Lasting power of attorney

Accessing and sharing customers’ information – guidance on the power of attorney

Here is some practical advice if a customer in a vulnerable condition needs your help to manage their affairs.

Our duty to keep our customers’ information safe

Our legal rights to give access to and share information we hold regarding a customer in a vulnerable condition depend on the circumstances. In particular, this depends on whether the cared-for customer is able to make decisions for themselves.

If a customer lacks the mental capacity, or has the capacity but still wants you to make a decision on their behalf, you’ll need to be appointed as their attorney. In all cases you must do what the person wants, or what’s in their best interests.

Your legal powers

There are many different types of legal power that allow you to help someone in a vulnerable condition to manage their affairs, or to access information and make decisions on their behalf.

If the customer in a vulnerable condition has the mental capacity, you can talk to them about creating a lasting power of attorney (LPA, in England, Wales or Scotland) or an enduring power of attorney (in Northern Ireland). This allows you to make decisions on a vulnerable customer’s behalf, including accessing their Vodafone account.

Alternatively, you may wish to apply for an ordinary or general power of attorney for when the person in vulnerable circumstances is still able to make decisions for themselves.

To create a lasting or an ordinary power of attorney, you need to contact your local Citizens’ Advice Bureau or you can find more information on the website

You may also wish to seek support from independent bodies and organisations. For example, the Office of the Public Guardian supports and promotes decision-making for those who lack capacity or would like to plan for their future, within the framework of the Mental Capacity Act 2005 (contact details are available at the end of this page).

If the person in a vulnerable condition lacks the mental capacity to be able to legally nominate you as their attorney, you may wish to consider applying for a court order to become the person’s deputy (in England and Wales) or controller (in Northern Ireland). In Scotland, if the customer lacks the mental capacity to nominate you as their attorney then an incapacity statement would be needed.

Information about these options is available from:

Office of the Public Guardian - England and Wales
Office of the Public Guardian – Scotland
Office of Care and Protection - Northern Ireland

How can we help you to exercise your legal rights?

Making a subject access request

As an attorney, you have the right to make a subject access request (SAR) in order to access the information we hold about the person you represent, in order to help you carry out your role as an attorney.

To make an SAR on behalf of the person you represent, you should print out and complete the SAR form and send it to us directly at this address:

Privacy Team (Data Protection)
Vodafone Limited
Level 2, Vodafone House
The Connection Newbury
Berkshire RG14 2FN

We have up to 40 calendar days from the date of receipt to respond to you. We’ll work as quickly as possible, but the easiest way to ensure a rapid response is to provide an appropriate date range for your request – this way we can send you only the information which you need.

You won’t receive an acknowledgement of your request so you may wish to send it by signed delivery so you can check whether we have received it. Please note that a statutory £10 fee (postal order or cheque made payable to Vodafone Limited) applies.

Accessing a vulnerable customer’s account and making decisions on their behalf

If you’re acting as an attorney on behalf of a customer, you should email your declaration along with proof of your identity and a certified copy of the legal document stating you’ve been granted lasting power of attorney to

Within 40 calendar days from the date of your request, you’ll be contacted by our Accessibility team. An adviser specifically trained in dealing with the needs of customers in vulnerable conditions will help you make decisions on behalf of the person you’re representing.

Your right to complain

If you feel we’ve acted wrongly – for example, you may have shown us the document and we still didn’t allow you to access the account of the person you’re representing – you can complain under the terms of our complaints code of practice. A link to this page is also available on our homepage.

Useful contacts

Information Commissioner’s Office England

Wycliffe House
Water Lane
Tel: 0303 123 1113

Information Commissioner’s Office Wales

2nd Floor Churchill House
Churchill Way
CF10 2HH
Tel: 029 2067 8400

Information Commissioner’s Office Scotland

Hadrian House
Callendar Business Park
Callendar Road
Tel: 013 2467 8300

Information Commissioner’s Office Northern Ireland

3rd Floor 14 Cromac Place
Tel: 028 9027 8757