Christians Against Poverty (CAP) is a national charity that aims to address poverty and its causes in the UK. We do this in partnership with local churches to provide a range of free services to members of the public, including debt help, job clubs, fresh start, life skills and money management courses. This privacy notice explains how we use any personal information we collect about you.
CAP has a legal duty to protect your information and provide you with information about the rights that you have. As we control how the information we collect will be used, the law refers to us as a “data controller”. Our registered address is Jubilee Mill, North Street, Bradford, BD1 4EW.
What personal information do we collect?
We collect information about you when you enquire about using any of our services, as part of us providing you with our service(s), or when you register an interest in supporting us. We will also collect information about you if you contact us to apply for a role working for CAP. Website usage information is collected using cookies. We will normally process your personal information on the basis that we have your consent to do so. We may also process some of your personal information on the basis that we believe there is a legitimate interest for us to do so.
Why do we collect this information?
Clients – we will initially use the information we collect from you to contact you to arrange an appointment, to provide you with details of our services in your area, or to enable you to use our online budgeting tool. We will then use your information to provide you with any service(s) we have agreed with you. As a faith-based charity, we may offer you our support through prayer, so we will record whether you are happy for us to do this so we can make sure we respect your wishes.
For Debt Help clients, we will use your financial information to advise you about how to deal with your debts and we may contact your creditors to make payment arrangements with them. For clients of other services, we will use your information to remain in contact with you for support, and record your ongoing progress.
We may use our clients’ information for the following legitimate interests: to contact you with information about other free services CAP offers that may be suitable for you, or to invite you to take part in research and feedback in relation to our services. We may also contact you to invite you to any free events (for example, client breaks) that we may run from time to time, if we consider that they might be suitable for you.
Supporters – we will use the information we collect from you, including your level of interest, support for us and location, to tell you more about our work. We will also thank you for your support, and invite you to continue to support us. We may also use your information to invite you to fundraising or other events, or to ask if you would be able to increase your support. We will also process your information on the basis of our legitimate interest to improve our fundraising strategies. This will include analysing the information we collect about you and using publicly available information to aid our understanding of our supporters, understand the level of potential donations, profile supporters into categories and help provide a personalised service to you on our website content and emails. We will always do this in compliance with the rules in relation to direct marketing, including those set out by the Fundraising Regulator.
Job applicants – we will use the information we collect from you to process and consider your application for a role at CAP. Your information will only be shared with our Human Resources department and other CAP staff who will be involved in the selection and recruitment process. We will only request a reference or a DBS disclosure with your prior consent.
Phone calls – we may record both inbound and outbound phone calls on the basis of our legitimate interest in monitoring our service and training our staff. If there is a dispute or misunderstanding about what was said during a telephone call, we may use call recordings to help clarify the contents of conversations we have had.
CCTV – we operate CCTV cameras on our Bradford head office site for the purpose of safeguarding the safety of our staff, visitors and property. We use these images on the basis of a legitimate interest in the prevention, investigation and detection of crime and for the prosecution of any offenders.
Market research and demographic data – We have a legitimate interest in ensuring we continue to improve, and we may use your contact details to contact you to ask for your comments and opinions on how we might improve and develop our services. We may also use your information to study and better understand the composition of our client and supporter base.
Corporate communications – We have a legitimate interest in building strong relationships with external companies that operate in sectors that we work in, and may store and use details of contacts at these companies to send regular communications. Any regular e-mail communications sent will include an unsubscribe link, and we will remove contact details on request.
When will we share your information?
If you are a client, we may obtain your consent to share your information with third parties so that we can provide you with our service – for example, by sharing debt help clients’ information with their creditors. We will not normally share any information we hold about you to others without your prior consent, unless one of the following exceptions apply:
- If it is necessary for law enforcement or similar purposes;
- For the legitimate interest of reviewing the quality of our services – for example, the Advice Services Alliance and the Money and Pensions Service may audit our Debt Help service. The regulator of our Debt Help service, the Financial Conduct Authority, also has the right to inspect our files. This includes information we hold about you, to ensure we are complying with their rules;
- As a necessary part of providing you with our service(s) or contacting you as a supporter - for example, by using a third party mailing house to process our communications;
- As a necessary part of ensuring we comply with our legal obligations as a data controller - for example, by using a third party to migrate data or ensure it is accurate and up-to-date;
When do we transfer your information out of the UK?
We will normally keep your information in the UK, but may transfer your information to other countries that have appropriate safeguards in place – for example, processors based in the European Union or the USA, where they are certified to the EU-US Privacy Shield. In particular, we may host your data on G-Suite servers operated by Google LLC which conform to the standards of the EU-US Privacy Shield.
How long do we keep your information for?
We will take all reasonable steps to ensure that the information we hold about you is kept secure. We will only hold your personal data for as long as it is required in line with our Data Retention Policy. Deleting your information may involve either the removal of the data or its anonymisation, meaning that it no longer continues to be personal data that will identify you. The following table sets out some of the main retention periods we have in place for the data we hold:
Type of data
Reason for retaining this long
Debt help client information
Up to 6 years from date case was closed
To allow for the defence of legal claims in line with the Limitation Act 1980
Other client information
3 years from date of last interaction
To allow us to analyse our client outcomes
6 years from date of last interaction
HMRC requirement in relation to Gift Aid records; to allow us to keep supporters informed of our work
Phone call recordings
2 years from date call recorded
Training and monitoring
Job application forms – if unsuccessful
Recommended practice by CIPD
Please contact us using the details below if you need further details about our retention policy, or to request that your data be deleted.
What are your rights over your information?
You have the following rights in relation to your information:
- You may withdraw consent where we are using your information on the basis of this
- You may object where we are using your information on legitimate interest grounds
- You can ask us what information we hold about you and can request a copy of this. There is normally no fee for this - unless a request is manifestly unfounded or excessive
- You can ask us to correct information we hold about you if it is inaccurate
- You can ask us to erase your information in some circumstances
- You can ask us to stop using your information for a period of time if you believe we are not doing so lawfully
To submit a request by email, post or telephone, please use the contact information provided below. We will deal with your request within one month, unless it is particularly complex, in which case we will contact you within one month to let you know that we may need a further two months to comply.
What information does our website collect?
- To establish the needs of visitors and customise the content of our website;
- To process any forms, requests or applications you send;
- For internal administration and analysis.
What is your right to complain?
If you have a complaint about CAP’s use of your information, you can contact the Information Commissioner’s Office via their website at ico.org/concerns or write to them at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By email: If you are a supporter, please contact firstname.lastname@example.org. Otherwise, you may contact us by email at email@example.com;
By phone: on 01274 760 720;
By post: Data Protection Officer, Christians Against Poverty, Jubilee Mill, North Street, Bradford, BD1 4EW.
For more information about your legal rights in relation to the information we hold about you, please visit the Information Commissioner’s Office at ico.org.uk.