Privacy Policy

At Luton 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 Luton Citizens Advice. Luton 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 may collect your personal data:

• in person on a registration form, we will ask you to complete a client details form at your initial visit and then at intervals thereafter
• in a web-form on our website when you request email advice
• over the telephone if you call us for advice

We may also collect data relating to your personal experience here at Citizens Advice Luton in the form of a survey, if you are happy to participate.

What information we collect

• Personal details
• Contact preferences
• Survey data including profile information
• Documentation related to the enquiry type (i.e. debt advice, energy advice)

What we use your information for

We will use your information to provide you with advice as well as to improve our service and inform our campaigns.

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

• Partner organisations for referrals for specialist advice / charitable support.
• Funders to comply with reporting requirements

Our lawful basis for using your information

• Article 6(1)(f) – Legitimate interests
• Article 6(1)(e) – Public task
• Article 9(2)(g) – substantial public interest (statutory)

How we use your data when applying to work or volunteer

How we collect your information

• Personal details are collected from completed application forms for volunteering and staff recruitment.

What information we collect

• Personal details including name, address, email and phone number
• Criminal convictions
• Entitlement to work in the UK (for employment purposes)
• Relevant experience and qualifications
• Diversity monitoring information

What we use your information for

We use the information provided in the application form to review and progress the application.

Who we share your information with

• Colleagues involved in the recruitment process
• Referees in the taking up of references
• National Citizens Advice audit team

Our lawful basis for using your information

This is done under our legitimate interests in potentially onboarding you as an employee or volunteer and to contact you to further progress your application.

How we use your data when using our website

What information we collect

• Personal details
• Contact preferences
• Enquiry details

How we collect your information

• In a web-form on our website when you request email advice
• Cookies to retain user preferences and provide anonymised tracking data to third party applications like Google Analytics.

What we use your information for

• We will use your information to provide you with advice as well as to improve our service and inform our campaigns.

Who we share your information with

• Partner organisations for referrals for specialist advice / charitable support
• Funders to comply with reporting requirements

Our lawful basis for using your information

• Article 6(1)(f) – Legitimate interests
• Article 6(1)(e) – Public task
• Article 9(2)(g) – substantial public interest (statutory)

How we use cookies on our website

• Please refer to our 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.

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 advice@lutoncab.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 advice@lutoncab.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