Privacy and Data Protection Statement

Introduction

Hospice at Home West Cumbria is committed to protecting your privacy. This statement explains how we collect and use the personal information you provide to us whether online or via phone, mobile, email, letter or other correspondence.

By using our website, any of our services or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

  1. Who we are
  2. Data Protection Laws
  3. What personal information do we collect?
  4. Where do we collect your data from?
  5. How and why do we use your data?
  6. More information about why we use your information for credit risk reduction and or fraud prevention
  7. Credit, debit card and standing order payment information
  8. Information sharing and disclosure
  9. The accuracy of your information
  10. Under 16s
  11. Vulnerable circumstances policy
  12. Storing your information
  13. Our website
  14. Cookies
  15. Changes to the policy
  16. Your rights
  17. How to complain
  18. Changes to Privacy Notice
  19. How to contact us

 

  1. Who we are?

Hospice at Home West Cumbria provides high quality, palliative and end of life care to people living in West Cumbria and we are the only provider of adult hospice services in this area. This means that all funds raised by local people help us to provide care for those in need within their own community.

Established in 1987 we have been nationally and internationally recognised as delivering an excellent model for homebased palliative and end of life care.

 What Do We Do?

Home nursing is at the heart of Hospice at Home West Cumbria. We provide skilled nursing care on a one-to-one basis to adults within their own home or alternative residential settings, enabling them to remain in their chosen place of care at end of life.

We deliver a range of family and bereavement support services for families, carers and those bereaved; these include one to one support, group support and complementary therapy. This support enables people to cope during the most difficult and challenging times in their lives.

We are also the sole providers of specialist lymphoedema care in West Cumbria. This is a particularly challenging condition that affects many people. It can be as a result of cancer or cancer treatment but it can also be caused by other non-cancer related conditions.

Our care and support is available to those with a life limiting illness, regardless of cause, and is offered for free at the point of need.

Hospice at Home West Cumbria (HHWC) is a registered charity (number 1086837) and a company limited by guarantee (number 4191126).  We are registered with the Information Commissioners Office as a data controller (number Z2999472). 

Hospice at Home West Cumbria
Upper Floor Cumbria House
New Oxford Street
Workington
Cumbria
CA14 2NA

Tel: 01900 873173
Email: info@hhwc.org.uk

If you have any questions or queries about this Privacy and Data Protection Statement, please contact our Data Protection Officer, using the above address and contact details.

  1. Data Protection Laws

In carrying out our day to day activities we process and store personal information relating to our supporters and we are therefore required to adhere to the requirements of the Data Protection Act 1998/General Data Protection Regulations 2018 (GDPR).

We take our responsibilities under these acts very seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.

Personal data in our databases is only accessible by appropriately trained staff and volunteers who need to access your personal information as an essential part of their role. We employ security technology including firewalls and encryption to safeguard personal data and have procedures in place to ensure that paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage.

  1. What personal information do we collect?

Basic Information

This includes your name, email address, postal address, telephone numbers and date of birth.

We collect information about the donations you make including how much, when and your reasons for donating.

Information for Gift Aid

We also collect information about whether you are a UK tax payer so that we can claim Gift Aid (please rest assured we do not collect information about your actual tax payments, just whether you are a tax payer or not).

Sensitive Personal Information

We do not usually collect “sensitive personal information” about you unless there is a clear reason for doing so, such as participation in an event where we need this information to ensure we provide appropriate facilities for you.  We may collect health information if you tell us about your experiences of the Hospice (for example, if you act as a case study for us); however, we will make it clear to you when collecting this information as to what we are collecting, why and how we will use it.

Event-specific information

We may also ask you for information for specific events. This is so that we can cater for your needs at our fundraising events and ensure events are safe and legal. For example

  • If you are participating in the Colour run for us we will ask for your t-shirt size so that we can provide you with a t-shirt.

Information about volunteers

As appropriate for the volunteer role, we may ask for:

  • emergency contact information
  • contact details for referees
  • your interests, experience and relevant qualifications
  • your driving licence record
  • any previous convictions
  • your DBS
  • relevant medical conditions
  • if you have been bereaved in the past 18 months.

We collect this information so that we can give you a volunteer role suitable and support you to do this role. We also have to ensure that those we care for are safe.

  1. Where do we collect your data from?

In most cases we collect data about you when you give it to us.

We collect personal information about you when you:

  • ask about our activities
  • register with us
  • make a donation to us, either through our shops or to our fundraising department
  • volunteer
  • sign up for an event
  • engage with our social media or message boards
  • play our lottery
  • order products and services
  • or otherwise give us personal information.

We also collect data about you from other sources such as Virgin Money Giving, Just Giving and Funeral Directors who pass on donations you make to us. We may also collect information about you from social media when you interact with us on these platforms.

We may make use of profiling and screening methods to produce relevant communications and so provide a better experience for our supporters. Profiling can help us target our resources more effectively through gaining an insight into the background of our supporters and helping us to build relationships that are appropriate to their interests and capacity to give.

