Privacy Policy
St Oswald’s Hospice Ltd and St Oswald’s Hospice Promotions Ltd Privacy Statement
When reading this document and we mention St Oswald’s Hospice this relates to both St Oswald’s Hospice Limited and St Oswald’s Hospice Promotions Ltd unless otherwise stated.
This is the Privacy Policy of St Oswald’s Hospice, Registered address: Regent Avenue, Gosforth, NE3 1EE. Charity number 503386. Company Number 1166239. ICO Registration number ZB163587
And
St Oswald’s Hospice Promotions Limited: Registered Address: Regent Avenue, Gosforth, NE3 1EE. Company Number 03146260.
Gambling Operations Number 000/005230/N/30378110004.
We at St Oswald’s Hospice aim to be as transparent as we can about how and why we communicate with you and how we will use your personal information.
St Oswald’s Hospice is committed to protecting the personal information of all those who provide it, regardless of the reason, whether it is provided online or offline.
In this statement we will tell you:
• Why we are able to process your information
• What purpose we are processing it for
• Whether you have to provide it to us
• How long we store it for
• Who we share it with
St Oswald’s Hospice is the Data Controller (based on the definitions in the General Data Protection Regulations – GDPR) for the personal information we process, unless otherwise stated.
There are many ways you can contact us, including by phone, email and post.
Our postal address:
Data Protection Officer
St Oswald’s Hospice
Regent Avenue
Gosforth
Newcastle upon Tyne
NE3 1EE
Switchboard Number: 0191 2850063
Email: DataProtectionOfficer@stoswaldsuk.org
Regardless of your status you can contact us about any of the data issues below at any time at any of the contact details above.
Please mark any correspondence for the attention of the Data Protection Officer.
We keep our privacy notice under regular review to make sure it is up to date and accurate. It was last reviewed in May 2020.
Most of the personal information we process is provided to us directly by you for one of the following reasons:
• You have been referred to one of our clinical services (this information will usually be provided initially by another health provider such as your GP).
• You are a family member of a patient using our services.
• You have made a complaint or enquiry to us.
• You have made a donation to us.
• You wish to attend, or have attended, an event.
• You subscribe to one of our newsletters.
• You have applied for a job or secondment with us or continue to work for us as a member of staff or a volunteer.
• You are representing your organisation.
• Suppliers/Contractors.
You may fit into more than one category so please read any sections that apply to you.
Your Rights
Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. If you wish to contact us about any of the rights described above please do so. We do have a form which can be returned via email to DataProtectionOfficer@stoswaldsuk.org however an email or letter will suffice as long as you are clear about the request you are making.
You have the right to ask for a copy of the personal information St Oswald’s Hospice holds about you and to correct any inaccuracies in that information.
Please direct any requests to access personal data to the data protection officer at DataProtectionOfficer@stoswaldsuk.org or on 0191 2850063.
When requesting clinical information, a consultant with specialist training (the Caldicott Guardian) will review the information before it is disclosed to ensure that no information is shared inappropriately.
We will aim to respond to your request within one month however if it is a complex request we will keep you informed of any potential delay.
You can read more about subject access requests on the ICO website by clicking this link.
There may be rare occasions when we are asked to disclose information to the police or other enforcement agencies. We will consider this on a case by case basis and aim to minimise data that is shared while still supporting the prevention or detection of crime.
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
When you ask us to rectify any information we hold about you we will take reasonable steps to investigate whether the data is already accurate or needs to be amended.
We will then contact you to confirm the data has been corrected, deleted or added to. If we believe the data is accurate and therefore disagree with your request we will write to you to inform you of our decision and rationale.
If your request relates to clinical information recorded we are not allowed to delete certain notes from your clinical record however in these instances we will make a note that you disagree with the content.
We will action your request within one month.
The ICO offers additional guidance about this which you can access here.
You have the right to ask us to erase your personal information in certain circumstances. However this excludes the following:
• Where we have a legal obligation to keep hold of your data, such as healthcare regulations, employment law, financial regulations.
• When keeping your data is necessary for establishing, exercising or defending legal claims.
