Privacy Notice

Norfolk Citizens Advice Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information. 

• Contact details 
• What information we collect, use, and why 
• Lawful bases and data protection rights 
• Where we get personal information from 
• How long we keep information 
• Who we share information with 
• Sharing information outside the UK 
• How to complain 

Contact details for data subjects: 

Telephone 0800 144 8848 

Email address a.matthews@ncab.org.uk 

What information we collect, use, and why 

We collect or use the following information to provide services and third party referrals: 

• Names and contact details 
• Gender 
• Pronoun preferences 
• Addresses 
• Date of birth 
• Emergency contact details 
• Health information (including medical conditions, test results, allergies, medical requirements and medical history) 
• Dietary information (including allergies and health conditions) 
• Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions) 
• Information about work, home and living conditions 
• Information about support requirements 
• Information about lifestyle, interests or personal history 
• Information about income and financial needs for funding or personal budget support 

With your express consent, which you may withdraw at any time, we also collect or use the following special category information as defined in the Data Protection Act to provide services and third party referrals.  This information is subject to additional protection due to its sensitive nature: 

• Health information 
• Marital status 
• Gender 
• Sexual orientation 
• Political opinions 
• Race and ethnic origin 
• Trade Union membership 
• Religious or philosophical opinions 
• Genetic and biometric data 
  

Where Special Category data is referred to in this notice it means the above listed categories.   

We collect or use the following personal information for research or archiving purposes: 

We also collect or use  special category information for research or archiving purposes. If used this information is anonymous.  This information is subject to additional protection due to its sensitive nature: 

We collect or use the following personal information for dealing with queries, complaints or claims: 

• Names and contact details 
• Address 
• Correspondence 

We also collect or use the following special category information for dealing with queries, complaints or claims.  This information is subject to additional protection due to its sensitive nature: Health.   

Lawful bases and data protection rights 

Under UK data protection law, we must have either a legal reason or your consent for collecting and using your personal information. There is a list of legal reasons in the UK GDPR. You can find out more about lawful bases on the ICO’s website. 

• You can ask us to send you copies of your personal information. You can ask for other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access. 
• If any of the information is incorrect you can ask us to correct or delete personal information you think is inaccurate or incorrect. You can ask us to delete or correct any inaccuracy 
• You can ask us to delete your personal information at any time. Read more about the right to erasure. 
• You can ask us to limit how we can use your personal information. Read more about the right to restriction of processing. 
• You may object to the processing of your personal data. Processing means storing, using, and reading   
• You can ask us to transfer the personal information you gave us to another organisation, or to you 
• When we use your consent to process your data you can withdraw your consent at any time either on the phone or in writing. 

If you make a request, we must respond to you without undue delay and in any event within one month. 

To make a request about the information we hold about you, please contact us using the contact details at the top of this privacy notice. 

Our lawful bases for the collection and use of your data 

Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third party referrals are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights apply, except the right to transfer. Our legitimate interests are: 
• The basis of the legitimate interest for using personal data is to improve the health and wellbeing of residents in Norfolk who are aged over 50 and in danger of falling and becoming injured. The information will be used by the data controllers (the data controllers are Norfolk Citizens Advice, AgeUK Norwich and Voluntary Norfolk) to produce personal proactive plans for data subjects to improve their physical health, mobility, and mental wellbeing and prevent possible falls and injury. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability. 

Our lawful bases for collecting or using personal information for research or archiving purposes are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 
• Personal data and Special category will be anonymised and used to shape health policy in the UK to reduce the need to over 50s to be a cost to the NHS as a result of injury through falls. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are: 

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time. 

Where we get personal information from 

• Directly from you 
• Family members or carers 
• Other health and care providers 
• Social services 
• Councils and other public sector organisations 

How long we keep information 

Norfolk Citizens Advice and our joint data controllers will store Personal data and Special category for 6 years after collection. 6 Years is required in the event a dispute arises between Norfolk Citizens Advice and its joint data controllers. 

Who we share information with 

Two other Joint data controllers 

We have a joint controller relationship with Voluntary Norfolk. We process your personal information with that joint controller for the following reason: We share client data with the above in order to fulfil services to data subjects via a funding agreement with Norfolk County Council. 

We also have a joint controller relationship with Age UK Norwich. We process your personal information with that joint controller for the following reason: See above paragraph referring to Voluntary Norfolk. 

Data processors 

Formagrid Inc. trading as Airtable 

This data processor does the following activities for us: Airtable will Store data subjects’ data securely within the European Union 

Others we share personal information with 

• Other health providers (eg GPs and consultants) 
• Care providers 
• Organisations we need to share information with for safeguarding reasons 
• Emergency services 

Sharing information outside the UK 

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place. 

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above. 

Organisation name:  Formagrid Inc, trading as Airtable 

Category of recipient:  Specialist data storage company 

Country the personal information is sent to:  EU, Frankfurt, Germany and Ireland. 

How the transfer complies with UK data protection law: The transfer mechanism used is that the data processor, Airtable, has incorporated the EU standard contractual clauses and the UK standard contractual clauses into its Data Processing Addendum. (DP Addendum)  
The DP Addendum is a contract in which Airtable (a company incorporated in the USA) agrees to be subject to and will comply with all EU, and UK Data Protection legislation. It incorporates the UK statutory Data Transfer Mechanism. This ensures that Data passing from the UK to the EU using a company incorporated outside the EU is transferred in compliance with UK and EU law. 

How to complain 

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF 

Helpline number: 0303 123 1113 

Website: https://www.ico.org.uk/make-a-complaint