StepChange is committed to protecting the privacy and security of your personal information.
Our privacy notice describes how we collect and use personal information about you during and after your client relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all clients, prospective clients, creditors and partners.
1. Who we are
Foundation for Credit Counselling
Trading as StepChange Debt Charity and StepChange Debt Charity Scotland
Registered Office:
123 Albion Street
Leeds
LS2 8ER
Registered In England no. 2757055
Registered charity in England and Wales: 1016630, Scotland: SC046263, Ireland: 20104887
Authorised and regulated by the Financial Conduct Authority.
Consumer Credit Counselling Service Voluntary Arrangements Limited
Trading as StepChange Voluntary Arrangements
Registered Office as above
Registered in England no. 5659160
Consumer Credit Counselling Service Equity Release Limited
Trading as StepChange Financial Solutions
Registered Office as above
Registered in England no. 6741879
2. What is the purpose of the privacy notice?
StepChange is a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
At times StepChange acts as a “Data Processor”. This means that we process personal information about you on another Data Controller’s behalf and instruction. We will only do so where the Data Controller has explicit consent to share your information with us for a specified purpose(s).
This notice applies to all clients, prospective clients, creditors and partners. This notice does not form part of any contract with you. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
3. Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes
4. Accurate and kept up to date
5. Kept only as long as necessary for the purposes we have told you about
6. Kept securely
4. The kind of information we hold about you
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).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
| Personal information | Description |
|---|---|
| Financial | Your financial position, status, financial transactions, income and outgoings and history. |
| Contact/personal | Your name, where you live and how to contact you (including residential address(es), email address(es) and telephone number(s)). It also includes your date of birth/age. |
| Socio-demographic | This includes details about your work or profession, nationality, education and where you fit into general social or income groupings. |
| Transactional | Details about the products or services we provide to you. |
| Contractual | Data we get about where you are, such as may come from your mobile phone and the address where you connect a computer to the internet. |
| Locational | Data we get about where you are, such as may come from your mobile phone and the address where you connect a computer to the internet. |
| Behavioural | Details about how you use our products and services. |
| Technical | Details on the devices and technology you use. |
| Communications | What we learn about you from letters, emails, texts, social media and conversations between us |
| Social Relationships | Your family, friends, and other relationships. |
| Open Data and Public Records | Details about you that are in public records such as the Electoral Register, and information about you that is openly available on the internet. |
| Documentary Data | Documents that contain details about you (stored in different formats, or copies of them). This could include photographs, videos, pictures or photocopies of things like your passport, drivers licence, birth certificate, VISA’s, regulatory checks, letters of authority, bank statements, income verifications, signed plan agreements and direct debit mandates. |
| Consents | Documentation where specific permissions, consents or preferences are required and given Such preferences could include; things like how you want us to contact you or if you require different print formats. |
| National Identifier | A number or code given to you by a public authority to identify who you are, such as a National Insurance number. This could include data contained within things like your passport, drivers licence, birth certificate or VISAs. |
We may also collect, store and use the following “special categories” of more sensitive personal information. We will only collect and use these types of data if the law allows us to do so.
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
- Trade union membership
- Information about your health, including any medical condition, health and sickness records
- Information about criminal convictions and offences
5. How is your personal information collected?
We may collect personal information about you (or your business) from companies within StepChange listed under the heading “Who we are” and from these sources. We will only collect information that we need to carry out the purpose of processing that information:
Data you give to us:
- When you apply for our products and services
- When you talk to us on the phone
- When you use our websites, Debt Advice, Debt Remedy or other financial advice or solution application or web chat
- In emails and letters
- In financial reviews
- In feedback or marketing surveys
We may sometimes collect additional information from third parties we work with, these may consist of:
- Companies that introduce you to us
- Your creditors and debt recovery agencies
- Financial advisers
- Card associations
- Credit reference agencies
- Insurers
- Retailers
- Fraud prevention agencies
- Market researchers
- Government, regulators and law enforcement agencies.