When making a request to be erased from our systems we will confirm that this has been carried out or advise you of the legal reason for not proceeding with your request.
The ICO provides additional guidance on this and you can read more about it here.
You have the right to ask us to restrict the processing of your information in certain circumstances for example if you are concerned about the accuracy of data or how it is being used.
We will action your request within one month.
The ICO provides additional guidance on this and you can read more about this right here.
You have the right to object to our processing of your data where it relates to processing for our legitimate interests or for direct marketing. If this is the case, please contact us using the contact details above and provide us with information about your objections.
We will action your request within one month.
The ICO provides useful guidance on this right. You can read more about this here.
We would always attempt to accommodate requests to access your data in a portable version, however we do not currently have any systems that would support the electronic transfer of data as outlined in GDPR. Healthcare records can be shared with consent via SystmOne, the national Summary Care Record or via sending paper notes if systems are incompatible. However, we will consider on a case-by-case basis and do our best to respond where we can.
You are not required to pay any charge for exercising your rights. We have one calendar month to respond to you.
Please note that we may ask for proof of identification before processing any request.
This privacy notice does not cover how any partner organisations process personal information; this includes any external links connected to our website. We encourage you to read the privacy notices on the other websites you visit. We do work with partner organisations to ensure that appropriate data sharing agreements or appropriate terms and conditions are in place to ensure that they are equally compliant in keeping your data as safe as we do.
We work to high standards when it comes to processing your personal information. If you have queries or concerns about St Oswald’s Hospice handling of your data or that of anyone working on our behalf, please contact us at DataProtectionOfficer@stoswaldsuk.org
If you remain dissatisfied with any immediate response to a particular situation, we will escalate this using our complaints policy.
Your personal data is held on secure servers operated by both St Oswald’s Hospice and agencies contracted by us. We do not transfer your data outside the European Economic Area (EEA) and we comply with the protection offered to you under the GDPR and the Privacy and Electronic Communications Regulations 2003 EC Directive (PECR).
Personal data is collected and stored securely subject to stringent security measures and is protected against misuse. When we use external data processing services, we do so only under strict contractual terms to mirror the security policies that we have in place.
The information we collect
The information we collect will depend entirely on our relationship with you.
As clinical, fundraising and internal human resources information is collected for entirely different purposes, we do not pass information between the different systems in order to protect your confidentiality unless you have given consent for us to do so. The only exception to this is when a patient dies we will inform our fundraising team with the sole purpose of ensuring that any supporters who have died while receiving care with St Oswald’s Hospice are not contacted inappropriately causing distress to the family.
If you are a patient
If you are referred to St Oswald’s Hospice clinical services, the purpose of collecting your personal and sensitive health information is to provide you with appropriate and safe healthcare. We may from time to time also ask you for additional information for the purposes of audit or research.
We do have a legal obligation to maintain healthcare records as set out in Regulation 17 or the Health and Social Care Act 2008, Regulations 2014, and as such, we need to capture information about you and your care to provide you with safe and effective treatment.
When starting to use our services, a member of the clinical team will seek your consent to share this information with other healthcare professionals involved in your care. We will seek additional consent in the event of your participation in any additional activities outside of this purpose, for example the use of photographs for teaching materials. We may also ask your consent to use any photographs for marketing purposes and this will be done very explicitly, no photographs or data will be used for this purpose without your consent.
If you are a patient we will need to collect information about you, your condition and others involved in your care in order for us to be able provide the best possible care to you.
The Data Protection legislation splits data into categories including personal and sensitive data, we will collect both kinds of data from you as set out below.
Personal information
The personal information we hold about you may include the following:
• Name, address, date of birth.
• Telephone numbers.
• Next of kin / emergency contact.
Sensitive Personal Information (special category data)
The sensitive personal information we hold about you may include the following:
• Details of your current or former physical or mental health. This may include information about any health care you have received or need, including about clinic and hospital visits and medicines administered.
• Details of services you have received from us.
• Information relevant to your continued care from other people who care for you or know you well, such as other health professionals and relatives.
