Privacy and cookie Statement

25 May 2018

Introduction

This statement has been established to give a clear explanation of our data processing practices to safeguard you and your personal information.

St Wilfrid’s Hospice (South Coast Ltd) (“we”) promises to respect any personal data you share with us or that we get from other organisations, and keep it safe.  We aim to be clear when we collect your data and not do anything you wouldn’t reasonably expect. 

This statement relates to information that may be collected about supporters, patients, patient’s next of kin, volunteers and employees (current and former). The type and quantity of information we collect and how we use it depends on why you are providing it. 

You can change the way we contact you or opt out of communications by:

Calling: 01243 775302

or

Emailing: general@stwh.co.uk

Please note that our marketing communications include information about our latest news, such as progress of our Hospice building project or our care in the community. You can choose to opt out of fundraising communications but still ask to receive our general communications.

You can read Our Supporter Promise here 

This statement covers:

  • What personal data we collect and how we use it
  • How and where we collect information about you
  • How we keep your data safe and who has access
  • How we keep your information up to date

for our:

Supporters

By developing a better understanding of our supporters through their personal information we can make better decisions, fundraise more efficiently and ultimately continue to provide vital community services.

1.  What personal data we collect and how we use it

The type and quantity of information we collect and how we use it depends on why you are providing it. 

If you support us, for example make a donation, volunteer, register to fundraise, sign up for an event, take an Education course or buy something from our shop, we will generally collect:

      • Your name
      • Your contact details including address, email or phone number
      • Your credit/debit card details (not stored after payment processed)
      • Details of any events you have participated in or attended
      • The value of your donation or sponsorship
      • If you are registered for Gift Aid

Where it is appropriate we may also collect:

      • Your date of birth
      • Your bank details for direct debits
      • Information relating to your health and emergency contact details (for example if you are taking part in one of our events) 
      • Your reasons for supporting St Wilfrid’s. We will never make this question mandatory, and only want to know the answer if you are comfortable telling us.

We will use your data to:

      • Provide you with the services, products or information requested.
      • Administer your donation or support your fundraising, including processing gift aid and thanking you.
      • Keep a record of your relationship with us.
      • Ensure we know your communication preferences.
      • Understand how we can improve our services, products or information.

Understanding our supporters and targeting our communications

We may use profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters.  Profiling also allows us to target our resources effectively, which donors consistently tell us is a key priority for them.  We do this because it allows us to understand the background of the people who support us. This helps us to make appropriate requests to supporters who may be able and willing to give more than they already do.  Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. 

When building a profile we may analyse geographic, demographic and other information relating to you in order to better understand your interests and preferences, so that we can contact you with the most relevant communications.  In doing this, we may use additional information from third party sources when it is available.  Such information is compiled using publicly available data about you, for example addresses, listed Directorships or looking at typical house prices in a given area. 

Direct Marketing – Use of Legitimate Interest

We would like to continue mailing those with recent donations or those who may have set up a lottery subscription, over the last three rolling years, to St Wilfrid’s. These individuals will have been asked to provide us with their communications preferences but may have not yet responded to us. The type of data that would be processed in order to retaining on our mailing list is name and address.

This form of processing benefits us through the means of donations received as a result of a mailing. Our services are offered free to the public upon referral, therefore this should be seen as a benefit to the general public.

Our Fundraising Department is always looking for new ways to seek donations and reach donors in a less intrusive manner. We will not use this legitimate interest as a step to prohibit future development and we will continue to seek consent (communication preferences) from all supporters. This collection of consent will be on-going and over time we hope to have communication preference stored on all records. We offer an opt-out on all communications with supporters.

The individual supporter has generally had some contact with St Wilfrid’s either via a friend, family member, retail or use of services we provide.  We feel these individuals do expect us to use their information in this way, they are asked at contact points to provide us with their communication preferences. When those preferences are provided they are recorded and respected, we are happy to discuss communication options with any supporter when asked.

