The Money Advice Trust “The Trust” is a charity founded in 1991 to help people across the UK tackle their debts and manage their money with confidence. The Trust’s main activities are giving advice, supporting advisers and improving the UK’s money and debt environment.
We give advice and information to people concerned about their debts through our National Debtline service and the equivalent service to small businesses through our Business Debtline service. We support advisers by providing training through Wiseradviser and recognise innovative debt advice projects through our Innovation Grants. We use the intelligence and insight gained from these activities to improve the UK’s money and debt environment by contributing to policy developments and public debate around these issues.
The Trust (“we” or “us”) take the privacy of your information very seriously. This notice explains how and for what purposes we use the information collected about you.
The Trust looks after the information it holds about you, and respects your privacy. We take appropriate security precautions to prevent your information being lost or falling into the wrong hands.
We make sure that the information we hold is as accurate as possible; we do not hold more information than we need; and we do not hold it longer than we need to.
We keep records of all personal data that we process ensuring we have identified and documented a legal basis for processing the data.
We do not share your data with anyone else without your permission, except when we believe it is the only way to prevent harm to you or other people. If we do disclose information without your permission, this is authorised by a senior member of staff, and we will explain our reason to you at the earliest opportunity.
This privacy notice details the way in which we will treat your information, your rights in relation to it, and how we will ensure that your data is kept safe, secure and in your control. It will do this for all the ways in which you choose to access our service.
If you have any queries about this notice or anything to do with how we treat your data, please get in touch with us by using the contact details at the bottom of this notice.
Registering on the site
We will collect the following personal information from you:
- name, a user name;
- email address, telephone number
- organisation details (name, postal address, telephone number)
- supervisor details (name, email address and telephone number)
- whether you are a member of the IMA – if you are, member number
- whether your organisation is funded by MAS – if it is, project name
- your organisation’s FCA authorisation number
If you do not provide this information then we will not be able to provide you with the full range of services the Charity Site has to offer.
Whilst using e-learning resources on the Charity Site, we track your progress through the e-learning modules and record this information. This is a Wiseradviser requirement to allow us to know when you have completed e-learning modules.
This information will be used to:
- Administer your accounts with us
- Process orders or applications submitted by you
- Send you information by email about products and services
- Verify that the organisation you work or volunteer for is eligible to access Wiseradviser
- Carry out marketing analysis and make general improvements to the Charity Site
- Obtain your views or comments on the services we provide
We may disclose your personal data to the following:
- your employing organisation / membership organisation / charity partner agency (and their respective membership organisations);
- in the case of Face-to-Face Project (formerly the Financial Inclusion Fund Project) funded advisers, to the Money Advice Service;
- on request for details of the user’s record of e-learning by your nominated supervisor. In this case we will forward a copy of your learning record;
- where specific learning is required in order to be granted a particular role e.g. to become a Debt Relief Order (DRO) Approved Intermediary. In this case we will send a list of the names of those who have met the requirements to the organisation granting the role. In the case of DROs this would be the Competent Authority;
- on enrolment in a face-to-face training event we will give the tutor the names of those enrolled to attend. This may also include the venue where the training is going to be held.
Should it become necessary for personal data to be shared with other third parties in the future, we will update this privacy statement to reflect the change.
Collated, anonymous data (such as number of advisers attending training courses) is shared within the Trust’s partner agencies (and their respective membership organisations), funders and government. This is to enable us to evaluate the effectiveness of the learning that we provide and to demonstrate demand and take-up of services.
Use of discussion forums or chat rooms
Wiseradviser includes discussion forums in which you can post information. Any information that you post in these areas becomes public information and you should always be careful when deciding to disclose your personal details as part of that information.
If you sign up to our newsletter, we will retain this information. This will not be sent to any other organisation. Should you wish to be removed from the newsletter/s at any point please either unsubscribe from the link in the most recent newsletter, or contact us using firstname.lastname@example.org.
If you contact us to enquire further about our services, we will retain this information. This will not be provided to any other organisation and will only be used for the purposes in which we have told you it shall be used. You can contact us at any time to request your information to be removed.
Information automatically collected from your computer
Log files/IP addresses: When you visit the site our web server automatically records your IP address. This IP address is not linked to any of your personal information. We use IP addresses to help us administer the site, to collect demographic information and to find out such things as how many people are visiting particular pages on our site. Our website may also use a website recording service which may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our website usability. The information collected is stored and is used for aggregated and statistical reporting, and is not shared with anybody else. We may also gather other non-personal information (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service.
Use of this information: We will use some of this information in order to:
- carry out marketing analysis and make general improvements to our site;
- analyse how users are making use of the site; and
- obtain your views or comments on the information and advice we provide.
