Privacy Policy
At Citizens Advice Denbighshire, 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 Denbighshire.Citizens Advice Denbighshire 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 including how long
your information is kept for, please see the national Citizens Advice privacy
notice.
How we collect your information
We collect your data for advice via the following methods:
When you visit our offices and complete a client registration form
When you telephone us seeking advice
When you contact us via our website using a contact form
When you contact us via WhatsApp
When you are referred to us by another organisation
When you get advice by any of the above methods, our adviser will log all your
information, correspondence, and notes about your problem into our secure
case management systems. Some of your information might also be kept within
our secure email and IT systems.
When you contact us via our website using a contact form
When you get in touch with us via our website using a contact form, your
enquiry is forwarded to a secure email address for the generalist advice team.
We then add a copy of your enquiry to our case management system and delete
the email. Your contact form enquiry also remains on our secure website server.
Enquiries are then deleted from the server at regular intervals.
When you contact us via WhatsApp
We use the WhatsApp communication platform.
Any data sent through the WhatsApp platform is also processed and stored
securely by WhatsApp and their parent company, Meta. Messages on the device
the are sent or received from are deleted once dealt with.
WhatsApp messages use end-to-end encryption. Messages are deleted
automatically from the WhatsApp server after 30 days and only retained on the
device they are sent or received from until deletion.
When you are referred to us by another organisation
We use a system called Refernet if we need to refer you to another organisation
or if another organisation refers you to us.
If you’re referred through Refernet, your information will be stored securely on
the Refernet system. We keep your information on Refernet for a year from the
date you’re referred. After a year, your information is deleted from the Refernet
system. However, personal data extracted from Refernet may be kept for longer
by any given partner organisation in accordance with data protection law.
We also accept referrals from other organisations by email. If you are referred to
us by email, a copy of the referral is added to our secure case management
system. We then delete the email once the referral has been dealt
with/completed.
What information we collect
We’ll only ask for information that’s relevant. Depending on what you want help
with, this might include:
your name and contact details – so we can keep in touch with you about your case
personal information – for example about family, work, or financial circumstances, or if you’re vulnerable or at risk of harm
details about services you get that are causing you problems – like energy or post
details of items or services you’ve bought and traders you’ve dealt with
information like your gender, ethnicity or sexual orientation.
To find out more about what information we collect, please see our national
Citizens Advice privacy notice.
What we use your information for
The main reason we ask for your information is to provide you with information
and advice to help solve your problem.
We also use your information:
for training and quality purposes
to investigate complaints
to help us improve our services
to defend legal claims
to help ensure our service is accessible to you
To find out more about how we use your information, see please our national
Citizens Advice privacy notice.
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
With your permission, we may share your information with other organisations
to help resolve your problem(s). The type of organisations that we refer people
to include (but are not limited to) – Denbighshire County Council, Vale of Clwyd
Foodbank, DASU, Shelter Cymru, SNAP Cymru, another Local Citizens Advice
office.
If you ask us to act on your behalf we may need to share some of your information
with other organisations – we’ll always tell you when we do this and only with your
express permission. For example if we contact your creditors about your debts, we
may need to share your name, address and financial details with them.
To find out more about who we might share your information with, please see our
national Citizens Advice privacy notice.
Our lawful basis for using your information
We use the following lawful bases to use your information to help you resolve your problem(s):
Legitimate interest – We have a legitimate interest to provide you with advice.
We also have a legitimate interest to:
ensure that we are meeting appropriate quality and standards in our advice to clients
defend legal claims
investigate complaints and implement lessons learned from them
ensure our service is accessible
promote equity and diversity in our service.
Establishment, exercise or defence of legal claims – Where we are helping you
establish your legal rights, for example in relation to benefits.
Also, where we are investigating complaints, defending against legal claims, are
helping to ensure that our service is accessible and to promote equity and
diversity in our service.
Substantial Public Interest (provision of confidential counselling, advice or
support) – Where we are providing advice to you which doesn’t relate to your
legal rights, for example in relation to your wellbeing
Vital interests – Where a person’s life may be in danger.
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
How we collect your information
We ask if you would like to provide feedback on our service. If you agree, we
record your consent on our case management system or we will send you a link
via email, WhatsApp or SMS (text message) to complete a feedback form on our
website.
We process feedback by adding the information to a securely stored central
spreadsheet on our Google Drive. Your completed feedback form remains on
our secure website server until it is processed and deleted.
We receive anonymised quarterly reports from National Citizens Advice with
regard to feedback via our case management system, in Google Drive for two
years before anonymising the information. This ensures we can review trends
and improve our service while protecting your privacy.
What information we collect
We ask for your feedback or comments on how we can improve our service
including how you contacted us and how you heard about our service. We also
ask for your name and contact details but you do not have to provide this.
What we use your information for
We use your feedback to help us review and improve our services. We also use
this information to review how people are accessing our service and how we
market our service.
Who we share your information with
Your information is not shared with any third parties. Feedback data is not
anonymised but it is not compulsory to fill in your name and contact details.
Our lawful basis for using your information
Legitimate interest – We have a legitimate interest to ask for feedback to help us
review and improve our service.