A minimal number of supporters will find our processing intrusive or object to their use. These complaints to the Hospice are tracked and report to the Board of Trustees in a timely manner. This is a relatively low number each year.

We aim to make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include information on how to opt out when we send you communications. If you don’t want to hear from us, just let us know when you provide your information or contact us 01243 775 302 or email general@stwh.co.uk.

We do not sell or share personal details to third parties for the purposes of marketing.  If we run an event in partnership with another named organisation your details may need to be shared. We will be very clear what will happen to your data when you register.

We will not sell or share your details with other charities or organisations (in compliance with the Data Protection Acts). But so we can contact you by post, we do need to securely supply your contact details to our professional mailing house partners.

How and where we collect information about you

We collect information in the following ways:

  • When you give it to us DIRECTLY

You may give us your information in order to sign up for one of our events, tell us your story, make a donation, purchase our products or communicate with us.  Sometimes when you support us, your information is collected by an organisation working for us (e.g. a professional fundraising agency like Local Hospice Lottery), but we are both responsible for your data at all times.

  • When you give it to us INDIRECTLY

Your information may be shared with us by independent organisers. For example, the London Marathon or fundraising sites such as Everyday Hero, Just Giving or Virgin Money Giving.  These independent third parties will only do so when you have indicated that you wish to support St Wilfrid’s Hospice and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

      • When you give permission to OTHER ORGANISATIONS to share or it is available publicly

We may combine information you provide to us with information available from external sources.  This is known as data- or tele-appending and enables us to contact you in the event that you change your address or phone number, or didn’t provide it to us.  We also use this information to gain a better understanding of our supporters to improve our fundraising methods, products and services.

The information we get from other organisations may depend on your privacy settings or the responses you give, so you should regularly check them. This information comes from the following sources:

Third party organisations
You may have provided permission for a company or other organisation to share your data with third parties, including charities.  This could be when you buy a product or service, register for an online competition or sign up with a comparison site.

Social Media
Depending on your settings or the privacy policies for social media and messaging services such as like Facebook or Twitter, you might give us permission to access information from those accounts or services.

Website
The content of our website pages are for your general information and use only. They are subject to change without notice.

Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Recent government legislation means we are obliged to seek your agreement to the use of cookies when you visit 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 which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. We will not associate any data gathered from this site with any personally identifying information from any source.

Information available publicly
This may include information found in places such as Companies House and information that has been published in articles/ newspapers.

How we keep your information safe and who has access

We ensure that there are appropriate technical controls in place to protect your personal details.  Our online forms are encrypted and network is protected and routinely monitored.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

We may use external companies to collect or process personal data on our behalf. When this is the case, we do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect or have access to. 

We do not sell or share your details with other charities or organisations (in compliance with the Data Protection Acts). However, so that we can contact you via post, we do need to securely supply your contact details to our professional mailing house partners.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

We will only ever share your data in other circumstances if we have your explicit and informed consent.

How we keep your information up to date

Where possible we use publicly available sources to keep your records up to date; for example, the Post Office’s National Change of Address database and information provided to us by other organisations as above. We will not purchase new addresses on data subjects, but may use the information provided to mark records as Gone Away. 

We appreciate it if you let us know if your contact details change.

How long is the information retained for

We are required to retain financial information for up to seven years. This includes details such as name, address and gift donations. If Gift Aid is claimed, we are required to retain the information and submit to HMRC as necessary to process the Gift Aid claim.

Sharing your story

Some people choose to tell us about their experiences using St Wilfrid’s services to help further our work.   This may include them sharing sensitive information related to their health and family life, in addition to their biographical and contact information. 

We will monitor the types of people who are involved (demographic information) to ensure that the views we hear are representative of all people who use our services.

If we have the explicit and informed consent of the individuals (or their parent or guardian if they are under 18) this information may be made public by us at events, in materials promoting our campaigning and fundraising work, or in documents such as our annual report.