6. How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform a contract we have entered into with you
2. Where we need to comply with a legal obligation
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. If we rely on our legitimate interests (or those of a third party), we will tell you what it is
4. Where we are required to process the information to comply with the law
5. Where you have given a freely given, specific, informed and unambiguous consent to the processing of your personal information for one or more specific purposes
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your vital interests (or someone else’s vital interests)
2. Where it is needed in the public interest or for official purposes
Purposes for which we will use your personal information
Here is a list of all the ways in which we may use your personal information, and which of the bases permitted by law we rely on to do so. This is also where we tell you what our legitimate interests are (if we rely on that basis).
To provide you with advice related to benefit entitlements
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Contact information
Health & wellbeing information |
Fulfilling contracts | To provide the advice service
To assess vulnerability |
To ensure StepChange is compliant with the regulations under which it is governed, through its governance and risk management
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Fulfilling contracts
Our legal duty |
To process financial transactions and reporting To provide the advice service To maintain regulatory compliance |
| Contact information | Fulfilling contracts
Our legal duty |
To process financial transactions and reporting
To provide the advice service To maintain regulatory compliance |
| Documentation | Our legal duty | To maintain regulatory compliance |
| Financial information Health & wellbeing information |
Our legal duty | To process financial transactions and reporting
To provide the advice service To maintain regulatory compliance |
To ensure we understand any additional assistance you may need throughout your journey through the services offered
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Contact information
Health & wellbeing information |
Consent | To assess vulnerability |
To ensure StepChange provides you with an appropriate debt advice service
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Fulfilling contracts | To provide the advice service |
| Budget information | Our legal duty | To process financial transactions and reporting |
| Budget information | Legitimate Interests | To provide the advice service |
| Contact information | Fulfilling contracts Our legal duty Legitimate Interests |
To provide the advice service To process financial transactions and reporting To maintain regulatory compliance |
| Documentation | Fulfilling contracts | To provide the advice service To process financial transactions and reporting To maintain regulatory compliance |
| Documentation | Legitimate Interests | To provide the advice service To process financial transactions and reporting |
| Financial information | Fulfilling contracts Our legal duty Legitimate Interests |
To provide the advice service To process financial transactions and reporting To maintain regulatory compliance |
| Health & wellbeing information | Consent | To assess vulnerability |
| Health & wellbeing information | Fulfilling contracts Legitimate Interests |
To provide the advice service To assess vulnerability |
To ensure our colleagues process your information correctly and accurately
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Legitimate Interests | To process financial transactions and reporting To maintain regulatory compliance |
| Contact information | Our legal duty | To process financial transactions and reporting To maintain regulatory compliance |
| Contact information | Our legal duty | To provide the advice service To process financial transactions and reporting To maintain regulatory compliance |
| Documentation Financial information |
Legitimate Interests | To provide the advice service To process financial transactions and reportingTo maintain regulatory compliance |
| Health & wellbeing information | Legitimate Interests | To maintain regulatory compliance To assess vulnerability |
To ensure personal data is securely disposed of
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| All information | Legitimate Interests | To maintain regulatory compliance |
To ensure our marketing materials and surveys are appropriate for you
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Consent | To ensure our current and future services are suitable |
| Contact information | Consent | To ensure our current and future services are suitable To provide our colleagues with your feedback To ensure our service was acceptable to you |
| Health & wellbeing information | Consent | To ensure our current and future services are suitable To ensure our service was acceptable to you |
To ensure our financial solutions provide you with an appropriate advice service
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Fulfilling contracts | To provide the advice service To maintain regulatory compliance |
| Budget information | Legitimate interests | To provide the advice service To maintain regulatory compliance |
| Contact information | Consent | To provide the advice service |
| Contact information | Fulfilling contracts Legitimate interests |
To provide the advice service To process financial transactional information To maintain regulatory compliance |
| Documentation | Fulfilling contracts Legitimate interests |
To provide the advice service To process financial transactional information To maintain regulatory compliance |
| Financial information | Fulfilling contracts Legitimate interests |
To provide the advice service To process financial transactional information To maintain regulatory compliance |
| Health & wellbeing information | Fulfilling contracts Legitimate interests |
To provide the advice service To process financial transactional information To assess vulnerability |
To ensure our relationships with third parties (including creditors, debt recovery agents and market funders) are managed in order to provide the services
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Legitimate interests | To ensure our current and future services are available |
| Contact information | Legitimate interests | To ensure our current and future services are available To ensure the charity is funded for the work it does To maintain regulatory compliance To ensure our current and future services are suitable |
To ensure our services are suitable and sustainable through research and analysis