How we use your data when applying to work or volunteer
How we collect your information
Volunteers – We ask you to complete an expression of interest form on our
website . We also collect your information through an application form, interview
and references.
Staff – When you apply, we ask you to either complete an application form or
submit your CV and a covering letter to our dedicated secure recruitment email
address. We also collect your information through interview and references.
What information we collect
Volunteers – We collect your contact details and information about your skills
and why you want to volunteer with us. We also ask about any possible conflict
of interest, including whether you are a current client.
Staff – As well as information about your previous roles, skills and experience
and education on a standard CV, we also ask you to provide us with a cover
letter detailing why you are interested in and suitable for the specific role.
What we use your information for
We use your information to process your interest or application in becoming a
volunteer or a staff member and to make sure our recruitment processes are
inclusive. This includes:
check you’ve got the right skills for a role
arrange an interview
let you know the result of your application
do checks when we make an offer, for example contacting your
references or checking your right to work in the UK
Who we share your information with
If you’re offered a role, we will share your data with third parties in order to
obtain references, background checks from third-party providers or, for certain
roles, a criminal record check from the Disclosure and Barring Service. We use a
trusted third party called uCheck to process any DBS checks required. You can
see the uCheck privacy policy here.
We won’t usually share your personal information with anyone else in a way that
could identify you. In some rare situations we have to share your information,
for example if:
we’re investigating a safeguarding issue
the police ask for the information to help them investigate a crime
a court orders us to share the information
Our lawful basis for using your information
Legitimate interest – We have a legitimate interest to use the information you
have provided to process your application to be a volunteer or a staff member.
Consent – Our legal basis for collection of special category data and information
about criminal convictions is consent.
How long we keep your data for
Volunteers – We will keep unsuccessful application information for 12 months.
Staff – We will keep unsuccessful application information for 12 months.
If you are successful, we have a separate Privacy Notice which explains how we
use your information and your rights when you volunteer or work for us.
How we use your data when using our website
This section covers how we use your data when you use our website.
National Citizens Advice covers their use of data when you use their website in
their privacy notice.
What information we collect
We collect limited information about users of our website to improve our
services and online presence. This includes:
Website usage data collected through Squarespace (e.g., pages visited,
time spent on the site, and referral sources).
Data collected through cookies, which help us enhance website
functionality and user experience.
Personal Information submitted via online forms. To find out more about
how we use this information, please see the sections called How we use
your data for advice or How we use your data when applying to volunteer
How we collect your information
We collect information in the following ways:
Cookies – We use cookies to track website performance, analyse user
behaviour, and improve functionality. Some cookies are essential for site
operation, while others help us improve our content and marketing. You
can manage cookie preferences via your browser settings.
Squarespace – We use Squarespace to measure how visitors interact with
our website. This service collects anonymised data about user behaviour,
such as which pages are visited and how users navigate the site.
Squarespace retains anonymised website data identifying unique visitors
and tracking a visitor’s session on the website for up to 24 months. See
Squarespace’s Privacy Policy for more details.
Through website user input through forms on the website - we use this
information to contact you via email, WhatsApp, Messenger or SMS (text
message) to further your request for information or advice, or to
acknowledge feedback.
What we use your information for
We use website data to:
Monitor and improve website performance and accessibility.
Analyse trends to enhance user experience.
Ensure our website remains secure and functions properly.
Respond to requests for information, advice, and to acknowledge
feedback.
How we use cookies on our website
Cookies help us understand how users interact with our website and improve
their experience. We use:
Essential Cookies – Required for core functionality, such as security and
accessibility (known as a “crumb”, which expires when the user browsing
session ends).
Analytics Cookies – Used by Squarespace to collect anonymous data on
website performance and user behaviour.
How we use user input on our website
User input allows our staff to respond to your requests and feedback. We collect
user input for:
Service user feedback - We ask if you would like to provide feedback on
our service. If you agree, we will send you a link via email, WhatsApp,
Messenger or SMS (text message) to complete a feedback form on our
website.
We process feedback by adding the information to a securely stored central
spreadsheet on our Google Drive. Your completed feedback form remains on
our secure website server until it is processed and deleted.
We keep all records of feedback on our Google Drive for two years before
anonymising the information. This ensures we can review trends and improve
our service while protecting your privacy.
Requests for information and/or advice - Users can access Citizens Advice
Denbighshire services via the form on our Get in Touch page.
This form collects information on the time and date the form is sent, your first
and last name, ways in which you’re happy to be contacted, your email
address, phone number, whether you’re a member of the Armed Forces
Community, whether you’re a carer, and information you would like to include
about how we can help.
This information is sent directly from our website to our advice service inbox
where an adviser will use the information input by the user to help give further
information and advice relating to your issue.
Who we share your information with
Website usage data is shared with Squarespace, but it does not personally
identify you.
We do not sell or share your data with third parties for marketing purposes.
Our lawful basis for using your information
Legitimate Interest – We have a legitimate interest to process data to analyse
and improve our website’s performance and user experience.
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@dcab.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 julie.pierce@dcab.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.
Address: Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113