• Details of your race and/or ethnicity.
• Details about any disabilities.
• Details about your language preferences.
• Details of your religion.
• Details of any relevant genetic data or biometric data relating to you.
• Data concerning your sexual orientation.
The confidentiality of your medical information is of paramount important to us, therefore we make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health.
We are obliged by Health Care legislation to keep ongoing records of the treatment provided to you. It is also an important tool to be able to share plans and progress between the team members involved in your care.
We gather health information about you from a number of sources including:
• Directly from you
• From the person referring you to our service
• From other people involved in your care
We keep your data primarily on a patient information system called SystmOne which is a product used by many NHS providers and allows us the capability to share appropriate information, with your consent, with other users of the system involved in your care.
Some services also keep paper notes for the day-to-day elements of care.
All clinical notes are reviewed and updated by the clinical team looking after you.
We will keep your clinical record for 8 years after your discharge from the service, or for 25 years if you are a child using our service. Your notes may be kept for longer in very particular circumstances such as involvement in a clinical trial but in these instances specific consent would be obtained.
We may from time to time offer you the opportunity to become involved with research projects linked to St Oswald’s Hospice, in these cases your direct consent will be obtained and the care of your data will be outlined as part of the project as it may differ from project to project.
The NHS are launching a National data opt-out scheme by which you can opt out of your data being used for research or planning purposes. St Oswald’s Hospice as a healthcare provider will aim to implement the scheme by the deadline of September 2020. More information can be found at: https://www.nhs.uk/your-nhs-data-matters/
If you are a family member or next of kin
We collect the details of family members and next of kin for patients in our care. We do this under the grounds of Legitimate Interest of the person in our care to provide the best possible support to them and their loved ones. There is also the Legitimate Interest of the family members who require support as a carer in their own right or become bereaved who may choose to receive support from our bereavement team. We may from time to time also ask you for additional information for the purposes of audit or research.
Names and contact details of your next of kin or emergency contact. We may also complete a family tree of your immediate family.
As a Hospice we provide holistic care to palliative care patients and also support for families and carers. As such it is important to understand family dynamics, who information is to be shared with and also identify who may need to be referred for additional support within our carer support or bereavement services.
We record this information as part of the clinical record of the patient. If you are referred for carer or bereavement support you will be registered as a patient / client in your own right and the details given in the section about patient data above will also apply.
We will use the data to invite you to a memorial service or advise you of other services that may be of benefit to you following the death of a loved one.
We will not pass your data on to our fundraising department.
As your data forms part of the clinical record, it will be kept for 8 years after the patient is discharged or 25 years if they are a child.
If you are an applicant
We use the information we have collected in order to:
• Manage the recruitment process.
• Assess and confirm a candidate’s suitability for the role and decide who will be appointed.
• To make reasonable adjustments to the recruitment process for candidates who have a disability in line with our legal obligations.
• To ensure effective general HR/Volunteer administration.
• To respond to and defend against legal claims.
• Information such as ethnic origin, sexual orientation, religion or belief, is used for the purposes of equal opportunities monitoring with the explicit consent of applicants, which can be withdrawn at any time.
Please note: This list is not exhaustive and we will update it periodically to reflect any major changes.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
• Legitimate interest – we need the information to enable us to assess your suitability for the position you have applied for prior to entering into a contract or volunteer/employment/work placement relationship with you.
• We have a legal obligation – for example we must check eligibility to work in the UK before employment starts.
The list below shows the main categories of personal data we may collect:
• Personal identifiers i.e. name, home address, personal telephone number/e-mail address.
• Details of your qualifications, professional membership, skills, experience and work history.
• Information about your current level of remuneration (only for paid roles).
• Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
• Gender.
• Marital status.
• If you have any cautions or convictions which may show on a criminal record check with the Disclosure & Barring Service.
• Information relating to your health.
• Information about your right to work in the UK.
• Personal data which you otherwise voluntarily provide, e.g. ethnicity*, religion*.
Please note: This list is not exhaustive and we will update it periodically to reflect any major changes.
