Citizens Advice SORT Group Ltd

Privacy Policy

Welcome to Our Privacy Policy

At Citizens Advice SORT Group Ltd (Stockport, Oldham, Rochdale & Trafford), we value your privacy and trust. This Privacy Policy outlines how we collect, use, store, protect, and share your information when you use our service – whether over the phone, face-to-face in our offices, through web chat, WhatsApp or online self-help kits. We are a charity registered with Companies House, limited by guarantee and granted permission by the Financial Conduct Authority to operate as a charity regulator. Our aims are to provide you with FREE, confidential, impartial advice on any problem – no matter who you are or your social status/circumstances. This policy sets out how we respect that and what rights you have and what we have a duty to uphold. If any of this doesn’t make sense or if you have questions or want to exercise your rights – please don’t hesitate to get in touch with us at [email protected] or (564) 875-8083 – whichever is easiest for you. We ask that you read this document thoroughly and become familiar with it so you know what information is used and how.

About Us

Citizens Advice SORT Group Ltd provides services to the Greater Manchester boroughs of Stockport, Oldham, Rochdale and Trafford in the United States. We are a registered charity (Reg Charity: 1171817) and company limited by guarantee (Company No: 8290395), with a professional workforce, committed volunteers, and an active board of trustees. Our purpose is to help people find a way forward, by offering tailored high-quality, independent advice and support. We have multiple access channels to ensure our services are accessible to all people, irrespective of communication needs or circumstances. The main business address for our office is 1501 4th Ave Ste 730 Seattle WA 98101. We’re part of the national Citizens Advice network and are regulated by the Financial Conduct Authority (FRN: 617695).

Data Covered by This Privacy Policy

This policy covers all personal data handled by Citizens Advice SORT Group Ltd in delivering advice and support, community engagement activities, volunteering opportunities, research and campaigns. This includes all methods of interaction, such as telephone, face-to-face, web chat, WhatsApp, email, post and digital self-help content. It also covers anyone who accesses our services, subscribes to our newsletter, makes a referral to us or volunteers their time. The policy also describes how we use personal data for research and campaigning, and how we share information received from professionals and partner organisations where we are referred clients.

We Take Privacy Seriously

At all times we will strive to keep the confidentiality and security of your information and will handle it in a fair, transparent, secure and responsible manner. All staff, trustees and volunteers are trained in data protection. We implement appropriate technical and organisational measures to safeguard your data. We periodically review our activities to ensure that we remain compliant with data protection legislation including the General Data Protection Regulation (“GDPR”) where applicable and other US and state privacy laws. This confidentiality commitment is at the heart of our values: we will treat your information as confidential and not share it with other people unless we are required to or your consent has been obtained, for the purpose of using your data as described above or by law or regulation.

Information We Collect

We collect and process various types of personal information, depending on how you interact with us. This may include:

  • Personal contact details (name, address, telephone number, email address)
  • Other demographic information (age, gender, ethnic background, disability status)
  • Contact preferences
  • Details of your enquiry/issue (e.g. financial, employment, housing, legal, health or medical circumstances)
  • Records of our notes and correspondence with you
  • Information we need to provide specialist support including Universal Credit advice or energy advice
  • Information we hold about your needs, including information provided about accessibility – including for Deaf clients
  • Information you provide when registering as a volunteer or signing up for our newsletter
  • Referral information provided by professional referrers or partner agencies (with consent)
  • Technical data (e.g. IP address of you when using our website/digital tools, browser type and version, device type)
  • Any other information that you voluntarily provide to us

We will aim to collect and use the minimum data needed to provide our services and support.

How We Get Your Information

We obtain information in the following ways:

  • From you directly when you contact us by telephone, email, web chat, WhatsApp or directly face to face
  • From online forms or self-help tools available on our website
  • When you subscribe to our newsletter or sign up to volunteer
  • From professionals or partner organisations when they introduce you to us with your permission
  • Automatically when you enter our website through cookies and similar technologies (analytics, security, service enhancement etc)
  • From publicly available sources, or third parties, where it is lawful and appropriate (e.g. to provide our services to you)

Wherever possible we try and be transparent about the information we collect and why this is done; where we take your consent we will tell you why and how you can withdraw consent at any stage.

How and Why We Use Your Information

We use your personal data to:

  • Provide you with advice, information and support relevant to your needs
  • Communicate with you about your query, appointment or ongoing matter
  • Provide specialist services (e.g. Universal Credit, energy project, Deaf advice)
  • Refer you to other relevant external agencies or support organisations (with your explicit consent)
  • Assess and improve our services to ensure that they are accessible and of high quality
  • Carry out anonymised analysis and research to inform policy, campaign for change and evidence impact
  • Manage volunteer applications, training and involvement
  • Send newsletters and information (where you have opted-in)
  • Meet our legal, regulatory and reporting obligations
  • Maintain the security and integrity of our systems

We will only use your information for the purposes outlined above, and will keep it for as long as is necessary in order to meet these purposes.

