Privacy Policy

At Citizens Advice Rushmoor, 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 Farnborough and Aldershot Citizens Advice. Rushmoor Citizens Advice 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

We collect appropriate information when you contact us directly or by a referral partner you have agreed to provide us with information.

What information we collect

To find out what information we ask for, see our national Citizens Advice privacy policy

What we use your information for

All information that is recorded is done so because:

• it is pertinent to progressing with your case
• the information helps us assess how we are performing in reaching out to all areas of the community we serve
• we are required to provide anonymised statistics to our funders to continue the funding of that service

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

If, with your agreement, we conclude that your case can best handled by another agency – we will share your information with that agency only with your signed consent.  Citizens Advice Rushmoor will only refer to agencies we have previously approved and retain on our Approved Referral Agency List.  All information shared routinely with our funders is anonymised and is for statistical purposes only.

Our lawful basis for using your information

We record and process personal information about you such as your address, telephone number because we have a Legitimate interest to do, and to assist you with your case.

Any further information, including special category data, may be recorded to:

1. establishment, exercise or defence of legal claims
   • This includes establishing legal rights such as housing, benefits, debt solutions
2. Substantial public interest – statutory basis 
   • when delivering advice laid down in law (e.g. consumer service)
3. Substantial public interest – provision of confidential counselling, advice or support
   • When delivering more welfare focused advice that doesn’t relate to legal rights and isn’t laid down in law

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

When you ask for our assistance in-person, on the phone or digital channels, we record personal information and special category information on our nationally provisioned and secure case recording system called Casebook.

What information we collect

This information could include data such as gender or ethnic origin which we would ask for whether it is relevant to helping you or not.  You are not obliged to provide this information to access our services.

What we use your information for

This information enables us to collate anonymous statistics to track and identify if our services are reaching the community we are here to support.

Who we share your information with

Anonymised statistics are shared with our funders and other parties to demonstrate the work we undertake and for who.

We only share identifiable information outside the Citizens Advice service if we have your consent to do so.

Our lawful basis for using your information

If you give your explicit consent to provide feedback about our services, you may be contacted by a third party contracted by Citizens Advice to carry out a survey.  Please Citizens Advice privacy notice for more information.

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 6(f) – Legitimate interests

We have a legitimate interest in processing EDI data to ensure we are promoting equity and diversity in our service. We have a full legitimate interest assessment for this processing.

How we use your data when applying to work or volunteer

How we collect your information

We use an online form through the Microsoft Office 365 Forms app or a paper form, to collate the information required to process your application.

What information we collect

Personal information is collated by Microsoft forms and transferred to an Excel spreadsheet stored in our SharePoint site, which is restricted and secured by multifactor authentication.

What we use your information for

We use the information to monitor the demographic composition of both paid staff and non-paid staff.  We aim to appeal to a broad section of society and all communities represented in Rushmoor.

Who we share your information with

Anonymised statistics are share with Citizens Advice national so they can monitor our performance representing our community and the performance of the service nationally.

Our lawful basis for using your information

We are contractually obliged as part of our membership agreement to provide demographic information to Citizens Advice about the people we recruit. Also:

Article 6(f) – Legitimate interests

We have a legitimate interest in processing EDI data to ensure we are promoting equity and diversity in our service. We have a full legitimate interest assessment for this processing.

How we use your data when using our website

We do not collate identifiable data when you visit our website.  We have collated anonymised data which give us basic information to monitor the performance of our website.

How we use cookies on our website

When you visit our website, you can accept cookies, refuse third party cookies or view our privacy policy for this information.

If you consent, we use Google Analytics Cookies to understand our website usage, you can lean more about Google cookies here:

How Google uses cookies – Privacy & Terms – Google

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.

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.

Citizens Advice Rushmoor does not employ any local third-party processors currently.

Miscellaneous

CCTV

Closed Circuit Television is in use around Farnborough Citizens Advice at the Civic Offices, operated by Rushmoor Borough Council, please visit their site for more information.

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:

[email protected]

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 [email protected]

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 [email protected]

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