We may collate anonymous data which is shared with our partner agencies, funders and the government. This is to enable us to demonstrate demand and use of the site.
The Trust and how we treat your data
The Trust is committed to good practice in the handling of personal data and careful compliance with the requirements of the Data Protection Act (1988) (references to the DPA shall include, to the extent applicable, the General Data Protection Regulation 2016/679).
The Trust is committed to good data management in order to protect people from harm. This means:
- Keeping information securely in the right hands.
- Holding good quality information.
- Obtaining explicit consent from our clients to record and process their data.
The Trust also ensures that it takes into account the legitimate concerns of individuals about the ways in which their data may be used. In particular, The Trust aims to be open and transparent in the way it uses personal data and, where relevant, to give individuals a choice over what data is held and how it is used.
The General Data Protection Regulations (GDPR) create new rights for how organisations treat individual’s data and these are detailed below
The Trust complies with all relevant DPA legislation and also ensures that the principles of GDPR are incorporated into the service that we provide.
The right to be informed
The Trust will ensure that all individuals understand why their data is being obtained, how it is being used and how they can access it. We shall provide this information in a manner that is concise, transparent, intelligible and easily accessible. This information is provided for all ways in which you may communicate with us.
The right of access
The Trust wants all people it helps to understand how they can access their personal data, and will ensure that they are able to do this easily and quickly. Please contact us for further information on this if required.
The right to erasure
The Trust wants you to be comfortable about the data that we hold about you and we provide the facility for you to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
You have a right to have your personal data erased and to prevent processing in the following circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/ processed.
- When the individual withdraws consent.
- When the individual objects to the processing and there is no overriding legitimate interest of for continuing to process it.
- When the personal data was unlawfully processed and the data has to be erased in order to comply with a legal obligation.
The Trust can refuse to comply with a request for erasure where the personal data is processed for the following reasons:
- To exercise the right of freedom of expression and information.
- To comply with a legal obligation for the performance of a public interest task or exercise of official authority.
- For public health purposes in the public interest, archiving purposes in the public interest, scientific research historical research or statistical purposes; or the exercise or defence of legal claims.
Records held on the Wiseradviser site will be held for up to three years. This is to ensure that you are able to access records of training courses completed with us. Should you wish for this data to be removed, then you just need to contact us.
The right to restrict processing
If you wish for us to no longer process your data, then we will ensure this happens. You may wish to do this if
- You contest the accuracy of the personal data.
- Where you object to the processing of the data.
- When processing is unlawful and you oppose erasure and request restriction instead.
- If the Trust no longer needs the personal data but you require the data to establish, exercise or defend a legal claim.
If the Trust has disclosed the personal data in question to third parties, we shall inform them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so.
The Trust will inform individuals if it decides to lift a restriction on processing.
The right to data portability
Should you wish for your data to be provided to you in a machine readable format (e.g. CSV) so that another organisation can process this data, then the Trust will facilitate this where possible. Please contact the Data Protection Officer for more information by email: DPO@moneyadvicetrust.org.uk.
The right to object
You have the right to choose how we use your data, if you object, then please let us know.
The rights in relation to automated decision making and profiling
The Trust does not used automated decision making in any of its processes.
The Trust only uses personal data for direct marketing in the following instances:
- Stakeholder contact details for email marketing to promote our commercial training and consultancy services.
- Contact details for advisers for email marketing to promote our (free) Wiseradviser courses.
Permission will be obtained when the contact details are provided together with details of how an individual’s details will be processed and what to do if they decide they want them removed.
The Trust will stop processing personal data for direct marketing purposes as soon as it receives an objection from an individual. There are no exemptions or grounds to refuse. The request will be dealt with immediately and be free of charge.
Transferring your information outside of Europe
As part of the services offered to you, the information you provide to us may be transferred to countries outside of the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU or one of our service providers is located in a country outside of the EU. These countries may not have similar data protection laws to the UK. If we transfer your information outside of the EU in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice. If you use the site while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
How to contact us
The Data Protection Officer for the Trust is the Head of Compliance and Risk. You can contact them by emailing DPO@moneyadvicetrust.org.uk or by writing to Money Advice Trust, Tricorn House, 51-53 Hagley Road, Edgbaston, Birmingham B16 8TP.
If you are unhappy with the way the way in which your personal data has been handled you can make a formal complaint in line with our standard complaints policy which can be found here. If you are still dissatisfied with the outcome of your complaint after following our process you can raise a complaint with the Information Commissioners Office (ICO) who will investigate the matter further. The link to their website can be located here https://ico.org.uk/