Privacy Notice

PRIVACY NOTICE

Income Max are committed to protecting the privacy and security of your personal information.

This privacy notice explains how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).  

1. Who we are

We are Income Max CIC, a community interest company.

Our Registered Office: 41 – 43 Brentwood Road, Romford RM1 2EU

Our website: www.incomemax.org.uk

Our email: info@incomemax.org.uk

Our telephone number: 0300 777 7772

Registered in England no. 07023661

Authorised and regulated by the Financial Conduct Authority. Reference 618767

Information Commissioners Office Registration No. Z2193255

We know that life happens but believe there is always a step forward. We provide independent personal money advice for the real world that helps you take control of your finances.

Income Max has helped thousands of households manage their finances and we know how to help real people. We never charge you for our service. Our costs are covered by the Partner that refers you to us or through other funding we receive.

2. The purpose of this privacy notice

Customers who we advise

This Privacy notice applies to this website and as a general statement when Income Max acts a Data Controller. This means that on some occasions 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.

In most cases Income Max acts as a Data Processor. This means that we process personal information about you on another Data Controller's (our Partner) behalf and instruction. Organizations that may refer you to Income Max include your bank, utility company or other financial services firms. The remainder of this website Privacy Notice may not wholly apply. Please contact the Partner, or us, directly for information about the processing of your data. You may have already been provided with a Privacy Notice specific to your referral.

 

Website Contact form users

This Privacy Notice applies if you complete the contact form on our website to the extent that we only receive your name and contact details. We will use your email address to send you information about Income Max and our services. You can stop receiving emails by selecting the unsubscribe option in any email we send you.

 

 

 

 

 

3. 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).

We will collect, store, and use the following categories of personal information about you:

Personal information	Description
Financial	Household financial position including income, outgoings and debts and if relevant your energy suppliers, water company, mortgage, rent and council tax details.
Contact/personal	Household names, where you live and how to contact you including residential addresses, email addresses, telephone numbers, dates 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 & 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 benefit letters, bills, or photocopies/scans of things like your passport, driver’s licence, birth certificate, VISA’s, regulatory checks, letters of authority, bank statements and income verifications
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, driver’s licence, birth certificate or VISAs.

We will also collect, store and use the following special categories of more sensitive personal information where it is relevant to your financial circumstances. e.g.

• Information about your health, including any medical condition or disabilities, health and sickness records
• Trade union membership  

4. How is your personal information collected?

We may collect personal information about you and your household. We will only collect information that we need to carry out the purpose of processing that information:

Data passed to us by the organisation who refers you to us (another Data Controller):

• Your name
• Contact information such as telephone number and email
• Your address and/or postcode
• The reason you have been referred to Income Max

Data you give to us:

• When you use our products and services
• When you talk to us on the phone or face-to-face
• When you use our website or web chat
• In emails and letters
• In feedback or marketing surveys  

5. How we will use information about you

• To provide you with advice related to benefit entitlements and other income you may be eligible for, including charitable grants, help with energy and water bills and ways to save money
• To ensure Income Max is compliant with the regulations under which it is governed, through its governance and risk management
• To ensure we understand any additional assistance you may need throughout your journey through the services offered
• To ensure Income Max provides you with an appropriate service
• To ensure our colleagues process your information correctly and accurately
• To ensure personal data is securely disposed of
• To ensure our marketing materials and surveys are appropriate for you
• To ensure we provide you with an appropriate advice service
• To ensure our relationships with third parties are managed in order to provide our services
• To ensure our services are suitable and sustainable

 

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to provide our service.

 

 

 

 

The bases permitted by law we rely on to process information 

Information used	Our reasons	Explanation
Contact information  Income information Outgoings information Information on debts Information on rent, mortgage, council tax and housing status Other household information e.g. ages of children and non-dependents and other info relating to household members which we need in order to carry out our service Case information e.g. case notes, benefit calculations, advice provided, case updates including estimated and confirmed income increases/bill savings and social impact of the service Documentation Financial information	Our Legitimate Interests	To provide the advice service to your benefit To assess vulnerability To maintain regulatory compliance To provide reports to contracting partners on the effectiveness of the service To ensure our current and future services are suitable To provide our colleagues with your feedback To ensure our service was acceptable to you
Sensitive Personal Data Health & wellbeing information Disability information Trade Union Membership Race, religion and ethnicity	We process Sensitive Personal Data that you share with us with your Consent.   When we receive health data and we haven’t had chance to gain your consent we will process this to safeguard your economic wellbeing (Data Protection Act 2018 Schedule 1, part 2, para 19). This includes where the data relates to other members of your household or family. We have a policy in place to deal with this.	We will use your sensitive personal data in the following ways: When assessing your needs for support When giving you advice about benefits you are, or maybe, entitled to as a result of your health or medical conditions To gain the required funding for the services we provide

 

6. Sharing of your data

Where we act as a Data Controller, we may share your data, in the form of a report of the outcome of our service, with the Organisation that originally referred you to Income Max.

Some work we do involves auditing the Warm Home Discount Scheme. We pass the results of these audits to Ofgem (Office of Gas & Electricity Markets) who administer certain elements of the scheme on behalf of the Government. The data we share with them uses a reference number and does not include your name.

We will never sell or share your data for marketing purposes.

Transferring information outside the EEA

We may transfer the personal information we collect about you outside of the European Economic Area (EEA). However, we always ensure that your personal information receives an adequate level of protection and 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. 

If you require further information about these appropriate protective measures, you can request it from info@Income Max.org.uk

 

7. How we protect your data

We have put in place measures to protect the security of your information.

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.

When we share data with a Partner or Ofgem we always use secure or encrypted methods.

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.

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.

 

8. 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. We mainly keep your information for six years beyond the completion of our service, to protect ourselves from legal claims.

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.

 

9. 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. This means that if we have provided you with advice, we will erase your information as stated in section 8 of this notice. If we have not provided you with advice and you want us to delete the limited information we hold, you can do so at any time.
• 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.
• Object to or Restrict processing. You can request us to stop or pause processing your information if we are about to start, or we are part way through, delivering our service to you.
• 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 info@Income Max.org.uk 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.

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 repetitive or excessive.

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 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. 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.

10. Complaints

If you wish to complain to Income Max about the processing of your data, please email us at info@Income Max.org.uk

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

11. Changes to this notice

We reserve the right to update this privacy notice at any time. 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 us.

 

Version 3 - updated April 2019