  1. How and why do we use your data?

Where we have your consent we will use your data

  • to send you direct marketing e.g. our Light up a Life appeal or our newsletter. This may be via email, postal mail, SMS or telephone depending on what consent you have given us
  • to provide you with the services, products or information you have requested
  • to invite you to participate in surveys or research.

We have a legal obligation to use your data

  • to claim Gift Aid (this involves sharing your information with HMRC)
  • for the purposes of credit risk reduction or fraud prevention (regrettably some people target charities for illegal purposes such as money laundering and, quite rightly, we are required to monitor financial activity and report suspected fraud to the appropriate authorities). See below for more information about this.

It is in our legitimate interest to use your data

  • to process any donation(s) we may receive from you
  • for administration purposes
  • for internal record keeping, such as the management of feedback or complaints
  • to analyse and improve the services we offer
  • to check on your preferences from time to time to ensure they are up to date
  • to make contact with you for administrative purposes for example to ask you about Gift Aid or your Lottery account.
  • to send you direct marketing about ways in which you have supported the Hospice previously and where you have not specifically told us not to contact you. For example, if you made a donation to our Light up a Life appeal, we will send it to you unless you tell us not to.

We do this because we believe it is necessary for our legitimate interests because our supporters are very important to Hospice at Home West Cumbria and all of our supporters deserve to have the information concerning their support recorded accurately and for it to be used to keep a proper account of the dealings we have with the public and to keep the public fully informed about the work of the Hospice where requested.

We use your data to fulfil a contract e.g.

  • to send you the items you have ordered
  • if you play our lottery or enter a raffle or competition.

We may also send you service communications via e-mail, text or social posting, for example when you make a donation online or by text.

We will not use your information for marketing purposes if you have asked us not to. However, we will retain your details on a suppression list to help ensure we do not continue to contact you for marketing purposes.

If we were to merge with another charity or restructure, we may share your personal details with other entities involved in the merger/restructure for that purpose but we would give you full information before doing so.

  1. More information about why we use your information for credit risk reduction and or fraud prevention

To comply with our obligations as a charity we take reasonable and appropriate steps to know who our donors are, particularly where significant sums are being donated.  This means that we may conduct research, including accessing information which is already publicly available, on prospective donors, partners or volunteers to ensure it would be right for us to accept support whether that is from an individual or organisation.  This will help to give assurance that the donation is not from an inappropriate source and to safeguard our reputation.  This does not mean that we will question every donation, or that we will research lots of personal and other details about every donor.  Any information we do collect for this purpose will only consist of what is necessary for us to meet these requirements and will be processed in line with your rights.

Your information may be used to ensure that the Hospice complies with the Fundraising Regulator’s Code of Fundraising Practice, which stipulates that we must take steps to assess and manage risks to our work and reputation with regard to certain levels of donation. More details can be found at www.fundraisingregulator.org.uk.

  1. Credit, debit card and standing order payment information

If you are making a payment to us we may also collect your bank account details and credit/debit card details.

We do not store your credit or debit card details at all following the completion of your transaction.

All card details and validation codes are securely destroyed once the payment or donation has been processed.  Only those staff authorised to process payments will be able to see your card details.

If we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this.

If you set up a standing order with us, either to make a donation or play our lottery, we will ask for your bank account details. These will be sent to your bank. They will be stored securely at the Hospice.

To process payments made over the website we use a third party called Paypal UK.  Paypal UK may use, retain and disclose your personal information as set out in their privacy policy, including transferring your data outside of the European Economic Area (EEA).  Where such transfer occurs, Paypal UK ensure your data is adequately protected under UK data protection law. https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Processing of donations via Virgin Money and Just Giving – These privacy policies describe how Virgin Money and Just Giving collect, use and look after the personal information that you provide them with:-

https://www.justgiving.com/info/privacy-policy-versions/privacy-policy-v20

https://uk.virginmoneygiving.com/giving/terms/privacy-policy.jsp

We use Payzone to take payments over the telephone and the following website sets out the basis on which any personal date will be processed by them:

https://www.payzone.co.uk/privacy-policy/

  1. Information sharing and disclosure

We will not sell or swap your information with any third party.

We may share your information with our data processors. These are trusted partner organisations that work with us in connection with our charitable purposes and other entities that act as fundraisers for us, sell our products or provide us with information and marketing (subject to your communication preferences and our internal policies and procedures). All our trusted partners are required to comply with data protection laws and our high standards and are only allowed to process your information in strict compliance with our instructions. We will always make sure appropriate contracts and controls are in place and we regularly monitor all our partners to ensure their compliance.

Currently the third parties we work with are:

  • Bauer Media who provide and help manage our website
  • TYG Tickets  for ticket sales
  • The Online Book Company
  • Unity Lottery who help us to run our lottery
  • B McAzurri to claim our retail gift aid donations

We may disclose your personal information to third parties if we are required to do so through a legal obligation (for example to the police or a government body) to enable us to enforce or apply our terms and conditions or rights under an agreement or to protect us, for example, in the case of suspected fraud or defamation.