Most of the personal data we process is collected directly from you i.e. through CV’s, application forms or collected through interviews or other forms of assessment (including online testing e.g. psychometrics). Occasionally we may be provided with data from recruitment agencies or work placement organisations who you have asked to act on your behalf.
For all paid job applicants we will only seek information from third parties e.g. references, health screening and criminal record checks once a conditional job offer has been made.
For volunteer applicants we will seek references once we have received your completed application form but we will not seek criminal record information (if relevant) until you have been offered a role.
Some personal data is considered highly sensitive and is subject to additional safeguards. The Hospice aims to limit the special categories of personal data which it processes as follows:
• Health Information
We process health information if we need to make reasonable adjustments to the recruitment process for applicants who have a disability e.g. whether adjustments need to be made during a test or interview. This is to carry out our obligations and exercise specific rights in relation to employment.
• Disclosure and Barring Service(DBS) checks/information
Given the nature of our organisation, DBS clearance is required in most roles. All applicants selected for assessment/interview will be asked if they have any cautions or convictions that may show up on a criminal record check. We will only seek a DBS check (if applicable) once the offer of a role is made and accepted. The HR/Volunteer Department can provide further guidance to applicants on request.
• Equal Opportunities Monitoring
The Hospice is committed to providing equal opportunities for all applicants and we will process information relating to ethnic origin, race, nationality, sexual orientation, disability etc., alongside information relating to gender and age, for the purposes of equal opportunities monitoring.
Applicants are entirely free to decide whether or not to provide such data and there are no consequence of failing to do so.
All special categories of data are confidential and will only be shared internally where there is a specific and legitimate purpose to do so.
We use the information we have collected in order to:
• Manage the recruitment process.
• Assess and confirm a candidate’s suitability for the role and decide who will be appointed.
• To make reasonable adjustments to the recruitment process for candidates who have a disability in line with our legal obligations.
• To ensure effective general HR/Volunteer administration.
• To respond to and defend against legal claims.
• Information such as ethnic origin, sexual orientation, religion or belief, is used for the purposes of equal opportunities monitoring and is purely voluntary.
Please note: This list is not exhaustive and we will update it periodically to reflect any major changes.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR/Volunteer team, interviewers involved in the recruitment process and managers in the business area with a vacancy.
No automated decision making is involved in our recruitment process.
The Hospice takes the security of your data seriously, we have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and it is not accessed except by those authorised to do so in the performance of their duties.
Paper information is stored in locked cabinets and access is strictly limited to the HR/Volunteer Team, interviewers involved in the recruitment process, managers in the business area with a vacancy and in certain emergency situations the Hospice Management Team (HMT) or Duty Co-ordinator.
Electronic data is stored on the HR/Volunteer Database and Hospice IT systems, including email, with access strictly limited to the HR/Volunteer Team, interviewers involved in the recruitment process, managers in the business area with a vacancy and in certain emergency situations HMT, the Duty Co-ordinator or IM&T Manager.
The Hospice policy is to retain personal data only for as long as needed to fulfil the purpose for which it was collected or otherwise as required under applicable laws and regulations.
If your application is unsuccessful we will keep your personal data on file for:
• Twelve months if you are applying for a paid role.
• Six months if you are applying for a volunteer role.
• Three months if you are applying for a work placement.
If you are a member of staff or a volunteer
We need the information to enable us to fulfil our obligations as your employer. Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
• We have a contractual obligation for some data.
• We have a legal obligation for other data items.
• You also have the option to provide some data such as sexuality, ethnicity or disability status for the purposes of equality monitoring. (see * items in the list below).
We may from time to time also ask you for additional information for the purposes of audit or research.
The list below shows the main categories of personal data we may collect:
• Personal identifiers i.e. name, home address, personal telephone number/e-mail address.
• Date of birth.
• Driving licence number (if applicable).
• Gender.
• Marital status.
• Emergency contact information.
• Criminal record information.
• Information relating to your health.
• Photograph (for identification purposes stored on the HR Database* and/or for the issue of a Smartcard).
• Documents evidencing your right to work in the UK.
• Bank account details and national insurance number.
