North Tyneside Citizens Advice Privacy Policy

At North Tyneside Citizens Advice, 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 North Tyneside Citizens Advice. North Tyneside 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 information directly from yourself or from a third-party representative if you have one. The information will be gathered over the phone or digitally (webchat, email, online forms submitted via our website) provided by yourself or your third-party representative.

We may contact third party organisations to gather relevant information. This information would be relevant to the reason you have contacted us and only with your consent. Any information we collect will recorded on our CRM system. Our goal is to ensure that we collect the minimum amount of data necessary to provide you with the most effective advice and support.

What information we collect

For locally delivered advice, we collect a variety of information to provide you with the best possible support. This includes your basic contact details, personal circumstances, and specific details relevant to your issue.

What we use your information for

We use the information we collect to provide you with tailored advice and support. This includes assessing your situation, providing relevant guidance, and connecting you with appropriate services. More specifically, we may use your data to:

‎ ‎ ‎ ‎ ‎ ‎ •‎ Evaluate your personal circumstances to identify the most suitable advice and support options available.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Offer tailored advice on a range of issues including legal matters, financial problems, housing, employment, health, and welfare benefits.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Prepare necessary legal documents and applications, particularly for specialised services such as Legal Aid.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Refer you to other advisory services or support organisations that can provide additional assistance.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Ensure continuity of service by maintaining accurate records of your interactions with us.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Analyse data trends to improve our services and ensure we are meeting the needs of our clients.

By using your information in these ways, we aim to offer the most effective and relevant advice to help you navigate complex situations and make informed decisions.

Our confidentiality policy

At North Tyneside 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

We share your information with various organisations to ensure you receive the appropriate support and services. This includes:

‎ ‎ ‎ ‎ ‎ ‎ •‎ Partner organisations: These are other charities, non-profits, and community groups we collaborate with to provide comprehensive assistance.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Funders: We report to our funders to demonstrate the impact and effectiveness of our services. This helps secure ongoing support and funding.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Government agencies: In some cases, we may need to share information with government bodies to comply with legal obligations or to facilitate your access to public services and benefits.

In addition to delivering advice, we also use your information for the following purposes:

‎ ‎ ‎ ‎ ‎ ‎ •‎ Monitoring and improving our services based on feedback and outcomes.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Conducting research and analysis to identify trends and needs within the community.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Reporting to funders and stakeholders to demonstrate the impact and effectiveness of our work.

We have several data sharing agreements and non-disclosure agreements in place to ensure that your information is handled securely and confidentially when shared with partner organisations and funders. These agreements are designed to protect your privacy and comply with legal and regulatory requirements.

Our lawful basis for using your information

Generally, we will use the lawful basis of processing that the Citizens Advice Network will use and this information can be found at this link here.

In addition, we will use the lawful basis of processing as detailed below (references to Articles are to UK GDPR);

Advice, information, and guidance provision:

• ‎ Legitimate interests (Article 6(f)) where processing is not based on any public function.
• ‎ Public task (Article 6(e)) where processing is based on official authority laid down by law or a statutory function.
• ‎ Establishment, exercise, or defence of legal claims (Article 9(2)(f)) for legal rights including benefits, debt, energy, and housing.
• ‎ Substantial public interest (Article 9(2)(g)) for statutory functions and confidential wellbeing support.

Witness support:

• ‎ Legitimate interests (Article 6(f)).
• ‎ Substantial public interest (Article 9(2)(g)) for administration of justice and emotional or wellbeing support.

Funder sharing:

• ‎Dependent on the purpose the funder is processing data for, determined on a case-by-case basis.

EDI monitoring:

• ‎ ‎ Legitimate interests (Article 6(f)) for promoting equity and diversity.
• ‎ Substantial public interest (Article 9(2)(g)) for processing information relating to race, ethnicity, religious beliefs, health, and sexual orientation.

Accessibility and reasonable adjustments:

• ‎ Legal obligation (Article 6(c)) in accordance with the Equality Act 2010.
• ‎ Substantial public interest (Article 9(2)(g)) for statutory and governmental purposes.

Statistical purposes and research:

• ‎ Legitimate interests (Article 6(f)) for statistical analysis and research.
• ‎ Archiving, research, and statistics(Article 9(2)(j)).

