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 Lancashire West.

Citizens Advice Lancashire West 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 how we, as your local charity, handle your information locally in our office.

How we collect your data

You can find out how we collect your data for our core advice services, see our national Citizens Advice privacy page.

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

How we use your information

Working on your behalf.

When you give us authority to act on your behalf, for example to help you deal with your debts, we’ll need to share some information with your creditors.

How we store your information

The national Citizens Advice charity and your local Citizens Advice operate a system called Casebook to keep your personal information safe. This means they’re a ‘joint data controller’ for your personal information that’s stored in our Casebook system.

If you contact us via the Online Enquiry or Professional Referral Webforms we will use the information you provide in your email enquiry to provide you with advice and/or to direct you to an alternative service that can assist you. Our policy is to minimise all data collected and we aim to transfer all personal information, including a record of your email and the advice we provide to you, to Casebook during the course of your case.

We use the SMS message platform aql to send meeting reminders, contact before call messages and important updates about your case. When using aql our policy is to minimise all data collected and we aim to transfer all personal information to Casebook during the course of your case. Aql stores your data in accordance with their Privacy Notice.

When using LiveChat to contact our debt service our policy is to minimize all data collected and we aim to transfer all personal information to casebook during the course of your case. LiveChat by Text is a third party platform and all data stored is in accordance with their Privacy Notice. 

When using Refernet to make a referral on behalf of a third party our policy is to minimize all data collected and we aim to transfer all personal information to casebook during the course of your case. The referrals use a third party platform Refernet, all data stored is in accordance with their Privacy Notice. We always ensure we have your consent before adding any of your personal data to Refernet. 

When using the WhatsApp Debt Service our policy is to minimise all data collected and we aim to transfer all personal information to casebook during the course of your case. Facebook will also store your data in accordance with the Terms of Service of your WhatsApp account. WhatsApp is a third-party service and Citizens Advice Lancashire West cannot accept liability for data held by WhatsApp or breaches of that data. Security of data cannot be guaranteed in messages you send to us through WhatsApp and we do not control and are not responsible for the use of your data by this third-party service.

Each local Citizens Advice is an independent charity, and a member of the national Citizens Advice charity. The Citizens Advice membership agreement also requires that the use of your information complies with data protection law.

You can find out more about your data rights on the Information Commissioner’s website.

We will handle and store your personal information in line with Data Protection law but if you would like to know more about why we store your information and how we use it please visit www.citizensadvice.org.uk/myinformation

If you have any questions about how your information is collected or used, you can submit a Subject Access Request here https://www.citizensadvicelancashirewest.org.uk/subject-access-request

You can contact us to:

• find out what personal information we hold about you

• correct your information if it’s wrong, out of date or incomplete

• request we delete your information

• ask us to limit what we do with your data - for example, ask us not to share it if you haven’t asked us already

● ask us to give you a copy of the data we hold in a format you can use to transfer it to another service

• ask us to stop using your information

To request the deletion of your personal data, please email individualrights@citizensadvice.org.uk

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 you give us authority to act on your behalf, for example to help you with your benefits, we’ll need to share information with that third party. For example, we may need to share your information with the JobCentre, a housing association, or the local authority.

Other examples of third parties we may need to share your information with are your local Council, DWP, or your creditors.

Our lawful basis for using your information

Generally our lawful basis for using your data to provide you with advice is ‘legitimate interests’. There is a clear legitimate interest in helping you with an issue you are seeking advice on so this is our default lawful basis and applies to our generalist advice.

When using special category data for advice purposes we can generally rely on ‘establishment, exercise or defence of legal claims’. While our advice doesn’t always often relate directly to a legal claim, we can also rely on this condition when establishing, exercising or defending legal rights in any way. This will include but is not limited to advice types such as:

• employment

• discrimination

• housing

• benefits

• debt and money

• immigration

However not all our advice will relate to legal rights in this way. There are also times where we discuss client welfare which isn’t related to their rights. For example if a client was looking for support with loneliness and mentioned they struggled with socialising due to a disability, we may offer support for their wellbeing. In such cases we can rely on the ‘counselling provision’ which is one of the ‘substantial public interest’ conditions.

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.

If you have any questions about how your information is collected or used, you can submit a Subject Access Request here https://www.citizensadvicelancashirewest.org.uk/subject-access-request

To request the deletion of your personal data, please email individualrights@citizensadvice.org.uk

Raising a concern about how we use your information

If you are concerned about how we have handled your personal information please submit your request via our Complaints form https://www.citizensadvicelancashirewest.org.uk/complaints-or-compliments

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