• Documents gathered during recruitment i.e. cv, application form, references, qualifications.
• Documents relating to professional memberships, insurance, essential qualifications, statutory and mandatory training and revalidation.
• General employment records including details of training, disciplinary and grievance matters, benefits, holiday, other absences, employment contract, performance records (including appraisals).
• Information gathered through the Hospice’s monitoring of its IT systems and CCTV recording.
• Personal data which you otherwise voluntarily provide, e.g. ethnicity*, religion*.
Please note: This list is not exhaustive and we will update it periodically to reflect any major changes.
Most of the personal data we process is collected directly from you i.e. through CV’s, application forms, passport or other identity documents or during meetings held with you. We may also receive personal information indirectly from third parties, such as:
• Previous employers when taking up references.
• Medical professionals to assess health before and during employment.
• The Disclosure & Barring Service (Criminal Record Information) to meet our legal obligations in relation to working in an environment with vulnerable adults and/or children.
Special Category Data: Some personal data is considered highly sensitive and is subject to additional safeguards. The Hospice aims to limit the special categories of personal data which it processes as follows:
• Health Information
The Hospice may process information about an employee’s physical or mental health in compliance with its obligations in connection with employment, in particular:
• To administer sick pay entitlements.
• To comply with obligations owed to disabled employees.
• To comply with patient care, health regulatory and health and safety obligations.
• To maintain a sickness absence record.
• To obtain health advice and support from our external Occupational Health Service Provider.
All health information is confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
• Disclosure and Barring checks/information (DBS)
Given the nature of our organisation, DBS requirements apply to most employees.
We are required to carry out DBS checks for roles as described in the Criminal Records policy. In all cases, we carry out the checks in line with the applicable law.
DBS checks will be repeated periodically during the course of employment in line with Hospice protocols.
We will always treat DBS information as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
DBS information will be stored in compliance with DBS rules. DBS information will typically be retained for a maximum period of 6 months or until the next CQC inspection, whichever is the longer, although the date, certificate number, level of check and outcome will remain on the employee’s record.
• Equal Opportunities Monitoring
The Hospice is committed to providing equal opportunities for employment and progression to all of its employees and from time to time we will process information relating to ethnic origin, race, nationality, sexual orientation and disability, alongside information relating to gender and age, for the purposes of equal opportunities monitoring and gender pay gap reporting.
We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
In addition, this monitoring will always take place in accordance with appropriate safeguards as required under applicable law, including:
• The provision of information relating to ethnic origin, race, nationality, sexual orientation and disability for the purposes of monitoring will be voluntary and processed for this purpose only.
• The monitoring will be conducted on the basis of using anonymised data so individual employees cannot be identified.
We use the information we have collected in order to:
• Pay your wages and administer any benefits under the employment contract.
• Manage day to day tasks and responsibilities.
• Manage and assess performance, including the conduct of annual appraisals.
• Consider eligibility for promotion or alternative roles.
• Comply with legal requirements, such as reporting to the local tax authority or professional regulators.
• Address disciplinary, grievance or health issues with individual employees.
• Monitor the proper use of Hospice IT systems.
• Prevent fraud or any illegal activity.
• Meet our legal obligations in respect of health and safety and disability legislation.
• To ensure effective general HR administration.
• To record all types of absence and leave to ensure effective workforce management and compliance with duties in relation to entitlements and pay/benefits.
Please note: This list is not exhaustive and we will update it periodically to reflect any major changes.
We may share some of this information with:
• Your line manager, certain members of the finance team and/or the relevant Director for your role.
• The Disclosure & Barring Service.
• The Independent Safeguarding Authority.
• The Care Quality Commission.
• Regulatory bodies i.e. the Nursing & Midwifery Council, or General Medical Council.
• Occupational health and/or external counselling providers.
• Our Legal representatives.
• Pension providers.
• HMRC or any appropriate government body.
In all cases not governed by regulation or legislation, the employee personal data is shared under the terms of a written agreement between the Hospice and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified or as permitted by law, and not for their own purposes, and they are not permitted to further share the data without our express permission.