Direct marketing of services:

• ‎ Legitimate interests (Article 6(f)) for marketing services in the client’s best interest.
• ‎ Consent (Article 6(a)) for direct electronic marketing.

Publication of client stories:

• ‎ Consent (Article 6(a)) for identifiable client stories.
• ‎ Explicit consent (Article 8(a)(a)).

Maintaining quality and standards:

• ‎ Legitimate interests (Article 6(f)) for meeting quality and standards.
• ‎ Establishment, exercise, or defence of legal claims (Article 9(2)(f)).
• ‎ Substantial public interest (Article 9(2)(g)) for protecting the public against dishonesty, malpractice, or incompetence.

Complaints:

• ‎ Legitimate interests (Article 6(f)) for investigating complaints.
• ‎ Establishment, exercise, or defence of legal claims (Article 9(2)(f)).
• ‎ Substantial public interest (Article 9(2)(g)) for protecting against dishonesty, malpractice, or incompetence.

Legal claims:

• ‎ ‎ Legitimate interests (Article 6(f)) for defending against legal claims.
• ‎ Establishment, exercise, or defence of legal claims(Article 9(2)(f)).

Individual rights requests:

• ‎ Legal obligation (Article 6(c)) in accordance with data protection law.
• ‎ Substantial public interest (Article 9(2)(g)) for statutory and governmental purposes.

Safeguarding:

• ‎ Public task (Article 6(e)) in accordance with the Care Act 2014 and the Social Services and Wellbeing (Wales) Act 2014.
• ‎ Substantial public interest (Article 9(2)(g)) for safeguarding children and individuals at risk.

Fraud prevention:

• ‎ Legitimate interests (Article 6(f)) for defending against fraudulent activity.
• ‎ Legal obligation (Article 6(c)) for disclosing actual or suspected fraud.
• ‎ Substantial public interest (Article 9(2)(g)) for preventing and detecting unlawful acts, preventing fraud, and suspicion of terrorist financing or money laundering.

Responding to a life-threatening emergency:

• ‎ Vital interests (Article 6(d)) where a person’s life may be in danger.
• ‎ Vital interests (Article 9(2)(g)) for protecting an individual’s vital interests.

 Money and Pension Service Debt Services:

‎ ‎ ‎ ‎ ‎ ‎ •‎ Legitimate interests(Article 6(f)) for providing debt advice and support.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Public task(Article 6(e)) for statutory debt functions.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Establishment, exercise, or defence of legal claims(Article 9(2)(f)) for debt-related legal rights.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Substantial public interest(Article 9(2)(g)) for statutory debt functions.

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 use your data for fundraising and donations

This section covers how we use your data to carry out our fundraising activities.

How we collect your information

‎ ‎ ‎ ‎ ‎ ‎ •‎ Casebook/Tableau– when advice is given to a client, certain data will be collected on our internal systems.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Feedback forms on client experiences are used to improve our service delivery. Consent from clients is required.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Surveys (paper & online format) on specific issues are used to collect more informed data, allowing us to gain greater knowledge and create more robust campaigns. Consent from ‎clients/participants is required.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Interviews/focus groups– when appropriate a client or relevant party may be invited to participate in specific research interviews or focus groups to add to our data collection. Consent from clients/participants is required.

What information we collect

‎ ‎ ‎ ‎ ‎ ‎ •‎ Demographic data– gender, age, ethnicity, disability/long-term health conditions, housing type, religion, geographical, sexual orientation (client does not have to provide these).

‎ ‎ ‎ ‎ ‎ ‎ •‎ Issue type:

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ Internal data gathered in advice interviews, certain issues (AICs) will be selected in relation to a client’s case.

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ External data gathered from surveys, interviews, or focus groups, will seek information on the relevant research topic. Typically, these questions will inquire about the participant’s‎ ‎personal experiences related to the chosen subject matter.

What we use your information for

‎ ‎ ‎ ‎ ‎ ‎ •‎ We only access it when we have a good reason to:

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ Internal data- we use different demographic categories and issues to track problems, analyse trends, and to identify systemic issues both locally and nationally.

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ External data– we use external data to enhance our understanding of a subject or issue. This data is collected to support the launch of campaigns aimed at improving situations, whether through report creation, event hosting, or informing relevant stakeholders through various channels.

Who we share your information with

‎ ‎ ‎ ‎ ‎ ‎ •‎ We only share what is necessary and relevant:

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ We may collaborate with other stakeholders to conduct specific research. If so, we will always ensure transparency about the partnership.

