Privacy Policy

At St Margaret of Scotland Hospice (the “Hospice”), we pride ourselves on being open and transparent with our patients, their families, our supporters, staff and anyone else who comes into contact with the Hospice including how their personal data is stored and used. This includes the processes we adopt when we ask for donations to keep our organisation running.

Purpose of this policy

This Privacy Policy explains what personal data we may collect about you, how we use it, and the steps we take to ensure that it is kept secure.

This includes, when you use this website at www.smh.org.uk, or when you contact us, for example by telephone, email, contact cards or through face to face interactions. We also explain your privacy rights and how the law protects you, including how we comply with the General Data Protection Regulation (“GDPR”), which came into effect on 25^th May 2018, and all other related privacy laws and any codes of practice issued by the Information Commissioner.

Additional information may be provided on particular pages of this website for example, on any specific pages where we collect personal data and you should also refer to those.

It is important that you read this privacy policy together with any statements or fair processing notices we may provide on specific occasions when we collect or process personal data so that you are fully aware of how and why we are using your data. This privacy policy supplements those other notices and is not intended to override them.

BY USING THIS WEBSITE AND/OR GIVING PERSONAL DATA TO US YOU INDICATE THAT YOU CONSENT TO US USING YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY

In summary, we are committed to protecting your privacy, your right to confidentiality and ensure that your personal information will be:

Processed lawfully, fairly, and in a transparent manner
Collected for specified, explicit and legitimate purposes
Only collected so far as required for our lawful purposes
As accurate and up to date as possible
Retained for a reasonable period of time, in accordance with retention policies
Processed in a manner which ensures an appropriate level of security

PERSONAL DATA

Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised and where the person’s identity has been removed.

We collect personal data in a number of ways, and for a number of reasons. For example, we may collect and hold information from fundraisers, donors and supporters in order to make better decisions about how we raise and spend funds. As a Registered Charity, our Hospice relies on the support of people living in its local community – both financially and in kind. By gathering information about our community we can fundraise more efficiently and get the right information to the right people based on what they want to see. Ultimately this means our Hospice is able to continue to provide excellent care to those in need.

Examples of Personal Data

a name and surname;
a home address;
an email address such as name.surname@company.com;
an identification card number;
location data (for example the location data function on a mobile phone);
an Internet Protocol (IP) address;
a cookie ID;
the advertising identifier of your phone;
data held by a hospital or doctor, which could be a symbol that uniquely identifies a person such as a hospital number or CHI.

We may receive your Personal Data:

through face to face interactions, through this website, by email, over the phone, or on paper (such as from any form you complete)
directly from you such as when you make a donation; when you sign up to an event or activity; when you join our Hospice Lottery; when you sign up as a Gift Aid donor in one of our shops or when you sign up as a volunteer.
from another organisation for example, where you use fundraising sites such as Just Giving or Virgin Money Giving to fundraise for the Hospice. These organisations may share your personal data with us if you allow them to do so. You should check their Privacy Policy to fully understand how they process your personal information.
from social media sites or apps. If your settings and preferences allow, we may obtain information (including personal data) from social media services such as Facebook, Instagram, Twitter and Linkedin.
automatically in the case of technical data, for example as you interact with our website including via the use of cookies and similar technologies.

Information about other people

If you provide personal data to us relating to any person other than yourself, you must ensure before you do so that they understand how their personal data will be used and that you are authorised to disclose it to us, and to consent to its use on their behalf. You should bring this privacy policy to their attention.

The personal data we collect

We will only use your personal data when the law allows us to, and in accordance with this privacy policy. We may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data.

The type and quantity of personal data we collect and how we use it depends on why you are providing it. Occasionally we may ask for your date of birth, for example, if there is an age restriction on an event or activity you have chosen to take part in (e.g. Lottery players must be aged over 16 years).