None of your data will be used for automated decision making.
The Hospice takes the security of your data seriously, we have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and it is not accessed except by those authorised to do so in the performance of their duties.
Paper information is stored in locked cabinets and access is strictly limited to the HR Team, your line manager and in certain emergency situations the Hospice Management Team (HMT) or Duty Co-ordinator.
Electronic data is stored on the HR Database and Hospice IT systems, including email, with access strictly limited to the HR Team, your line manager and in certain emergency situations HMT, the Duty Co-ordinator or IM&T Manager.
The Hospice policy is to retain personal data only for as long as needed to fulfil the purpose for which it was collected or otherwise as required under applicable laws and regulations Current retention periods are shown in the Standard Operating Procedure Library, Document Retention Procedures in Sharepoint. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
If you have any queries about your personal data held by HR or would like access to your personal data held by St Oswald’s Hospice then please contact them directly on HumanResources@stoswaldsuk.org or via the DataProtectionOfficer@stoswaldsuk.org email.
If you are a donor, supporter or customer
The purpose of capturing your personal and potentially sensitive information (i.e. health information for physical events) within income generation (e.g. fundraising) will be for the purpose of processing your donation, organising a sponsored event, processing your gift aid etc. This will be done on the basis of explicit consent which will be gathered from entry forms and other marketing materials.
What we need will vary depending on the type of fundraising interaction however the most common details collected will be name, contact details, donation details, bank details and for some events, health information.
Patients, staff and volunteers can also be donors, supporters, customers or even patients.
If you are a donor, supporter and/or customer the information we will collect will be that which we require to process your donation, purchase, gift aid donation or to keep you safe during an event.
We collect name and contact details, payment details where appropriate and in addition, we ask you to supply information about the type of person or organisation you are so we understand your relationship with St Oswald’s Hospice so as to tailor future communications to you.
Often people who interact with St Oswald’s Hospice have more than one status within the organisation meaning your data may have been collected a number of times for different purposes by different departments. We do not share your data internally for marketing purposes unless you have given us permission to do so. On most data collection forms within St Oswald’s Hospice we will ask you if you’re happy to receive marketing from us. If you give consent for us to market to you we also ask if you would kindly let us know your status or status’ with us, i.e. are you:
• Name of Organisation (if applicable)
• A member of staff
• A volunteer
• Next of Kin to a patient
• A patient of ours
• A friend or relative of a patient
• We also always give the option: Prefer Not to Say
If you do kindly tick the correct box(es), this gives us permission to use this status information which will help us protect you and send you information more relevant to you in future.
Other areas of the organisation do not share this information with Fundraising unless you have given your consent for them to do so.
In addition to the information you provide, Fundraising may use online platforms such as Facebook, Twitter, Instagram and LinkedIn in order to gather available information about you where relevant. Any information we are given, or gather about you which is in the public domain, will help us tailor the information we send you to your needs to ensure it is as relevant to you as possible.
If you tell us your status, here is how we will use this information:
If you tell us you are a staff member: We will stop sending printed paper copies of information to your home address and ask that you pick up a newsletter from display points around the Hospice, one of our shops or through internal emails instead. This will help us save money on printing and postage.
If you tell us you are a volunteer: We would like to continue to communicate with you with more relevant information to you such as updates, volunteer opportunities and fundraising, as we know so many volunteers not only give their valued time but also support us in our fundraising and for that we are truly grateful. If you are worried about postage costs and have an email address, we can send a lot of this information to you via email, which will allow us to keep in touch with you without the printing and postage costs. However in order to email you we would need you to stipulate you are happy to receive emails from us.
If you tell us you are a patient: As you are currently receiving support and care from us, if you tell us you are a patient, unless you opt out, we will continue to send you the newsletter to keep you up to date with our activities, but will not send you any direct requests to help fund our service. If you choose not to divulge this information we completely understand but please note that if we do not know you are a patient, you may receive requests from us for funds in future and we apologise if this causes you any distress. Please know this is not our intention. If you do not wish us to know your status please tick the “Prefer Not to Say” option and we will continue to communicate with you as we would any other supporter.
