Privacy and Usage Policy

Christians Against Poverty is committed to respecting and protecting your privacy. This privacy policy sets out how Christians Against Poverty uses and protects any information that you give us.

As Christians Against Poverty is committed to ensuring that your privacy is protected we ask you to provide certain information by which you can be identified when you access our service. You can then be assured that it will only be used in accordance with this privacy policy.

Christians Against Poverty holds and processes personal details in accordance with the Data Protection Act 1998 and is registered with the Information Commissioner, as data controller.

Christians Against Poverty includes the derivatives CAP Debt Help, CAP Money Course, CAP Money Plus, CAP Money Ministers, CAP Money Students, CAP Money Youth, CAP Release Groups, CAP Life Skills and CAP Job Clubs, which are part of the CAP franchise and brand and are included in this policy statement.

Christians Against Poverty will from time to time make changes to this statement by updating this page. Please make sure that you check regularly to see what’s changed and to ensure that you are happy with any changes. This policy is effective from 19 April 2016

Personal Details – The Information that we collect

CAP Debt Help – Our Debt Counselling Service through our Centre Network and Head Office.

As a client - if you do elect to follow the advice offered by Christians Against Poverty, your personal details will be required to enable us to contact you. Your consent will be required before you proceed. We will keep your personal information confidential and secure and we will only use this data to provide you with the services requested.

We will collect the following information:

• Your name and those of your immediate family who live with you
• Your job title
• Contact information – including address, landline and mobile telephone numbers and email addresses
• Other information relevant to our Debt Counselling service

CAP Money Plus and CAP Money Ministers – Our Online Debt Counselling Service

As a CAP Money Plus or CAP Money Ministers client - if you do elect to follow the advice offered by Christians Against Poverty through our online debt counselling service, your personal details will be required to enable us to contact you. Your consent will be required before you proceed. We will keep your personal information confidential and secure and we will only use this data to provide you with the services requested.

We will collect the following information:

• Your name and those of your immediate family who live with you
• Your job title
• Contact information – including address, landline and mobile telephone numbers and email addresses
• Other information relevant to our online Debt Counselling service

How we will use your information

When CAP Debt Help, CAP Money Plus and CAP Money Minister clients give us information about themselves we will only use the information they supply to help support them in their journey out of debt.

If you are a client using our debt counselling service we may use your details when appropriate to create a CAP Plan for you. Your CAP Plan is a budgeting account and will be used to supply you with our continued debt counselling and management service, debt advice and support. The information will be used to process any requests, applications or transactions undertaken by you.

We will use this information only for the reason you have supplied it or any other reason, which you have given us permission to do so.

Any information we hold on you will be kept secure and will only be used for purposes directly relevant to CAP Debt Help, CAP Money Plus and CAP Money Ministers. Once you are no longer a client, we will retain your information in accordance with the requirements of our retention schedule and then delete it.

Sensitive Personal Information

Under the Data Protection Act some information is classed as sensitive personal data and is given extra protection under the Act. If you give us sensitive personal information, including but not limited to, your physical or mental health or condition, we will meet our obligations to use this information by explaining to you how we will use this information and obtain your explicit permission to do so. You will be able to withdraw your consent for us to use this information at any time and you can ask us to delete it.

CAP Money – Our Money Management Course and Online Budgeting Tool

• Your name
• Your email address

The CAP Money Course is a money management course linked to online budgeting tools that teaches course candidates people budgeting skills using a simple, cash-based system.

The online personal budget is located on CAPs servers but is only accessible by the candidate using their own password

CAP Job Clubs

As a CAP Job Clubs member your personal details will be required to enable us to contact you. Your consent will be required before you proceed. We will keep your personal information confidential and secure and we will only use this data to provide you with the services requested.

We will collect the following information:

• Your name and address
• Your employment history & experience
• Contact information – including address, landline and mobile telephone numbers and email addresses
• Other information relevant to our Job Club service.

How we will use your information

When CAP Job Clubs applicants give us information about themselves we will only use the information they supply to process their CAP Job Clubs application, ascertain their suitability to be come a CAP Jobs Club member and to monitor this information for statistical purposes.

Personal information from unsuccessful applicants will be held for 6 months after their application has been made, it will then be destroyed or deleted from our files.

Once you have been assessed as a suitable CAP Job Clubs member, we will hold your information on file. Any information we hold on you will be kept secure and will only be used for purposes directly relevant to CAP Job Clubs. Once your membership comes to an end we will retain the file in accordance with the requirements of our retention schedule and then delete it.

CAP Release Groups

As a CAP Release Group member your personal details will be required to enable us to contact you and help support you break free from dependencies. Your consent will be required before you proceed. We will keep your personal information confidential and secure and we will only use this data to provide you with the service requested.