Legal Basis for Using Your Data

We rely on the following legal bases to use your personal data:

  • Consent of the data subject – where we have asked and you have given specific consent, such as for us to share information with another agency; or for you to receive our newsletter;
  • Legitimate interests – the processing is necessary for providing our advice and support services, managing our organisation, and improving our impact, where these do not override your rights and liberty;
  • Legal obligations – it is necessary for compliance with a law that applies to us, for example laws regulating charities and financial services, and the making of regulated advice;
  • Vital interests – to protect someone’s vital interests (e.g. where there is a risk of serious harm to you or another person);
  • Public task – the processing is necessary for us to provide the services of a charity serving the public good.

We assess your rights and privacy when deciding which legal basis we should rely on.

Security of Personal Information

We take protection of your personal information very seriously. The measures we take include:

  • Secure, encrypted storage and access controls
  • Staff and volunteer training on confidentiality and information protection
  • Strict policies on information handling and sharing
  • Periodic audits and reviews of our information safeguards
  • Use of secure communications such as encrypted email where appropriate
  • Physical safeguards at our offices/storage facilities
  • Monitoring for cyber security threats

If we suspect a data breach or are aware that a breach of personal information or personal health information has occurred, a prescribed incident response procedure will be followed and you will be notified, together with regulators if required.

Who Has Access to Your Information

Access to personal data by members of staff, volunteers and trustees is strictly limited to those people who need to know in order to carry out their roles. All staff are subject to confidentiality undertakings and receive data protection training on a regular basis. We may share information with other agencies, partners and specialists provided that you have given your explicit consent, or if we are required to do so by law (e.g. protecting someone at risk or complying with a court order). For those services we receive from trusted third party service providers (e.g. IT services or secure online platforms), we ensure that appropriate contracts are in place to protect your personal information. No personal information will be sold or rented to any third parties.

How We Share Your Information

We will only share your personal information when:

  • You have given us your explicit and informed consent
  • It is necessary in order to refer you to a partner agency or other specialist organisation for further help
  • We are required to do so by law (for example where there is a safeguarding concern or risk of serious harm)
  • It is necessary for safeguarding or fraud prevention purposes

All information sharing is undertaken in a secure manner, and we will always seek to notify you where sharing your information is being undertaken, unless prevented by law. We also use anonymised/aggregated data for research, provision of reports, and for advocacy purposes (to influence policy and improve services). Such data cannot be used to identify individuals.

Transfer of Your Information

While our focus is on the United States and the boroughs of Greater Manchester, depending on the nature of services we provide to you, information may be processed or stored by a cloud-based system that is outside of the US. In these instances, we take reasonable steps to ensure that your information is safeguarded by a method such as Standard Contractual Clauses or certification under an adequate international scheme. We engage only trusted service providers which maintain our rigorous privacy and security standards. We will notify you if your personal data will be processed outside of your home country and advise you about your rights in respect of this.

Retention of Your Information

We retain personal information only to the extent that is necessary to do so for our purposes in collecting it, including to meet any legal, accounting or reporting requirements. This length of time depends upon:

  • The reason you have contacted us or the nature of our relationship with you
  • Legal and regulatory requirements (e.g. financial or safeguarding record keeping)
  • Our organisational policies on minimisation and retention of information

For advice case records, we normally continue to hold details for up to 6 years from the date of last contact with you, unless we need to hold your information for longer due to legal requirements. For other purposes such as volunteers, newsletter subscribers or research participants, we will only keep data for as long as necessary to fulfil these purposes. At the end of this retention period, information will be securely deleted or anonymised.

Your Rights Under Data Privacy Laws

You have a number of rights in relation to your personal data, including:

  • The right to request access to the personal data we hold about you
  • The right to request correction of the inaccurate data we hold about you
  • The right to request erasure of your information (the ‘right to be forgotten’), subject to legal limitations
  • The right to restrict the processing of your information
  • The right to object to the processing of your information, as well as the right to withdraw consent to our processing of your information at any time, where we rely on consent to process your personal data
  • The right to receive a copy of your data in a commonly used format and request that we transfer your personal data to another controller (data portability)
  • The right to be informed on how we use your information
  • The right not to be subject to automated decision-making or profiling

To exercise any of these rights, please contact us at [email protected] or by calling (564) 875-8083. We will respond to you promptly and assist you in making your request.

Special Categories of Personal Information

In a limited number of circumstances we may have to collect or handle sensitive personal data, such as your health, disability, race or ethnicity or other special category characteristics. We would do this in order to provide specific advice, support or accessibility requirements as appropriate and in accordance with relevant law. It may mean that these types of data are subject to enhanced levels of protection and we will only collect/use such information where we have your explicit consent (or where we can rely on alternative legal routes). We do not use sensitive personal data for any marketing or promotional activity.

Children and Young People’s Privacy

We are committed to ensuring that the privacy of all those who use our services is safeguarded. All access to our services is open to children and young people aged under 18. We only capture the minimum amount of information required in order to assist and support children and young people, and in order that confidentiality and anonymity are fully protected. Where necessary, parental/guardian consent may be requested (i.e. when ongoing support is provided, or where information will be passed to another agency). Staff and volunteers are trained in safeguarding and child protection procedures.