If you tell us you are Next of Kin, or a friend or relative of a current or previous patient: If we have this information within Fundraising this will help us send information to you about service updates and fundraising opportunities we have specifically for people who would like to help in memory of a loved one. Many people choose to fundraise in memory and find it a positive way of helping them to come to terms with the death of their loved one, but there is absolutely no obligation to do this and we understand if you wish to opt out and no longer receive information from us. If you do not wish us to know your status please tick the “Prefer Not to Say” option and we will continue to communicate with you as we would other supporters.
If you have kindly allowed us to claim Gift Aid back on your donation of money or goods it is your responsibility to let us know if your tax status has changed when you make any further donations. You can do so by contacting enquiries@stoswaldsuk.org telling us your name, address and new status.
Under the Data Protection Act 2018, we cannot send marketing information to you via text or email without your specific consent to use these channels, even if you’ve supplied your email address or mobile number to us in the past.
It is not a legal requirement that we obtain explicit consent to contact you with marketing information via traditional mail or over the telephone if you have supplied us with your contact details and assuming we are contacting you about something which is relevant to how you’ve contacted us or supported us in the past.
However you can opt out of receiving marketing from us via these channels at any time by emailing supportercare@stoswaldsuk.org or calling 0191 246 9123.
We shall process the data you supply in order that we can assist you and respond appropriately. We will not share or sell your data for marketing purposes outside of St Oswald’s Hospice.
If you subscribe to one of our newsletters
Our purpose for collecting the information is so that we can provide you with a service and let you know about upcoming events or information that may be of interest to you.
The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR.
To subscribe to one of our newsletters we need your name and email address.
To be able to send the newsletters as cost effectively as possible we distribute them via email.
We only use your details to provide this service, we do not pass your details on. We gather statistics about email opening and clicks using industry standard technologies including Clear Gifts and Mailchimp to help us monitor and improve our newsletter.
We will keep your details until you unsubscribe from the service. As you may opt to receive other services from us, we may need to retain your details to record the fact you no longer want to receive a particular newsletter.
We use external suppliers to deliver the e-newsletter, currently Mailchimp. For more information, see the Mailchimp privacy notice.
If you make an information request, make a complaint or an enquiry
Our purpose for collecting the information is so that we can respond to your complaints or enquiry appropriately.
The legal basis we rely on for processing your personal data is Legitimate Interest of both parties in resolving the issue or query raised.
Contact details and the details of your request.
To be able to investigate a complaint, respond to your query or request.
We only use your details to provide a response to you, we then retain a minimal log of complaints and access requests to be able to monitor the service and how it can be improved. We are also required to share anonymised versions of the logs with the NHS under the provision of the NHS contract.
We keep a log of complaints for eight years from the date of the complaint and subject access requests are retained for three years from the date of request.
All logs are maintained on Microsoft software internally to St Oswald’s Hospice.
If you attend an event, seminar or workshop
Our purpose for collecting this information is so we can facilitate the event and provide you with an acceptable service. The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR. When we collect any information about dietary or access requirements we will do so purely for your own safety and participation in the event. Such data will not be retained after the event has taken place.
If you wish to attend one of our events, you will be asked to provide your contact information including your organisation’s name and, if offered a place, information about any dietary requirements or access provisions you may need. We may also ask for payment if there is a charge to attend.
We use this information to facilitate the event and provide you with an acceptable service. We also need this information so we can respond to you.
If you are not successful in securing a place, we will let you know and hold your details on a reserve list in case a place becomes available. If you are allocated places at an event, we will ask for information about any dietary/access requirements. We will not share this information in any identifiable way with the venue, and we delete it after the event.
Your attendance at a course may be retained on your personnel file, otherwise your data will be deleted after the provision of the course.
We use data processors to help facilitate the events. We collect registration information from some of our conference microsites, this will be clear in any communications about the event. We would encourage you to check their privacy notices. We may sometimes charge a fee to attend an event. If this happens, our communications about the event will provide details of the data processor we use to collect payments.