We may collect the following information:

• Your name and address
• Your date of birth
• Contact information – including address, landline and mobile telephone numbers and email addresses
• Information on your dependency and your target goal
• Record your attendance at the Release Group
• Other information relevant to our CAP Release Group service.

How we will use your information

When CAP Release Groups members give us information about themselves we will only use the information they supply to help support them in their dependencies and to monitor this information for statistical purposes.

Personal information from people who do not complete the Release Groups course will be held in line with our data retention policy and it will then be destroyed or deleted from our files.

Any information we hold on you will be kept secure and will only be used for purposes directly relevant to CAP Release Groups. Once your course comes to an end we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Other uses of the information we gather

We gather this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping
• We may use the information to improve our products and services
• We, and our partner Churches, may periodically send you information about us, which we think you may find interesting, using the email address, telephone number or postal address you have provided. (See Controlling Your Personal Information)
• From time to time we, and our partner Churches, may also use your information to contact you for market research purposes, invite you to events and for fundraising activities. We may contact you by email, phone, fax or mail (see Controlling Your Personal Information).
• We may also need to pass on information when required by law or by a regulatory body (for example, for a Gift Aid audit by the Inland Revenue or if asked for your details by a law enforcement agency).

CAP Life Skills

As a CAP Life Skills course member your personal details will be required to enable us to contact you and help support you. Your consent will be required before you proceed. We will keep your personal information confidential and secure and we will only use this data to provide you with the service requested.

We may collect the following information:

Your name and address
Your date of birth
Contact information – including address, landline and mobile telephone numbers and email addresses
Record your attendance at the Life Skills course
Other information relevant to our CAP Life Skills course service.

How we will use your information

When CAP Life Skills course members give us information about themselves we will only use the information they supply to help support them in this and to monitor this information for statistical purposes.

Personal information from people who do not complete the Life Skills course will be held for 6 months it will then be destroyed or deleted from our files.

Any information we hold on you will be kept secure and will only be used for purposes directly relevant to CAP Life Skills course. Once your course comes to an end we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Web Chat

CAP use web chat as a service that enables you to chat online to a member of our New Enquiries Team about CAP services, without having to make a phone call.

Our New Enquiries Team member can answer your questions about our services but they can't give you advice.

If you want an appointment or to attend a CAP course you will need to call us - you can find the services we run in your area by going to our web page at capuk.org together with contact telephone numbers and email addresses. 

For your own security you should never disclose any personal information when using the chat service and we will only ask you for a name and telephone number if we need to arrange a call back with you.  

We also use web chat as an internal communication channel between CAP Debt Help Centres and Client Services at Head Office. This information is case specific.

Web Chat information is stored on our own internal servers and is held in line with our data protection policy. You can ask for a transcribed copy of this information relating to you by making a Subject Access Request – please see the section ‘Controlling Your Personal Information’ below.

Demographic information

To help us monitor that our services are being accessed by all, regardless of any potential grounds for discrimination such as age, gender, race, sexual orientation or religious belief, marital status, parental status, employment status, disability and residence type, we will collect demographic data. We may also use this information to us assist us in delivering our debt counselling service to our clients and for referring them to other agencies, trusts or bodies, as appropriate, which may be able to assist them, for instance trusts which offer hardship grants.

Statistical information and case studies

We do compile general statistics for our Charity Annual Report, to demonstrate who is accessing our service, levels and type of debt, age groups, etc. We may also use general statistics to promote the services we provide and for general media enquires. This will be in a form that does not identify any individual or families.

We may also use case studies to demonstrate the problems and issues that our clients face when in debt or struggling to budget, find work, etc. We will only use anonymous information and statistics that do not identify individuals or families. We will ask your express permission if we wish to identify you or your family in the case study.

This information helps us be open about our service and accessibility and helps us promote out aims as a Charity.

Peer reviews

At Christians Against Poverty (CAP) we are passionate about giving the best service to our clients and we may engage in peer reviews on our debt counselling service. The peer review scheme provides a mechanism for specialist debt advisers to assess the quality of advice by their peers and has been developed with input from a range of organisations across the debt sector. Peer reviewers will assess our clients’ files and judge how well clients have been advised. They will identify areas where we, as an organisation, and our debt counsellors, can develop and explore actions required to make the changes. The peer review scheme will also highlight areas of good and best practice and share them across the debt-counselling sector. This review evaluates our work by one or more people of similar competence to the debt counsellors at CAP and will be carried out by debt counselling organisations external to CAP, facilitated by the Money Advice Service (MAS). The Money Advice Service has statutory responsibility for enhancing the quality of debt advice across the UK, in order to secure the best possible outcomes for clients receiving debt advice. This sort of review constitutes a form of self-regulation by qualified members of our profession. Peer review methods are employed to maintain standards of quality and improve performance.  We may also take part in a similar scheme administered by the Scottish Government in relation to their National Standards, once this scheme has been finalised.

