Privacy Notice

IncomeMax 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). 

 

It applies to all clients, prospective clients, creditors and partners.

 

1. Who we are

We are IncomeMax 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

 

2. The purpose of this privacy notice

IncomeMax 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 IncomeMax 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	Household financial position including income, outgoings and debts and if relevant your energy supplier(s), water company, mortgage, rent and council tax details.
Contact/personal	Household names, where you live and how to contact you including residential address(es), email address(es), telephone number(s),  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, drivers 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, drivers licence, birth certificate or VISAs.

We may also collect, store and use the following "special categories" of more sensitive personal information. e.g.

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
• Trade union membership
• Information about your health, including any medical condition or disabilities, health and sickness records
• Information about criminal convictions and offences

 

We will only collect and use these types of data if the law allows us to do so.

 

5. 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 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

 

We may sometimes collect additional information from third parties we work with, these may consist of:

• Your creditors, debt recovery and supporting agencies
• Your energy and water suppliers
• DWP
• HMRC
• Local authorities
• Credit reference agencies
• Fraud prevention agencies
• Market researchers
• Government, regulators and law enforcement agencies.
• Charities and other organisations we work with
• Carers or health professionals

 

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 service you have agreed for us to provide

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

• 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 IncomeMax 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 IncomeMax 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

 

The bases permitted by law we rely on to process information

Information used	Our reasons	Our legitimate interests
Contact information  Health & wellbeing 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 Disability information 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	Fulfilling contracts Our legal duty Legitimate interests Consent	To provide the advice service  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

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

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 appropriate written policies 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
• 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.

 

9. Sharing of your data

We may share your data with third parties. We would only 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.

We require third parties to respect the security of your data and to treat it in accordance with the law.

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
• For the prevention and detection of crime
• To gain the required funding for the services we provide

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. 

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 info@incomemax.org.uk

 

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 info@incomemax.org.uk

 

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 info@incomemax.org.uk

 

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. We mainly keep your information for six years, to ensure we meet professional indemnity insurance requirements.

 

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 info@incomemax.org.uk 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.

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. 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 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 us.

 

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 us.

 

Version 1 - updated 25^th May 2018