Children

We occasionally collect and manage information from children, and aim to manage it in a way which is appropriate to the age of the child.  Information is usually collected when children attend our events or fundraise for us.

Where possible and appropriate, we will seek consent from a parent or guardian before collecting information about children.  Our events have specific rules about whether children can participate, and we‘ll make sure advertising for those events is age appropriate.  

Patients

What personal information we collect and how we use it

If you receive care and support from St Wilfrid’s in any location we will usually collect:

  • Your name
  • Your contact details
  • Your date of birth
  • Your NHS number
  • Family, next of kin and carer details, such as their phone number or address
  • Information about your current and previous healthcare

How and where we collect information about you

This information is managed separately from other data provided to the charity. It will be securely retained in our electronic patient database. Any information recorded on paper is stored securely in the patient medical record file.

This information is used for the treatment you receive under our care.  Our clinical team collect sensitive personal data about your health when you speak, email or send an instant message to them. They will use this information to answer your questions and give advice or guidance.

How we keep your information safe and who has access

We may share your information with other Health and Social Care providers eg your GP, community nurse or hospital teams. For example, this may be information given to your doctor about the care you have received; it may be to a hospital or other service you are being referred to by our staff.

If we ask another healthcare provider to be involved in your care such a referral will include your personal details and any other information which will help you get assistance that is appropriate to your needs. Details of your next of kin/main carer will be included with these referrals.

Some anonymised data may be used for clinical audit or research purposes or shared with NHS commissioners for the purposes of service planning and provision.

In some circumstances, eg when required by law or where there is a serious risk of harm to others, we may share some personal details with others including statutory bodies, for example the police, without your consent.  

We may also collect and retain your information if you send feedback about our services or make a complaint. 

If you make any donations to the Hospice and supply your details, these will be recorded on our fundraising database. You will be invited to choose what future communications, if any, you would like to receive from the Hospice.

Patient’s Next of Kin – use of Legitimate interest

Our Family Services Team, and members of the clinical team if relevant, will offer support to the next of kin/nominated person. Our services can be offered prior to death or just after depending on the request of the individual and/or the need as assessed. We offer counselling and other support services for them free of charge.

Support for the patients’ families and friend’s is a fundamental element of our service and forms part of our charitable objectives. In order to do this, we must use the information provided to us by the patient to contact them – this could be via phone, post or email. This information is noted on our electronic patient database and may be shared with our Volunteer Services Team.

Next of kin or the nominated person are offered at various points, the option to update how we communicate with them and if requested can be removed from receiving our services.  By accepting our services, they are directly benefiting from this contact.  If we do not contact these individuals to offer our support it could place them under additional stress through bereavement and this could negatively impact them as an individual as well as the Hospice’s reputation.

Writing and/or phoning these individuals is often the best way to offer our services. We believe this is a reasonable way to offer our support. Individuals will also be invited to our Remembrance Events such as: Light up a Life, Rainbow Day and Time to Remember services.

The individual has generally had some contact with us either via a friend, family member or use of our services provided.  The individual would usually know that their details have been given to us by the patient but this will not always be the case. We feel that individuals would expect us to use their information in this way; they are asked at contact points to provide us with their communication preferences. When those preferences are given they are recorded and respected, we are happy to discuss this with any individual if asked.

A minimal number of bereaved relatives or next of kin could find our processing intrusive or object to the use. Any of these complaints to the Hospice are tracked and reported to the Board of Trustees. This is a relatively low number each year (less than 1 per year).

Volunteers

Volunteers provide vital services to us.

What personal information we collect and how we use it

We are the data controller for the information you provide during the process of volunteering. If you have any queries about the process or how we handle your information, please contact us at volunteers.office@stwh.co.uk.

All information you provide during the process will only be used for the purpose of progressing your application to volunteer, or to fulfil legal and regulatory requirements if necessary. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

Application stage

We will ask you for your personal details including name, contact details, any previous work experiences and other information relevant to the role they are undertaking. Our Volunteer recruitment team and line managers where relevant will have access to this information.