Where it has not been possible for us to obtain consent from a client to be included within this process, the case submitted will be anonymised and redacted so that the client's identity is not disclosed to the third party.  Please note that our regulator, the Financial Conduct Authority, has the legal right to inspect any of our casework files at any time in order to fulfil their statutory duty to protect consumers.

Faith sharing

As a faith based organisation, it is not unusual for someone's faith, or interest in faith to be a real factor in how we can offer help. E.g. some people really appreciate prayer in a time of crisis. In order to best support our clients, we will gather and record data appropriate to supporting them in their faith journey.

CAP Supporters

• Your name and address
• Contact information – landline and mobile telephone numbers and email address
• Your level of interest and support for our organisation
• Your bank details (sort code, bank account number and branch name and address) if you are a regular giver and support Christians Against Poverty financially.

CAP Current or Former Employees

• Your name and address
• Contact information – landline and mobile telephone numbers and email address
• Your level of interest and support for our organisation

If you enter sensitive personal data, including but not limited to, your racial or ethnic origin, religious or spiritual beliefs or your physical or mental health or condition, you hereby consent to the use of such data. If you do not wish to provide this information you do not have to do so.

Information on Children

Christians Against Poverty does not process any information from individuals under the age of 16. Details of any under 16s are processed only when a parent or guardian is receiving assistance with their finances from Christians Against Poverty debt counselling service or through the CAP Money Plus & CAP Money Ministers online-based debt counselling service.

Visitors to our website

When someone visits our website we collect standard Internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way that does not identify anyone. We do not make any attempt to find out the identities of those visiting either of our websites. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it (for your data to be completely anonymous you will need to disable cookies – see the Cookies Section for further information)

Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites and this privacy statement does not govern such sites. You should execute caution and look at the privacy statement applicable to the website in question.

Confidentiality and security

Personal data is kept securely in our database and on our premises. We have implemented security policies, rules and technical measure to protect the personal data that we have under our control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

All of our employees, data processors, volunteers, agents and suppliers who have access to and are associated with the processing of personal data, are obliged to respect the confidentiality of our delegates, client’s and supporters personal data and creditors commercially sensitive information.

Christians Against Poverty does not sell, rent or disclose any information to third parties for their marketing purposes.

Christians Against Poverty endeavour to keep the data we hold on you up to date. Should you spot any errors, or you no longer wish to receive information from us, please contact us.

The data we collect will, in the vast majority of cases, be stored within the European Economic Area (“EEA”). However, we may use providers who store data on servers in the USA. In this case we will only use service providers who are comply with the US “Safe Harbor” Principles. The Information Commissioner considers that personal data sent to the US under the “Safe Harbor” scheme is adequately protected. CAP also uses "Cloud" servers to store and process personal data. All our systems containing personal data are firewall-protected.

Use of CCTV at CAP Head Office

The Data Protection Act governs the processing of personal data captured by CCTV systems (including images identifying individuals) and the Information Commissioner’s Office (ICO) has issued a code of practice on compliance with legal obligations under that Act. The use of CCTV at CAP Head Office is covered by the Act, regardless of the number of cameras or how sophisticated the equipment is.

CAP uses CCTV equipment to provide a safer, more secure environment for staff and visitors to prevent vandalism and theft. Essentially it is used for:

The prevention, investigation and detection of crime.
The apprehension and prosecution of offenders (including use of images as evidence in criminal proceedings).
Safeguarding visitor and staff safety.
Monitoring the security of the site.

CAP does not use the CCTV system for covert monitoring.

Cameras are located inside the building on every external door - facing out - they are not on fire doors. CAP’s CCTV system is used solely for purposes(s) identified above and is not used to monitor staff conduct.

The purpose of the CCTV cameras is to monitor security around the building (live) or to investigate suspicious / security related events after the event (recorded).

CAP has notified the Information Commissioner’s Office of both the name of the data controller and the purpose for which the images are used. All operators and employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. Access to recorded images is restricted to staff that need to have access in order to achieve the purpose of using the equipment. All access to the medium on which the images are recorded is documented and secure. All employees are aware of the restrictions in relation to access to, and disclosure of, recorded images.

CAP can view CCTV footage in order to make a decision as to whether the recorded footage reveals that a member of staff has committed theft; this evidence may be used in a disciplinary case.

Image storage, viewing and retention

Recorded images will be stored in a way that ensures the integrity of the image and in a way that allows specific times and dates to be identified. Access to live images is restricted to the CCTV operator and security staff unless the monitor displays a scene, which is in plain sight from the monitored location.

