Back on Track Privacy Policy

Introduction

The Back on Track website (www.getmebackontrack.org.uk)  is owned by the Centre for Responsible Credit Ltd. We are a registered charity.

In this Privacy Policy when we refer to “us”, “we”, and “our” we mean the Centre for Responsible Credit Ltd.

Your privacy is important to us. This privacy statement explains what personal data we collect, why we collect it, and how we use it.  

We comply with data protection law and its principles in respect of your personal data.  This means that your personal data will only ever be collected and treated lawfully, fairly, and transparently:

  • Personal data is only collected and retained if relevant to the purpose that has been agreed by you;
  • Personal data is kept accurately and up to date;
  • Personal data is only retained for as long as necessary, and only for the agreed purpose;
  • Your personal data is protected securely.

We only obtain and share personal data with your express consent, and any personal information that you provide to us is only kept for 12 months from the date on which you have provided it to us.  You can request that we delete your data at any time.

Hosting and maintenance of the Back on Track platform.

The Back on Track digital platform is hosted on Amazon Web Services by the Centre for Responsible Credit Ltd.  It is maintained on our behalf by our software developers, Rapidsoft, who also trade under the name ‘Djangohouse’. 

This means that the information you supply to us is retained and processed on secure UK based servers and all your personal data is encrypted.  

What information do we collect?

The Back on Track platform collects the following personal information directly from you:

  • Your name
  • Gender
  • Address
  • Telephone number
  • E-mail address
  • Your local GP practice

The Back on Track platform also asks for sensitive information from you in respect of your ethnicity, employment status, health, and household and financial circumstances.  We also ask whether you are a tenant of any of our participating landlords.

Why do we collect this information?

We collect this information:

  • To verify that you are eligible for the Back on Track service.
  • To help you send information to the project’s Financial Support Link Worker teams so they can better advise and support you.
  • To help you send information to your local Council and, if you are a tenant of our participating housing associations to these, so that they can put a stop of any debt enforcement action for up to 60 days and share details of your debts with the Financial Support Link Worker teams.
  • To help us evaluate the take-up, operation, and impact of the Back on Track service. We do this by sharing your contact details with our project evaluators, Cordis Bright Ltd, and by telling your local GP you have requested an appointment and that they have your permission to contact the Financial Support Link Worker teams to ask what support they are providing to you. This is so we can determine the impact of the project.

Who do we share your personal information with?

The Back on Track platform shares information with these other parties:

  • Your local Financial Support Link Worker team.  This will either be Citizens Advice Southwark or Age UK Lambeth depending on the GP practice that you are registered with.
  • Your local Council
  • If relevant, your housing association.  This will only apply if you are a tenant of Hyde Housing, Metropolitan Thame Valley, Optivo, or Southern Housing.
  • Your GP practice.
  • Our Research Evaluation Partner, Cordis Bright Ltd.

However, the extent of data sharing with each of these organisations differs.

The Financial Support Link Worker teams

With your express consent, we share your personal and sensitive information, including details of your household composition, local GP, health and financial concerns with these teams.  This allows them to better assess how they can help you.

In order to share this information, we send an e-mail to the Financial Support Link Worker team that is linked to your local GP. 

As set out in our Terms and Conditions of use, the Financial Support Link Worker teams are also told that you have consented to them sharing relevant information about you with your Council, and, if relevant, your Housing Association.

Your Council and, if appropriate, your Housing Association

With your express consent, we share the fact that you have requested an appointment with one of the Financial Support Link Worker teams with these organisations. 

As set out in our Terms and Conditions of use, they are also informed that you have consented to their sharing information with the Financial Support Link Worker teams regarding any debts you may have with them. They then share this information with the Financial Support Link Workers directly.  At the same time, these agencies have committed to putting a stop on any enforcement action for up to 60 days whilst the Financial Support Link Worker teams support you.

Your GP

We share your name and address with your GP practice, so that they can liaise with the Financial Support Link Workers about your health problems and receive updates on the support you are getting. This is to help us track the impacts that our service is making to health outcomes.

Our Research Evaluation Partner

We are working with Cordis Bright Ltd, who are evaluating the Back on Track project.

Cordis Bright Ltd. may be provided with your e-mail address and telephone number in order for them to contact you and ask about your experience of using the service and the impacts that it has had on your financial circumstances and health.

The information that you provide to them is covered by their own data protection and privacy policies, which they will explain to you if you are contacted.

We do not share any other personal information with them.

However, we do share anonymised profiling information concerning the usage of the Back on Track platform.

Our Project Directors

The Back on Track project is being directed by the Centre for Responsible Credit Ltd and we are responsible for the security of your information on the platform.  We also send you e-mails confirming that we have requested an appointment for you.

It is sometimes necessary for the Centre for Responsible Credit Ltd to view individual records on the platform. For example, if there have been problems with the sending of e-mails.  In these instances, Centre for Responsible Credit Ltd, will maintain the confidentiality of your personal information. Centre for Responsible Credit Ltd may also need to store your information on its own secure cloud-based systems for a temporary period in order to respond to any complaints. Should such a situation arise you will be informed of this.

Centre for Responsible Credit may also contact you directly to ask if you can help it with research projects related to your situation. To facilitate this, your contact details (but no other information) may be shared with our e-mail provider, MailChimp.  This is based in the United States.  No other information than your name and e-mail address will be provided to this provider.

We don’t sell or share your personal data to anyone else

We will never share or sell your personal data to any other third parties.

Your rights

You have the following rights in respect of information held on the Back on Track platform:

The right of access

You have the right to be provided with a copy of your personal information (the right of access). You can view the information that we hold by e-mailing us at admin@responsible-credit.org.uk and asking us to send this to you.

The right to withdraw your consent

You can ask us to stop processing your data at any time.

The right to restrict processing

You can ask us to suspend the processing of your data at any time, for example where you need to amend the data that we hold about you.

The right to be forgotten

You can ask us to delete your data at any time.  Please contact us via e-mail at admin@responsible-credit.org.uk

The right of rectification

You can amend the information we hold about you at any time by e-mailing us at admin@responsible-credit.org.uk

The right to data portability

You have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or to transmit that data to a third party

The right to object

You have the right to object to our processing of your personal data for profiling or any other purposes. This will ordinarily require us to delete your data.

The right not to be subject to automated decision-making including profiling

The Back on Track platform does not involve any automated decision-making. The platform does generate profiling reports about its users, but these are anonymised. You have the right not to have your data included in these reports, but this will ordinarily require you to delete your data.

Your right to complain

Our Executive Director oversees our data protection policies, protocols and Privacy Policy. For questions about this Privacy Policy, our data protection policies or how we handle and use your personal data, please contact damon.gibbons@responsible-credit.org.uk 

You also have the right to contact the Information Commissioners Office to file a complaint https://ico.org.uk/make-a-complaint/ 

Amendments to this privacy policy

We may amend this privacy policy from time to time to keep it up to date with legal requirements and the way we operate our business. 

This privacy policy was last amended on 20th October 2023.