We do not share your information with any other third party for any other purposes.

  1. The accuracy of your information

We aim to ensure that all information we hold about you is accurate and, where necessary, kept up to date. If any of the information we hold about you is inaccurate and either you advise us or we become otherwise aware, we will ensure it is amended and updated as soon as possible.

  1. Under 16s

If you are aged 16 or under and would like to participate in an event, make a donation or get involved with us, we must ensure that we have your parent/guardian’s permission before receiving your personal information.

When we collect information about a child or young person we will make it clear why we are collecting this information and how it will be used.

  1. Vulnerable circumstances policy

We recognise the importance of protecting our vulnerable supporters and follow the guidance issued by the Institute of Fundraising on treating donors fairly. We believe this helps to support our staff and fundraisers who come into contact with supporters in providing high-quality customer care, ensuring anyone donating to the Charity is in a position to make a free and informed decision. Access the Institute of Fundraising’s website for more guidance.

  1. Storing your information

We take great care to ensure that your data is kept secure at all times. Data is only accessible to appropriately trained staff and volunteers.

Although most of the information we store and process stays within the UK some information may be transferred to countries outside the European Economic Area. This may occur if, for example, one of our trusted partners’ servers are located in a country outside the EU. These countries may not have similar data protection laws to the UK, however, we will take steps with the aim of ensuring your privacy continues to be protected as outlined in this privacy policy.

We will keep your information for as long as required to enable us to operate our services but we will not keep your information for any longer than is necessary. We will take into consideration our legal obligations and tax and accounting rules when determining how long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of, at the appropriate time.

  1. Our website

For all areas of our website which collect personal information we use a secure server. Although we cannot 100 per cent guarantee the security of any information you transmit to us we enforce strict procedures and security features to protect your information and prevent unauthorised access.

Our website contains links to other websites belonging to third parties and we sometimes choose to participate in social networking sites including but not limited to Twitter and Facebook. We may also include content from sites such as these on our website, however, we would advise that we do not have any control over the privacy practices of these other sites. You should make sure when you leave our site that you have read and understood that site’s privacy policy in addition to our own.

  1. Cookies

We use Google Analytics, a service provided by Google. They gather anonymous data on how people are using this site and then provide us with visitor statistics, details of page views etc. You can think of it as being a bit like CCTV but one that automatically blurs your face so we can see what people have done, but not who. If you are anti-Google you can opt-out of being tracked by Google Analytics at http://tools.google.com/dlpage/gaoptout (we’d prefer you didn’t though as this data is seriously helpful to us in improving our website).

 What is a cookie?  A cookie is a small file of letters and numbers that we may put on your computer or mobile device when you access our website.  These cookies allow us to distinguish you from other users of the website helping us to provide you with a good experience when you browse our website and also allow us to improve our site. For example, they will tell us whether you have visited our site before or whether you are a new visitor.

Access the All About Cookies website – to find out more about cookies and how you can disable.

Third party website widgets

We also embed some page elements from trusted third parties so that we can provide you with features like Interactive Maps, Like Buttons and Videos. Collectively they make our website more interesting to you as a site visitor however most of these come with their own cookies. They are:

  • Facebook
  • Twitter
  • YouTube
  • Vimeo
  • Google (Maps + Plus)
  • ShareThis
  1. Changes to the policy

This policy replaces all previous versions and is correct as of May 2018. We will regularly review and update this Privacy and Data Protection Statement and will update, modify, add or remove sections at our discretion.  Any changes will be notified to you either via e-mail or through an announcement on our website and your continued use of our website, any of our services and/or the continued provision of personal information after we have posted the changes to these terms will be taken to mean you are in agreement with those changes.

  1. Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, these are the right to:

  • fair processing of information and transparency over how we use your personal information
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • ask us to remove your personal information concerning you in certain situations (please note that we are only able to do this if you have not made a gift aidable donation to us in the last 7 years and do not play our lottery or actively volunteer).
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal affects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us using the information provided below
  • let us have enough information to identify you
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates

If you wish to find out more about these rights, or obtain a copy of the information we hold about you, please contact us by post

Hospice at Home West Cumbria
Upper Floor Cumbria House
New Oxford Street
Workington
Cumbria
CA14 2NA

Tel: 01900 873173 or Email: info@hhwc.org.uk

  1. How to Complain

If you have any concerns or complaints about how we are handling your data please do not hesitate to get in touch. You can also contact the Information Commissioner’s Office and can find information on how to do this at www.ico.org.uk.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisor authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone [0303 123 1113]. 

  1. Changes to this privacy notice

This privacy notice was last updated on 16th May 2018.

  1. How to contact us

If you have any questions about our Privacy and Data Protection Statement please contact Julie Monk in the first instance at:

Hospice at Home West Cumbria
Upper Floor Cumbria House
New Oxford Street
Workington
Cumbria
CA14 2NA

Tel: 01900 873173
Email: info@hhwc.org.uk