- Bury Hospice is a charity registered in England and Wales and a company limited by guarantee. Registered charity Number: 1136843, Registered office: Bury Hospice, Rochdale Old Road, Bury, BL9 7RG.
- At Bury Hospice we take your privacy seriously and are committed to protecting your personal information. We are legally obliged to use your information in line with all laws concerning the protection of personnel information including the Data Protection Act 2018, the Privacy Electronic Communications (EC Directive) Regulations 2003 and the EU General Data Protection Regulation (GDPR) of May 2018.
Quality, Governance and Compliance Lead
Bury Hospice – Rochdale Old Road, Bury, Lancashire BL9 7RG
Or call us on 0161 725 9800 ext 211
This policy includes:
- How we collect information
- Where we collect information from
- What personal information we collect
- How we will use your personal information
- Children’s data
- How we keep your data safe and who has access to it
- Who we share your personal data with
- How we keep your information up-to-date and how long we keep it for
- Legal basis for processing your information
- Your right to your information
- Complaints policy and procedure
- The Fundraising Preference Service
- Changes to this policy
How we collect information
- We collect information about you whenever you interact with us. The type and quantity of information we collect and how we use it depends on the way you are providing it. Examples of data collection maybe when you:
- Use the clinical services at the Hospice
- Make a donation, register to fundraise, sign up for an event
- Buy something from our shops
- Sign up for our E-newsletter
- Post content to our website/social media sites (including Facebook)
- Volunteer for us
- Attend a meeting with us and provide us with information about yourself
- Contact us through the following: online, email, phone, SMS, social media or post
Care and support services – separation of data
- If you, a relative, or friend are cared for or supported by Bury Hospice, the personal and/or sensitive/special category data information you provide to us will be used only for the purposes of providing you with services, or training or monitoring and auditing the quality of our services. Bury Hospice will not disclose your personal information to any third party without your consent, except to (i) healthcare professionals and organisations involved in the provision of care and (ii) exceptionally, to professional bodies or otherwise as required by law, regulation or codes of practice.
- If you use our clinical services we will need to collect information such as your name, age, address, gender, and possibly sensitive/special category information such as details concerning your health and wellbeing, ethnic origin, sexuality, religion, politics and genetics. In order to provide complete care we may also collect some information about family members and carers. If you stay for the purpose of using services or simply visit our premises we may collect your image on CCTV. We also receive data about our patients and their families and carers from other healthcare providers.
How we might collect your information
Bury Hospice may collect information in the following ways:
- Information given directly
- You may provide your details to us when you request specific information or when you make a donation or campaign for us or participate in one of our events. We may work with a professional fundraising agency which will collect this information on our behalf, but we are still responsible for your data.
- Information given indirectly
- Your information may be shared with us when you use other fundraising sites, and provide your consent to be contacted by Bury Hospice. For example, if you are fundraising for us via Just Giving, Virgin Money, Every Day Hero or other similar online giving platforms. In particular PayPal is our provider for donation handling and eBay shop payments. These other organisations will have their own privacy policies so please do ensure you review these when providing your data.
Where you may have given other organisations permission
- You may have provided your details to another organisation that works with Bury Hospice. For example, in order to sign up to the lottery you may have provided details to our external fundraising agency. However, when working with other organisations, we work to ensure it’s completely clear to you that your information will be shared with Bury Hospice. We also ensure that these organisations are certified data controllers with the Information Commissioners Office and we have contracts in place to protect your data in this situation.
- You might give us permission to access information from messaging services like Facebook and Twitter. This will depend on your settings or the privacy policies for the particular social media site.
When you are using our website
- When you visit our website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the numbers of visitors to the various part of the site, to monitor and report on the effectiveness of the site and help us improve it. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
What categories of personal information we collect
- If you support us, for example by making a donation, volunteering, registering to fundraise, signing up for an event or campaigning for us, we may collect where relevant:
- Your full name
- Your contact details (full address, email address and phone number/s)
- Your date of birth – if required for specific purposes
- Your bank or credit/debit card details (only if you are paying for an event, buying from our shops or making a donation or subscribing to the lottery or making a regular gift)
- Also where appropriate we may also ask for information relating to health if you are undertaking a high risk event for fundraising.