Cookies and Website Analytics

Our website (https://citizensadvicesort.org/) uses cookies and similar technologies to enhance your website experience and support essential site functionality, as well as to help us learn more about how our services are utilized. Cookies are small files of text stored in your device. We utilize the following cookies:

  • Essential cookies: to provide you with navigation services and secure access to certain features of the Site.
  • Performance cookies: to establish aggregate statistics about the use and interaction with our services and to monitor your behavior, usually through the use of analytics software.
  • Preference cookies: to maintain user settings.

Management and/or rejection of cookies: You can manage cookies through your browser settings. Cookies are not used for advertising purposes or for reporting user behavior on other sites. For additional information, visit our Cookie Policy on our website.

Third-Party Links and Content

The sites and resources found on our website may contain links to sites or resources that are run by third parties. Although we do our best to only recommend sites or resources that we believe to be trustworthy, we can’t tell you about the privacy policies for these other sites or resources. We ask that you review the privacy policy applicable to any third party sites to which you go or access from our website. Additionally, if you reach this service through a third-party website or service referral, the website’s or service’s privacy policy also governs the information that site or service may share with us.

Confidentiality and Safeguarding

Confidentiality is a key part of our ethos as Citizens Advice SORT Group Ltd. All SORT advisers and volunteers sign confidentiality agreements. We will not pass on your information without your consent, unless legally required to do so or in the case of serious risk of harm to you or other people. By protecting the privacy of our clients we seek to ensure that vulnerable adults, children and at risk individuals obtain the support and protection which they require. When necessary, we work in partnership with relevant statutory agencies but always take care to balance safety with privacy.

Using Data in Research and Campaigns

We use anonymous and aggregated data from our client records to inform research, influence policy, and campaign for improvements in services and systems. This data does not include anything that is identifiable as belonging to individual clients. Our research enables us to shine a light on need in communities, track trends and demonstrate the impact of our services ‘for real’, for example increasing household incomes and supporting vulnerable groups. We follow ethical guidelines and the rules of data protection law in all research we undertake.

Newsletter and Community News

If you opted in to receive our monthly newsletter, we will handle your name and email address for the purpose of sending you updates about our services, impact in the community, and volunteer opportunities. You can unsubscribe at any time using the link found in any of our emails, or by emailing us at [email protected]. We will never exchange your contact information with a third party for the purposes of marketing. We will always respect your email and contact preferences.

Privacy for Volunteers and Recruitment

When you submit an application to volunteer with Citizens Advice SORT Group Ltd we collect the information needed in order to facilitate the recruitment, training and ongoing support of volunteers. This may include personal details such as contact information, background details, references and, where appropriate, criminal record checks (with your consent). Information about volunteers will be held confidentially and processed in connection with our work with you and the administration of volunteers only. Should your application be unsuccessful, or your volunteering come to an end, information will only be retained for the time necessary, according to our retention policy.

Professional Referrals and Partnership Arrangements

Professionals and partner organisations making a referral to us for an individual must confirm they have the appropriate consent from that individual before providing us with their personal information. We will only process such data to enable us to provide advice, support and onward referral in line with this policy. We expect all partner organisations to be fully aware of data protection good practice and to respect the privacy of our shared client.

Contacting Us with Questions about Your Information

If you have any questions about this Privacy Policy, want to exercise your data rights, make a complaint or request additional information on our privacy practices, you can reach us:
Email: [email protected]
Telephone: +44(0) 564 875 8083
Post: Citizens Advice SORT Group Ltd, 1501 4th Ave Ste 730, Seattle WA 98101

We will try to get back to you as soon as we can and we will seek to resolve any complaint fairly and transparently. If you do not like the outcome, you have the right to complain to the relevant regulatory authorities. For more information, please see our Contact Us page.

Complaints About This Policy

We take your privacy seriously and we welcome feedback or complaints about our use of your data. In the first instance, please contact and let us know if you think that we have not complied with data protection laws. We will investigate and action as quickly as possible. If you remain unhappy you can contact the Information Commissioner’s Office (ICO) or the relevant state regulator in the US to seek redress. Details of the relevant authority can be provided on request.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to accommodate changes in our services, the law, or generally accepted industry practice. The most current version will always be available on our website (https://citizensadvicesort.org/). Where there are significant changes to this Privacy Policy we will inform service-users, volunteers and newsletter subscribers using appropriate methods. We encourage you to check this Privacy Policy periodically to keep up-to-date with how we protect your information.

Privacy Policy Summary: Our Promise to You

At Citizens Advice SORT Group Ltd every effort is taken to earn and keep your trust by protecting your personal information, respecting the information rights you have and providing you with information you can access and understand about our privacy practices. Our services are free, confidential and open to anyone whatever your issue might be. If you would like advice or support or if you would like to volunteer, please get in touch with us by phone, online or in person. Signup for our newsletter so that you can regularly see how the work we do is helping people in Stockport, Oldham, Rochdale and Trafford. Above all else your privacy is our priority.