| Information used | Our reasons | Our legitimate interests |
|---|---|---|
| Budget information | Consent | To ensure our current and future services are available |
| Budget Information | Fulfilling contracts Legitimate interests |
To ensure our current and future services are suitable |
| Contact information | Consent | To ensure our current and future services are suitable To review other areas within the market where StepChange can assist in providing debt advice, education and financial solution |
| Contact information | Public interest/ exercise of official authority | To allow the StepChange to lobby parliament and ensure social policy is given a sufficient voice for you and other persons affected by problem debt, requiring debt or financial solutions |
| Contact information | Legitimate interests | To ensure our current and future services are suitable |
| Documentation | Consent | To ensure our current and future services are suitable To review other areas within the market where StepChange can assist in providing debt advice, education and financial solution |
| Documentation | Legitimate interests | To ensure our current and future services are suitable |
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide our services for example; debt management plans may need to be cancelled or revoked and applications for mortgages, debt relief orders, individual voluntary arrangements, bankruptcy orders may be delayed or terminated.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
We have in place an appropriate written policy document and safeguards which we are required by law to maintain when processing such data.
7. Our obligations to you and your information
We will use your sensitive personal information in the following ways:
- When assessing your needs for support
- When giving you advice and finding an appropriate solution
- To gain the required funding for the services we provide
Do we need your consent?
We may approach you for your explicit consent to allow us to process certain particularly sensitive personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
You should be aware that, there are circumstances permitted by law where we may use particularly sensitive personal data without your consent.
8. Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
9. Sharing of your data
We may share your data with third parties, including third-party service providers and the entities within StepChange listed under the heading “Who we are”.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the European Economic Area. If we do, we ensure the same degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). The activities listed under the heading “What about other third parties” involve processing by third parties.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with entities within StepChange?
The entities within StepChange listed under the heading “Who we are” may share personal information with each other as part of providing Debt Advice, Debt Remedy and/or other financial advice or solutions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of:
- Archiving and disposal of information
- For auditing and regulatory requirements
- For quality management purposes
- To compile statistics and undertake research/surveys
- To provide our services (including obtaining an accurate picture of the financial position of our clients and processing payments)
- To provide you with printed materials
- For the provision of our online application system where it is not hosted by StepChange
- For the prevention and detection of crime
- To gain the required funding for the services we provide
- To verify the identity of and/or attempting to trace our clients
We may also need to share your personal information with regulators such as the Charity Commission, the Financial Conduct Authority, the Insolvency Practitioners Association and the Information Commissioner’s Office, or to otherwise comply with the law.
Transferring information outside the EEA
We do not routinely transfer the personal information we collect about you outside of the European Economic Area (EEA). However, in the event that we did, to ensure that your personal information does receive an adequate level of protection we will put in place appropriate protective measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
Appropriate specific protective measure(s) include, for example, model contractual clauses and security assessments. If you require further information about these appropriate protective measures, you can request it from dpo@stepchange.org.
10. How we protect your data
We have put in place measures to protect the security of your information. Details of these measures are available upon request from dpo@stepchange.org
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure
We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from dpo@stepchange.org.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11. How long we retain your data for
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from dpo@Stepchange.org.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention policy and/or applicable laws and regulations.
12. What your rights are: rights of access, rectification, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. This request would need to be in writing.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no legal reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). This request would need to be in writing.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request a copy of your personal information for transfer to another party.
If you want to request a copy of the personal information we hold about you, or request erasure of your personal information, please contact customerrelations@stepchange.org in writing detailing your request.
If you want to review, verify, correct your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using your usual method or email customerrelations@stepchange.org
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. You will be informed of this in writing, where this is the case.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your explicit consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact us or use the appropriate unsubscribe links available. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so in law.
13. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Find out on their website how to report a concern or call the ICO helpline on 0303 123 1113.
14. Changes to this notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates that would affect your rights or how we process your personal data. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact dpo@stepchange.org
Version 1.0 – updated 25/05/2018