- In some instances we may also ask why you decided to donate to the hospice.
Use of your personal information
- We will use your personal information in a number of ways, mainly including the following:
- To provide you with the services/products or any information you have requested
- To update you about any changes to our services
- To administer your donation, including Gift Aid processing
- To support your fundraising
- To maintain our organisation records and ensure we have your most up-to-date marketing preferences
- To help us improve our services, campaigns or information-offering
- To analyse and improve the operation of our website
- To invite you to participate in voluntary surveys or research
- To contact you where you have been identified as a contact person for an organisation, such as a school (if we obtain your contact details in this way, we will only use them to contact you in the ways in which you have agreed to be contacted)
- To communicate volunteering opportunities
- As required by law
We may also use your information for purposes that are not related to your direct care:
- To investigate queries, complaints or legal claims
- To manage our services.
- For research and planning purposes. Your personal information will not be used for this purpose if you have signed up to the National Data Opt Out. For more information, relating to the National Data Opt Out, click the following link:
Please note: Bury Hospice will not use your sensitive/personal identifiable information unless it is absolutely essential. This means that when we are processing your information for non-direct care purposes, we will endeavour to either anonymise it which means that all personal identifiable information is removed with no possibility of tracing the information back to you in the future; or pseudonomise it which means that all personal identifiable data is replaced, and highly restricted access is applied to the pseudonimisation code.
- Situated within the Inpatient Unit and Day Hospice facilities, there are leaflets available for patients, relatives and carers which documents what data we collect and what we use that data for.
- We may also use your personal information so that we can understand our donors better, to assist with targeting relevant communications to match profiles of supporters and to target our resources effectively which is key to our fundraising campaigns. We may analyse geographic, demographic and recency, frequency and value of your giving history to better understand your interests and preferences in order to contact you with the most relevant communications as well as taking into consideration your preferred marketing options. This assists us to raise more funds in a cost-effective manner for the charity.
- If you wish to stop us sending information or direct marketing materials, or change your preferred contact preferences – please contact the Quality, Governance and Compliance Lead either in writing at Bury Hospice, Rochdale Old Road, Bury, BL9 7RG or call us on 0161 725 9800 extension 211.
- If you would like to update us on how you receive information from us, please contact us by the same method above to let us know your preferences in respect of mail, email, phone, or text methods.
- The majority of services that the Hospice provides does not require the collection of children’s data. However, our bereavement service does provide support to children and therefore personal details are required however these are gathered, stored and used appropriately. We also appreciate that our supporters are of all ages. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children. All Bury Hospice’s events will have clear rules on whether or not children can take part and the collection of data will be managed in accordance with each individual event, with appropriate safeguards in place and consent obtained from whoever holds parental responsibility for the child.
How do we keep your data safe and who has access to it?
- We place great importance on the security of your personal information and will always try to take appropriate precautions to protect it.
- Our website has a SSL certification. Data is held in an encrypted state in a secure data centre within Europe under a contract with an external IT provider.
- We always ensure only authorised personnel have access to your information i.e. Bury Hospice’s staff, volunteers or contractors and that they are appropriately trained to manage your data. We also use external agencies for the purpose of mailing data and these only act on specific instructions we provide.
- Despite all of our precautions however, no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk. However, any payment card details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards.
- We also undertake regularly testing and risk assessments of our data security and are compliant with the Data Security Protection Toolkit which is submitted annually to NHS England.
- Permissions to all systems and records are allocated in line with Caldicott principles and there are processes and procedures in place to review permissions and revoke as required e.g. when somebody transfers department or leaves the Hospice.
Who we share your personal data with
- We do use external organisations that collect and/or process personal data on our behalf. Before working with these companies we perform rigorous checks to ensure they meet all relevant regulations and legislation. We always implement a contract with our suppliers, which impose robust data protection requirements, including the provisions of this policy, and seek to provide maximum protection to your personal details.
- We may legally be required to disclose your details if required to by the police or for regulatory reasons. We will only ever share your data in other circumstances if we have your consent to do so.
- We do not sell or share personal information to any other third parties for the purposes of marketing. But if we run an event in partnership with another organisation, your personal information may need to be shared for administration of the event, but we will always ask for your consent and be clear on what these details will be.