Recorded images can only be viewed in a restricted area by approved staff. The recorded images are viewed only when there is suspected criminal activity and not for routine monitoring of staff or visitors. Images are only retained for one week when they will be erased.

Disclosure of the recorded images to third parties can only be authorised by Ellie Gage – CAP’s dedicated Data Protection Officer. Disclosure will only be granted:

If its release is fair to the individuals concerned.
If there is an overriding legal obligation (e.g. information access rights).
If it is consistent with the purpose for which the system was established.

All requests for access or for disclosure are recorded. If access or disclosure is denied, the reason is documented.

Please note: Disclosure may be authorised to law enforcement agencies, even if a system was not established to prevent or detect crime, if withholding it would prejudice the prevention or detection of crime.

Subject access requests – in line with an individual’s rights, an individual has the right to view images of themselves and, unless they agree otherwise, to be provided with a copy of the images. If CAP receives a written request under the Data Protection Act it will comply with requests within 40 calendar days of receiving the request. CAP will charge a fee of £10 for the provision of a copy of the images in line with our Subject Access Request policy. All subject access requests should be made in writing to The Data Protection Officer at the CAP Head Office address - see the 'Controlling your personal information' section below.

Security Systems – Online Tools

We take protecting your data extremely seriously. We take all reasonable steps to ensure that any data you supply is protected when you use our online tools.

Ways in which we do this include:

• Use of an SSL certificate on the site (all traffic between this site and your computer is encrypted)
• Hosting in a secure data warehouse
• Protection by a managed firewall
• Secure encryption of key data within the system
• Training of CAP staff to comply with data protection laws relevant to your country
• Password requirement of a minimum 6 alphanumeric characters – if the services we provide you give you access to our online tools.
• Encrypted data (e.g. password) is not accessible to CAP staff or CAP representatives at our partner Churches and system administration is limited to key IT Personnel only

Whilst we do what we can, it is important that you take steps to protect your account. You are responsible for the strength of your CAP Online password, as well as maintaining the security of your personal email account (the means by which the system issues sign-up and password reset instructions). We would recommend that you do not store your password in your browser.

IP addresses and log file data

This website does not automatically capture or store personal information, other than logging the user’s IP Address or the location of your computer or network on the Internet, for systems administration and troubleshooting purposes.

Use of cookies by Christians Against Poverty

Other data may be collected anonymously about your use of our site from cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

People who call Christians Against Poverty

When you call Christians Against Poverty’s we collect Calling Line Identification (CLI) information. This software will help us identify current and former clients, delegates and supporters, CAP Centre’s and partner Churches and allows us to direct your call to the correct point of contact within our organisation and this helps improve our efficiency and effectiveness.

Any call to CAP or from CAP may be recorded for quality assurance purposes and training purposes and recordings will be retained for up to 130 days.

People who make a complaint to us

When we receive a complaint from a person we may make up a file containing the details of the complaint. This will normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile statistics showing information like the number of complaints we receive, but not in a form that identifies anyone.

We usually have to disclose the complainant’s identity to whomever the complaint is about. This is inevitable where, for example, the level of service we provide is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for seven years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

If you wish to make a complaint about our service please refer to the relevant section on our website.

People who use Christian Against Poverty services

Christians Against Poverty offers various services to the public. For example, we send out information about our services, self help packs and distribute an electronic newsletter. We use a third party to deal with some publication requests, but they are only allowed to use the information to send out the publications.

We have to hold the details of the people who have requested our service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested our service to carry out a survey to find out if they are happy with the level of service they received. When people do elect to become a delegate, client or subscribe to our services, they can cancel at any time and are given an easy way of doing this. 

CAP job applicants, current and former Christians Against Poverty employees

When individuals apply to work at Christians Against Poverty, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure and Barring Service we will not do so without informing them beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for 6 months after the recruitment exercise has been completed, it will then be destroyed or deleted. Your details will be retained by our Supporter Relations team until you request them to be removed as we will wish to keep you up to date about our activities and contact you as a supporter of Christians Against Poverty (if you wish for your details to be removed from our systems please see the Controlling Your Personal Information Section below)

Once a person has taken up employment with Christians Against Poverty, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Christians Against Poverty has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us through our supporterrelations@capuk.org or writing to us at the address provided below.

If you are a client you will be able to request closure of the CAP Plan we have created for you at any time by emailing, writing or telephoning your Case Team.

If you have any queries about how your information is handled please contact us on info@capuk.org or you can write to us at:

Data Protection Officer
Christians Against Poverty
Jubilee Mill
30 North Street
Bradford
BD1 4EW

Your Rights

It is your right to request details of the information we hold about you. To receive a copy of the personal information we hold about you please write to our Data Protection Officer at the address given above enclosing a cheque for £10 made payable to Christians Against Poverty. We will respond within 40 days of receiving your letter.