Clever Night Owl (CNO)

Independent Advice, Advocacy, Representation and Support Services

Effective Date: 11 June 2026

1. Who We Are

Clever Night Owl (CNO) provides independent advice, advocacy, representation and support services relating to benefits, housing, homelessness, complaints, appeals, tribunals and related matters.

Data Controller:
Paulina Skulimowska
Clever Night Owl (CNO)
The Wellsprings Business Centre, Office 2.11
Howell Croft South
Bolton
BL1 1SB

Email: contact@clevernightowl.co.uk
Telephone: +44 7748 559294

2. Information We Collect

We may collect and process the following information:

• Name, date of birth and contact details
• Address history
• National Insurance Number
• Identification documents
• Employment and financial information
• Benefit-related information
• Housing-related information
• Health and medical information
• Correspondence, emails, telephone notes and documents provided by you
• Information relating to complaints, appeals, tribunals and representation matters

3. How We Use Your Information

We use your information to:

• Assess your circumstances
• Provide advice, advocacy, representation and support services
• Communicate with you regarding your case
• Contact relevant organisations where authorised by you
• Prepare forms, letters, submissions and supporting evidence
• Maintain accurate records
• Comply with legal and regulatory obligations

4. Legal Basis for Processing

We process personal information under one or more of the following lawful bases:

• Your consent
• Performance of a contract or requested service
• Legitimate interests in providing support services
• Compliance with legal obligations

Where special category data (including health information) is processed, we will do so only where appropriate consent has been provided or another lawful basis applies.

5. Sharing Information

Information will only be shared:

• With your consent;
• Where necessary to progress your case;
• With government departments, local authorities, healthcare providers or other relevant organisations involved in your matter;
• Where required by law, safeguarding obligations or court order.

We do not sell personal information to third parties.

6. Data Security

We take reasonable steps to protect personal information against unauthorised access, loss, misuse, disclosure or alteration.

Records may be stored electronically and/or in paper format using appropriate security measures.

7. Retention of Information

Client records may be retained for up to six years following closure of a case unless a longer retention period is required by law or necessary to defend legal claims.

After this period, information will be securely deleted or destroyed.

8. Your Rights

You may have the right to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request deletion of information where applicable;
• Restrict or object to certain processing activities;
• Withdraw consent where consent is relied upon.

Requests should be made in writing using the contact details above.

9. Complaints

If you are unhappy with how your information has been handled, you may contact us directly.

You also have the right to complain to the Information Commissioner’s Office (ICO):

www.ico.org.uk

10. Changes to This Policy

This policy may be updated from time to time. The latest version will always be available on our website.