- Requests for access to records for research purposes occasionally come to the Hospice from specialist hospitals e.g. The Christie. Consent is always asked for from the patient and their next of kin and this is documented within clinical notes. In circumstances like this we ensure that as a Hospice any third party we are sharing medical information with has the appropriate accreditation in line with the National Data Opt Out Policy.
How we keep your information up-to-date
How long we keep your information for
- We will hold your personal information on our systems for as long as is necessary for the relevant activity, for legal requirements and we will also hold some information to help understand your past relationship with us.
- If you ask us to stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us. If your register with the Fundraising Preference Service we will also keep your information on record to fulfil this criteria.
- Legacy income is vital to sustaining Bury Hospice’s work. We may keep data you provide to us indefinitely, both to administer legacy gifts and to communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyse the source of legacy income we receive.
- Where you contribute stories, content, photographs, material to us for use in materials promoting our campaigning and fundraising work or for use in publications such as our annual report etc. we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted, unless otherwise stated at the point of collection. We will also keep details of the explicit and informed consents of individuals, or their parent or guardian if they are under 16 years of age.
Our legal basis for processing your information
- Although in many cases we will seek consent to process your personal data, in some instances we may process your information without consent when we are legally allowed to do so. This will only be where it is in our legitimate interests to do so and where we are confident that such processing is not likely to prejudice your legitimate interests or rights and freedoms. We will carry out a Legitimate Interests Assessment (LIA) for the purpose on each occasion.
- Where we are processing your personal data on the basis of consent that you have given us, you are entitled to withdraw that consent at any time such that we can no longer rely on it as a basis for continuing to process your personal information.
- You retain control of how we use your data and you have the right to ask us to stop holding and processing your personal information, which we will do. In some circumstances we may legally be required to retain your personal information for legal/audit purposes. However, this will be discussed with you depending on your requirements. Please call or write to Quality, Governance and Compliance Lead, Bury Hospice, Rochdale Old Road, Bury, BL9 7RG – Tel: 0161 725 9800 extension 211.
- You have the right to withdraw consent to direct marketing. You can exercise this right at any time and can ask us to update your preferences. See above for relevant contact details.
- You also have the right to access your personal data and the right to obtain a copy this is usually referred to as a Subject Access Request. This request can be verbally or in writing. This gives entitlement for you to obtain the following from us:
- Confirmation that we are processing your personal data;
- A copy of your personal data; and
- Other details such as the purpose of processing your data, the categories of data concerned, who we disclose this data to, the retention period for storing your data or the criteria for determining how long we will store it.
- In limited circumstances you may be able to require us to restrict our processing of your personal data. For example, if you consider what we hold is inaccurate and we disagree, the processing may be restricted until the accuracy has been verified.
- Where we have no lawful basis for holding onto your personal data you are entitled to require us to delete it.
- In limited circumstances you may be entitled to have the personal data you have provided to us sent electronically to you for you to provide to another organisation.
- If you have any concerns or complaints about how we are handling your data please do not hesitate to get in touch as noted under the Complaints Policy section below. You can also contact the Information Commissioner’s Office and can find information on how to do this on their website. www.ico.org.uk.
Complaints Policy and procedure
- If you would like to raise a concern or make a complaint about how we process your personal data, or about any of the services provided by Bury Hospice, we encourage you to speak to manager of the department concerned first, they will respond to you. If they have not been able to satisfy your complaint please contact our Quality, Governance and Compliance Lead.
The Fundraising Preference Service
- The Fundraising Preference Service (FPS) is a website-based service that can help members of the public control the communications they receive from charities.
- By entering your details on the Fundraising Preference Service website, or by calling the helpline on 0300 3033 517, you can choose to stop email, telephone calls, addressed post and/or text messages directed to you personally from a selected charity or charities.
- This policy may change from time to time in accordance with legislation or best practice guidelines. If we make any significant changes to this policy, we will publicise these changes clearly on our website.
- Please feel free to revisit this policy each time you consider giving your personal information to Bury Hospice.
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If you have identified a potential discriminatory impact of this procedural document, please refer it to the Chief Executive, together with any suggestions as to the action required to avoid/reduce this impact.