Money Advice Plus is registered with the Information Commissioners Office (ICO). Our registration number is Z5736768
Money Advice Plus is committed to good practice in the handling of personal data and we are compliant with the requirements of the Data Protection Act (2018).
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Information about sharing personal data
More information about your circumstances, for example mental health problems or other difficulties can help us to work with you better. If you tell us about specific needs which you have, we will record the information on your file and will check with you how we can tailor our service to accommodate any needs. You can be confident that we will not share this information without explicit consent from you to do so.
Money Advice Plus is the “data controller”, that means we are responsible for deciding what data we need to collect, how we store and process it. We keep your personal data in our offices and databases.
This information applies to any client of Money Advice Plus. Where we have received data relating to an individual who does not become a client (eg a referral where the person referred declines an appointment) we keep the data for as long as is required to track the progress of the referral, and provide feedback to the referrer where appropriate.
Processing Your Data
Personal Data is used to provide reports to funders on what we are doing. For example, for some projects we are required to say what percentage of our clients are in different age ranges, and what their genders are. When we make reports, we take out information which could identify individuals (eg addresses, names etc). If a funder asks us to provide a report that could identify individual clients, then you will be separately notified and we will not share this information without explicit permission.
We also process information for our own internal reports, eg equalities monitoring, to check that we are providing a service that is accessible to all sections of our community.
Categories of Data
Much of the data that we hold is necessary in order that we can provide a full advice service relevant to the individual circumstances of each client. We need to retain this after the end of our work with an individual, so that we can check the accuracy & quality of advice given, and in case we are contacted with any questions or complaints after the end of our work. This is in line with recommended advice sector best practice.
This includes information that you give us when we speak with you, and also information provided by others (eg if you have been referred to us, information provided on the referral form) such as:
Your name, address, and date of birth, previous addresses etc
Information about your financial situation, any debts, income expenditure etc
People who live with you
Anything else you tell us that is relevant to your case or the support and advice we can give you
There is also a small amount of data which we collect and hold solely because we are required to report about it. This data is collected separately on an equal opportunities monitoring form, and clients are given the option to withhold all or any of this information, without it affecting the service that we provide.
Each year we review what categories of data we collect and hold on our database, and check that it is still required for a good reason.
We are mindful that 2 pieces of data that alone do not identify a client may do so when pieced together: eg if a client’s postcode is shared together with details of their medical condition. The data controller checks report formats to ensure that client confidentiality will not be breached by reporting and that data cannot be pieced together in this way.
Sources of Data
Most data is provided directly by clients. Some data is provided at the point of referral by a third party. We ask referrers to satisfy themselves that they have gained consent to share data with us.
Personal data is never transferred from Money Advice Plus without explicit consent for information sharing from a client, and as is necessary to do work (eg with your permission we might send information required to make a referral to another agency) or in specific circumstances without consent (eg safeguarding: see our confidentiality policy).
Data is never transferred outside the EU.
On occasion we may contract outside agencies to process data on our behalf. We may also share data with our database support service, for the purpose of identifying systemic faults in the database. We follow our confidentiality policy and before data is shared for either of these purposes we must be satisfied that the outside agency has arrangements to securely store the data and dispose of it properly as soon as the work is completed.
Retention of Data
In accordance with recommended advice sector best practice all data is stored for 7 years after the end of our work with a client, except those kept longer: see below.
The following are stored for 14 years:
All cases at closure where there has been a complaint, or a case involving significant corrective action
During the 7 year storage period, when a client or representative contacts us with a significant question or complaint
When cases are identified by casework supervisors as concerning unusual or novel points of law, at the point of closure, or when checking closed files
When a client dies and we have been unable to contact any next of kin, and we are left holding a residual estate.
Clients are advised of the storage period and how to access their closed files during that time in the closing letter.