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ In reports, events, and all other forms of campaigning, all data is anonymised.

Our lawful basis for using your information

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.

Complaints and Legal Claims- Article 6(f), Article 9(2)(f) and Article 9(2)(g)

‎ ‎ ‎ ‎ ‎ ‎ •‎ We have a legitimate interest to investigate complaints and to implement lessons learned from them.

‎ ‎ ‎ ‎ ‎ ‎ •‎ We need to be able to investigate complaints to defend against claims of malpractice or negligence

‎ ‎ ‎ ‎ ‎ ‎ •‎ Specifically, we rely on is in Data Protection Act 2018, Schedule 1, (11) Protecting the public against dishonesty etc where we are investigating complaints in order to protect against:

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ dishonesty, malpractice or other seriously improper conduct

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ unfitness or incompetence,

‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎ ‎◦ mismanagement in administration

‎ ‎ ‎ ‎ ‎ ‎ •‎ We have a legitimate interest in defending our organisation against legal claims

Individual rights requests- Article 6(1)(c) and Article 9(2)(g)

‎ ‎ ‎ ‎ ‎ ‎ •‎ We have a legal obligation to carry our individual rights requests in accordance with data protection law.

‎ ‎ ‎ ‎ ‎ ‎ •‎ Specifically we rely on is Data Protection Act 2018, Schedule 1 (6) ‘statutory and governmental purposes’ to comply with the UK GDPR and Data Protection Act 2018.

Safeguarding and Responding to Life Threatening Emergencies- Article 6(1)(e), Article 9(2)(g), Article 6(1)(d) and Article 9(2)(g)

‎ ‎ ‎ ‎ ‎ ‎ •‎ The legislation covering safeguarding is the Care Act 2014 (England) and the Social Services and Wellbeing (Wales) Act 2014. These acts put duties on local authorities in relation to adult ‎safeguarding and while they don’t apply to us directly as a charity, we acknowledge Citizens Advice may receive their funding or are contracted to deliver services on their behalf and therefore‎ ‎‎‎it’s essential that we understand our role in protecting adults at risk.

‎ ‎ ‎ ‎ ‎ ‎ •‎ The special category data condition is met when the processing is necessary for the safeguarding of children and of individuals at risk in accordance with Data Protection Act 2018, Schedule 1,‎ (18) ‘Safeguarding of children and of individuals at risk’

National Citizens Advice covers their use of data for fundraising in their privacy notice.

How we use your data when applying to work or volunteer

How we collect your information

We collect the data based on your application through our recruitment systems called People First

What information we collect

We may collect the following types of personal data:

‎ ‎ ‎ ‎ ‎ ‎ •‎ Identification data (e.g., name, date of birth, gender)

‎ ‎ ‎ ‎ ‎ ‎ •‎ Contact details (e.g., address, telephone number, email)

‎ ‎ ‎ ‎ ‎ ‎ •‎ Employment details (e.g., job title, work history, qualifications)

‎ ‎ ‎ ‎ ‎ ‎ •‎ Financial information (e.g., bank details for payroll)

‎ ‎ ‎ ‎ ‎ ‎ •‎ Sensitive personal data (e.g., health information, racial or ethnic origin)

What we use your information for

We collect and process personal data for the following purposes:

Recruitment and selection HR administration Payroll and benefits administration Performance management Compliance with legal and regulatory obligations

Who we share your information with

We may share your personal data with third parties, such as payroll providers, pension administrators, and regulatory bodies, only when necessary and in compliance with data protection laws. We do not sell or trade your personal data.  Under certain circumstances, we may transfer your personal data outside of the European Economic Area (EEA); in such cases, we will ensure appropriate safeguards are in place, such as standard contractual clauses, binding corporate rules, or other legally recognised measures to protect your data’s security and privacy.

Our lawful basis for using your information

We primarily rely on your explicit consent to process your personal data and special category data, however, legitimate interest will still apply. By providing your personal data, you consent to its use for the purposes outlined in this statement.

How we use your data when using our website

How we use your data when using our website

Our privacy policy for website use can be found at the link indicated on the bottom right hand corner “privacy and 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.

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.

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 DPO@citizensadvicegateshead.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 DPO@citizensadvicegateshead.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