Conditional offer checks

If we make a conditional offer to volunteer, we may ask you for information so that we can carry out pre- checks for certain roles. We are required to confirm the identity of our volunteers and seek assurance as to their trustworthiness, integrity and reliability. You may be asked to provide:

  • Proof of identity
  • Proof of qualifications
  • Details to complete a Disclosure and Barring Service (if required).
  • Details of referees that will be contacted
  • Bank details – to process out of pocket payments
  • Emergency contact details

How long is the information retained for

If you are unsuccessful at any stage of the process, the information you have provided will be retained for one year from the closure of the application process.

Job applicants, current and former employees

What personal information we collect and how we use it

We are the data controller for the information you provide during the application and employment process. If you have any queries about the process or how we handle your information please contact us at hradmin@stwh.co.uk

All information you provide during the process will only be used for the purpose of progressing you application, or to fulfil legal and regulatory requirements if necessary. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

Application stage

We will ask you for your personal details including name, contact details, any previous work experience, education, referees and answers to questions relevant to the role you have applied for. Our HR team and the recruitment panel will have access to this information.

Conditional offer/employment check

If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. We are required to confirm the identity of our staff, their right to work in the UK and seek assurance as to their trustworthiness, integrity and reliability.

You will be asked to provide:

  • Proof of identity
  • Proof of qualifications
  • You will be asked to complete a criminal records declaration
  • Details to complete a Disclosure and Barring Service (for relevant roles required)
  • Details of referees that we well contact
  • Bank details – to process salary payments
  • Emergency contact details
  • Pension details

How we keep your information safe and who has access

Use of data processors

We use third party data processors to provide elements of our employment services such as payroll services, pension, Occupational Health and to store personnel records. We have   contracts in place to ensure they cannot do anything with your personal information unless instructed by us. They will not share your personal information with any organisation apart from us. It will be held securely and retained for the period we instruct.

A full list of our third party data processors can be requested. 

ID and Access Passes

ID and Access passes are issued as per the Hospice Security Procedure.  Access to the Hospice building is administered by the Facilities Team.  Personal data is only shared in the context of security enforcement.

How long is the information retained for

If you are successful, the information you provide will be retained as part of your employee file for the duration of employment plus 6 years following the end of employment. This includes criminal records declaration, fitness to work, records of any security checks and references.  We use this information to administer payroll, pensions, training and appraisal, monitor equal opportunities and manage your access to various services such as IT and buildings.  We are legally obliged to collect, retain and disclose certain information about you.

If you are unsuccessful at any stage of the recruitment process, the information you have provided until that point will be retained for 6 months from the closure of the recruitment campaign.

Information generated throughout the assessment process, for example interview notes, is retained for 6 months following the closure of the recruitment campaign.

How you can access and correct the information we have

You have a right to ask us to stop processing your personal data and, if it’s not necessary for the purpose you provided it to us for (e.g. processing your donation or registering you for an event), we will do so.  Contact us on 01243 775302, by post or email general@stwh.co.uk if you have any concerns.

You can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Acts. If we do hold information about you we will:

  • Give you a description of it;
  • Explain why we are holding it;
  • Inform you who it could be disclosed to; and
  • Let you have a copy of the information in an intelligible form.

To make a request, please put it in writing addressed to our Chief Executive. 

St Wilfrid’s Hospice
Grosvenor Road
Chichester
PO19 8FP

We cannot accept these requests by email in order to ensure that we only provide personal data to the correct person. If there are any discrepancies in the information, please let us know and we will correct them.

If you have any questions, please send these to general@stwh.co.uk and for further information see the Information Commissioner’s guidance here. (link is external)

Changes to this Statement

We may change this Privacy Statement from time-to-time.  If we make any significant changes in the way we treat your personal information we will make this clear on the St Wilfrid’s website, St Wilfrid’s News mailing or by contacting you directly.

Last updated on 25th May 2018

To be reviewed November 2018, then May 2019