients may have the option of being unnamed
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:
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talking with you over the phone, face to face or by email
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accessing your records on our case management system - if you've got advice from us before
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accessing a survey you completed - for example on our website
With your permission, we might ask you to fill in an online survey about your experience getting help from us - this is called the ‘Client Experience’ survey.
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:
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your situation like family, work or financial circumstances - and how it affects you
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how you use Citizens Advice and other organisations' services - and what you thought about them
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your name and contact details - so we can keep in touch with you
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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.
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:
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ask you to share your story with the media
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include your information in a report or blog as part of our research and design, campaigns, or media work
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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 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.
Who we share your information with
We will normally only share anonymous information with other organisations. We will always get your agreement before sharing your personal details with other organisations.
We might share your information with government or industry regulators as part of our campaigns and policy work. We may share details of your situation with local organisations like Eastbourne Borough Council or the Jobcentre inorder to raise a wider issue with them as part of a campaign.
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.
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?
Statistical purposes and research (including feedback)
Article 6(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
How we use your data for fundraising and donations
At present, we don't collect your personal information when fundraising.
How we use your data when applying to work or volunteer
How we collect your information
We use online forms or paper forms to enable people to apply to work or volunteer with us.
What information we collect
We collect your name, address contact details, basic profile information which is kept separate to the application, a DBS check if that is required by the role
What we use your information for
We use your personal information as part of the recruitment process.
Who we share your information with
Your personal information is kept within a limited number of staff involved in recruitment and is not shared with anyone outside our office. If for any reason we need to share your information with anyone else we will get your agreement before doing this.
Our lawful basis for using your information
We rely on the Legitimate Interests as our lawful basis of processing.
How we use your data when using our website
We have two main websites:
www.eastbournecab.co.uk This site does not collect any personal information from you and doesn't use cookies.
and www.eastsussexcab.co.uk This site contains a series of webforms which collect information about you and your enquiry. These are held within a central server which is secure. Only our staff can access the content of your enquiry and your personal information.
What information we collect
We collect the same information as listed above for Advice.
How we collect your information
www.eastsussexcab.co.uk This site contains a series of webforms which collect information about you and your enquiry.
What we use your information for
To help give advice on the enquiry you need help with.
Who we share your information with
We only share your information with other organisations with your permission to do so.
Our lawful basis for using your information
We use the same lawful basis as those listed above under Advice.
How we use cookies on our website
We do not collect personal information on www.eastbournecab.co.uk
We do collect personal information on www.eastsussexcab.co.uk
We do not use cookies on this site.
You can view the privacy policy here
https://www.eastsussexcab.co.uk/privacy-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
Purpose
Retention
Case records stored electronically and other client paper records
Advice
6 years
Personnel files of employed and volunteer staff including training records and notes of disciplinary and grievance hearings
Employment
6 years from the end of employment
Application forms/interview notes for paid and volunteer staff (including unsuccessful applications)
Recruitment
1 year from the date the application was received
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.
Processor name
Activities
Data hosting location
Email webform
Collecting client enquiries and personal data
Manchester
Your data protection rights
You have rights in relation to your personal data that we hold. Your rights include being able to request:
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Access to copies of your data
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Corrections are made to inaccurate data
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Deletion of your personal data
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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 administrator@eastbournecab.co.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 administrator@eastbournecab.co.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.
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Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
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Helpline number: 0303 123 1113
Cookie Policy
You can read about our cookie policy here: www.citizensadvice.org.uk/about-us/citizens-advice-privacy-policy/how-we-use-cookies/
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For General Advice freephone: 0800 144 8848
Debt helpline: 0800 240 4420
Consumer Helpline: 0808 223 1133
Universal Credit Help to Claim: 0800 144 8 444
CA1066 Energy Advice Helpline: 0800 145 6879