If you communicate with us as a business
We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the business. If this relates to interactions regarding our regulatory functions, the legal basis is article 6(1)(e) of the GDPR. If the interactions relate to suppliers, contracts, buildings management, IT services etc., the legal basis is article 6(1)(c) of the GDPR for any legal obligation or article 6(1)(f) because the processing is within our legitimate interests as a business.
We do monitor any emails sent to us, including file attachments, for viruses or malicious software. You must ensure that any email you send is within the bounds of the law.
If you connect with us via Social Media
St Oswald’s Hospice website contains links to our social media pages where we operate our business accounts. These social media pages are hosted and operated by third parties under their own differing privacy policies. Should you choose to access one of our social media pages, you will be leaving St Oswald’s Hospice website, this Privacy Policy will no longer apply and you will be bound by the Terms and Conditions of the external Social Media site. Upon entering the Social Media site, it is your responsibility to abide by the relevant Terms and Conditions and we accept no responsibility for your misuse of any social media site.
We operate a variety of Social Media pages to allow us to operate our business, provide information about fundraising events, retail services and maximise revenue income. We also provide links to Social Media sites of partner organisations that we feel could be of legitimate interest to our supporters, patients and their families.
For social media pages that we operate, we require the supporter to request to follow our relevant social media channel.
To allow us to showcase our services, provide communication about the Hospice and our fundraising activities to generate awareness and fundraising income via Social Media pages and engagement with our followers.
We gather statistics around social media traffic and click through rates to help us monitor and improve our online presence. We are able to view the profiles of our supporters online depending on how much information they have shared via their own personal privacy settings. We engage with our supporters via social media and answer their queries online.
Our supporters follow our social media pages until either they choose to unfollow the page, they request that we remove them from the page or we choose to deactivate or close that social page.
All our social media pages and their content are stored on external servers run by external providers.
Other Privacy Issues
These are small files that are widely used in order to make websites work more efficiently. Most web browsers allow some control of cookies through browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them from your computer, visit allaboutcookies.org.
St Oswald’s Hospice may, from time to time, engage in re-marketing, which means third-party vendors, including Google, may display St Oswald’s Hospice adverts on the internet, based on your prior interaction with the St Oswald’s Hospice website. To find out more about how Google uses any data it collects please visit google.com/privacy_ads.html. Any information collected via cookies is used solely for this purpose and no other purpose.
The St Oswald’s Hospice website contains some links to websites operated by third parties under different privacy policies. Should you choose one of those links, you will be leaving St Oswald’s Hospice site and this Privacy Policy will no longer apply.
We will not use your personal data for automated decision making within any of our services or functions listed above.
Copyright © St Oswald’s Hospice, all rights reserved. Unless otherwise stated, the copyright of all the information, materials, images, logos, downloadable documents and video content on this website belongs to St Oswald’s Hospice Ltd. Information may not be published in any other format without the express written permission of the Hospice.
If we decide to change our Privacy Policy, we shall post changes on this page so that you are always aware of how St Oswald’s Hospice uses your personal information.
We have chosen not to upload all of our policies onto the website, however should you wish to view any of our data protection policies you are more than welcome to request them via: DataProtectionOfficer@stoswaldsuk.org
At St Oswald’s Hospice we often take photographs and videos most commonly for marketing and promotional purposes but occasionally it may be for medical reasons. Where necessary we will ask for written consent from participants and this can be withdrawn at any time simply by contacting a member of the communications team or the care team in the case medical photography. You should note that we are highly likely to be taking photographs and videos at events arranged by ourselves and sometimes events organised by our supporters. We consider these to be public events and as such do not obtain consent but will make every effort to make participants aware when photographs are being taken. When working with schools, we will adhere to the schools own consent arrangements for the taking and use of photographs and videos.
We may use photographs on the website, social media pages, newsletters or printed material such as leaflets or posters in order to promote the work of the hospice or fundraising efforts.
We try to take a common sense approach to the handling of imagery with relation to data protection and as such will review issues as and when they arise. If you have any concerns about any photographs or videos in use please contact the Communications team on enquiries@stoswaldsuk.org