At Torbay 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 Torbay Citizens Advice. Torbay 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.
National Citizens Advice has a privacy notice available on their website that covers general advice and nationally funded advice programmes, please refer to this policy When you get advice – Citizens Advice
For general advice and nationally funded advice programmes please see the 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
Our lawful basis for using your information
Article 6(f) – Legitimate interests
Where processing is not based on any public function. We have carried out a Legitimate Interests Assessment for this processing.
Article 6(e) – Public task
Where processing is based on official authority laid down by law or a statutory function. For example, in relation to our consumer service functions.
Article 9(2)(f) – establishment, exercise or defence of legal claims
Where the processing relates to the establishment or defence of legal claims including legal rights including but not limited to those such as those in relation to benefits, debt, energy and housing. For criminal offence data the same provision is outlined in Data Protection Act 2018, Schedule 1, Part 3 (33).
Article 9(2)(g) – substantial public interest (statutory)
Where our advice, information or guidance relates to a statutory function, such as in our consumer service we rely on Data Protection Act 2018, Schedule 1, (6) ‘Statutory etc and government purposes’. This condition also applies to criminal offence data
Article 9(2)(g) – substantial public interest (counselling)
Where our advice, information or guidance relates to confidential wellbeing support. For example, if supporting a client with issues relating to loneliness. The specific substantial public interest condition we rely on is in Data Protection Act 2018, Schedule 1, (17) ‘Counselling etc’. This condition also applies to special category data and criminal offence data.
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
Surveys – electronic or hard copy
What information we collect
Feedback on our service.
Clients have the option to provide their contact details should they wish.
What we use your information for
To support research, campaigns and to get client satisfaction data.
Who we share your information with
Anonymous data is provided to funders and for research and campaigning opportunities. With explicit consent, client stories may be shared more widely (media and with funders).
Our lawful basis for using your information
Article 9(2)(j) Archiving, research and statistics
As per the A6 condition.
How we use your data for fundraising and donations
This section covers how we use your data to carry out our fundraising activities.
National Citizens Advice covers their use of data for fundraising in their privacy notice.
How we collect your information
Via online donation tools asking for personal data, donation envelopes, through campaigns offering people to join our mailing list for service updates and fundraising campaigns.
What information we collect
Name and contact details.
What we use your information for
To contact you with the information you have consented to being sent to you.
Who we share your information with
No one external to the organisation.
Our lawful basis for using your information
Article 9(2)(j) Archiving, research and statistics
As per the A6 condition.
How we use your data when applying to work or volunteer
How we collect your information
Application form.
Microsoft Forms.
What information we collect
We collect personal and application information from staff and volunteer applicants, including contact details, bank details, so we can pay any expenses/wages incurred, employment or volunteering history, references, right‑to‑work and safeguarding checks (such as DBS where required), and equality‑monitoring data. This information is used only for recruitment, safeguarding, and monitoring purposes and is managed in line with data‑protection requirements.
What we use your information for
We use applicant information to recruit and select staff and volunteers safely and fairly, meet legal and safeguarding requirements, seek references, plan training and support, and monitor equality and diversity. Information is used only for these purposes and managed in line with data‑protection requirements.
Who we share your information with
It is shared with our HR company – Howden’s (paid staff only).
Our lawful basis for using your information
Legitimate interests (UK GDPR Article 6(1)(f))
Legal obligation (Article 6(1)(c))
Contract (Article 6(1)(b)) (for successful applicants)
Common Article 9 conditions for charities
(Article 9(2)(b))
(Article 9(2)(g)) + Data Protection Act 2018 Schedule 1
How we use your data when using our website
What information we collect
We use cookies to track aspects of user visits, including the length of a user’s visit, their browser and geographic location.
How we collect your information
We use cookies to collect your information. Further information about how we use cookies is detailed on our Cookie Policy. If you don’t want to receive cookies, you can change settings in your web browser so that your browser tells you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.
If you wish to restrict or block web browser cookies, the Help function within your browser should tell you how.
What we use your information for
We use your anonymised data to help improve our website.
Who we share your information with
Your anonymised data is stored with our third party website provider.
Our lawful basis for using your information
Article 6(1)(f) – Legitimate interests
We have a legitimate interest as an organisation to ensure that we are meeting appropriate quality and standards in our web-based information and services to clients.
How we use cookies on our website
A ‘cookie’ is a small text file saved on your computer that is used to store information. The Citizens Advice Torbay website only uses an anonymous cookie, which ensures the content of page loads quickly and effectively by distributing the workload across several computers.
Google Analytics collects information by putting cookies on your device. Read more about how Google Analytics uses cookies.
If you don’t want Google Analytics cookies added to your device, you can opt out from Google Analytics cookies.
You can find out more about cookies on the Information Commissioner’s Office (ICO) website.
What information we collect
We use cookies to track aspects of user visits, including the length of a user’s visit, their browser and geographic location.
How we collect your information
We use cookies to collect your information. Further information about how we use cookies is detailed on our Cookie Policy. If you don’t want to receive cookies, you can change settings in your web browser so that your browser tells you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.
If you wish to restrict or block web browser cookies, the Help function within your browser should tell you how.
What we use your information for
We use your anonymised data to help improve our website.
Who we share your information with
Your anonymised data is stored with our third party website provider
Our lawful basis for using your information
Article 6(1)(f) – Legitimate interests
We have a legitimate interest as an organisation to ensure that we are meeting appropriate quality and standards in our web-based information and services to clients.
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.
| Data | Purpose | Retention |
| Client information | Casework | 6 years |
| Client information from Citizens Advice consumer service | Casework and statistical analysis | 6 years followed by anonymisation |
| Client information for cases subject to serious complaint, insurance claim or other dispute | Support evidence for dispute | 16 years |
| Application forms/interview notes for paid and volunteer staff (including unsuccessful applications) | To ensure fair and transparent recruitment processes | 6 months from the date the application was received |
| Gift Aid donor information | Legal requirements for Gift Aid returns | 6 years |
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.
| Processor name | Activities | Data hosting location |
| Citizens Advice national systems | Advice delivery, case recording, reporting, and audit
|
UK & EEA (primarily Ireland / EU)
|
| Microsoft | Email and internal communication
Secure document storage and collaboration Systems administration and security
|
UK data centres (with some EU/EEA services)
|
| Who hosts our server? | Cosmic Digital Solutions | UK |
| Website hosting provider and who manages analytics | AmplifyME Web design | UK |
| Telephone system or VOIP provider
|
Concorde .co.uk
|
UK – No data access |
| Exeter City Council
|
Process staff payroll
|
UK |
| Howden’s HR | Advising and supporting with HR issues | UK
|
| Sage
|
Financial administration and reporting
|
UK‑hosted (for UK cloud products)
|
| UCheck | Disclosure and Barring Service (DBS) – Processing criminal‑record checks for staff and volunteers where required
|
UK |
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 sue.julyan@torbaycitizensadvice.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 [insert relevant email address].
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