The following table explains the main types of personal data which we may collect, use, store and transfer. It also explains the purposes for which we use different categories of personal data, and the lawful basis or bases which we believe applies to those uses:

Purpose	Types of personal data used	Lawful basis for processing
To manage our relationship with you as a patient, for example to communicate with you and to provide you with the correct care and treatment.	Identity and Contact Data such as your name, home address and date of birth/CHI.	Necessary for performance of our contract with you, compliance with our legal obligations, and for our legitimate interests in providing you with our proper ongoing care and treatment.
To provide you with information where necessary, as the next of kin of one of our patients. For example, to contact you in the case of an emergency or to facilitate any elements of patient care.	Identity and Contact Data such as your name, home address, date of birth	Necessary for our compliance with our legal obligations and for our legitimate interests in providing you with necessary information about the patient, as part of our provision of proper care for that patient.
To manage our relationship with you as a volunteer, for example to contact you, or to carry out any necessary administration.	Identity and Contact Data	Necessary for our legitimate interests in managing our volunteer network to support our organisation and to comply with our recruitment policies.
To process your application for a job or volunteer role with us, including if you are between the ages of 14-16 and apply to volunteer as part of a formal work experience arrangement with your school, or as part of the Duke of Edinburgh Scheme.	Identity and Contact Data Career and Interests Data including any CV, career history information or references. Child Data including name, home address, date of birth and information about their education.	Necessary for our legitimate interests in the operation of our organisation in order to be able to respond to you and to consider you for a role within our organisation. Where we collect and process Child Data in the context of an application for volunteering, we do so on the basis that it is in our legitimate interests to be able to consider and respond to you.
To provide any products or services you request to you, including taking payments and contacting you where necessary in relation to the same.	Identity and Contact Data Financial Data including bank account numbers and details	Necessary for the performance of the contract that you have entered into with us.
To administer this website, including troubleshooting, data analysis, testing, system maintenance and support	Identity and Contact Data Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our services. Profile Data such as username and password details, demographic postcode preferences and interests, and information such as feedback and survey responses.	Necessary for our legitimate interests in providing and improving our website and customer service to you, to improving the services we offer you and to ensuring our website operates properly and for network security.
To ensure our third-party service providers can perform their obligations to us.	Identity and Contact Data Technical Data Profile Data	Necessary for our legitimate interests in ensuring that our third party providers such as external consultants and contractors are able to provide support services to us.
To deal with new enquiries	Identity and Contact Data, including any data you provide when completing the ‘Contact Us’ form on this website. Child Data	Necessary for our legitimate interests in the operation of our organisation in order to be able to respond to and deal with new enquiries. Where we collect and process Child Data in the context of a new enquiry, we do so for our legitimate interests in the operation of our organisation in order to be able to respond to and deal with new enquiries.
To facilitate your account if you join our lottery, including undertaking any necessary age restriction checks and fraud prevention measures.	Identity and Contact Data Financial Data	Necessary for the performance of the contract that will be in place between us.
To administer a donation you make to us, or to administer you as a gift aid donor. Including communicating with you in the event of a query.	Identity and Contact Data Financial Data	Necessary for the performance of the contract that will be in place between us, and for our legitimate interests in the operation of our organisation in order to be able to collect and process donations.
To sign you up for, and communicate with you in relation to an event or activity you wish to take part in.	Identity and Contact Data Financial Data Child Data	Necessary for the performance of the contract that will be in place between us and for our legitimate interests in the operation of our organisation in arranging and facilitating fundraising and awareness events and activities. Where we collect and process Child Data in the context of an event, we do so for our legitimate interests in the operation of our organisation in arranging and facilitating fundraising awareness events and activities.
To communicate with you once you have decided to leave the hospice as a volunteer, so that we can send you information about new events or activities you may wish to take part in in the future, or to send you any other information we think you may find interesting.	Identity and Contact Data	Necessary for our legitimate interests in developing, marketing and promoting our organisation.
To undertake market research in order to improve the products and services we offer.	Identity and Contact Data Profile Data	Necessary for our legitimate interests to ensure that the goods and services we provide and the work we do are appropriate.
To create a profile about you to understand your preferences, including analysing demographic and geographic information	Identity and Contact Data Profile Data	Necessary for our legitimate interests to ensure that our fundraising work is effective and to improve our ability to meet our aims.

Where it is appropriate we may also ask for:

information relating to your health (for example if you are taking part in a high risk event such as one of our treks or skydives)
how you heard about the event/activity/Hospice
why you have decided to donate to us. We understand that you may have private reasons and we only want to know the answer if you are comfortable telling us, you are under no obligation to do so
your bank or credit card details (these are used for the single transaction only and are destroyed after use). No credit card information is retained by the Hospice.

How we will use your Personal Data

All personal data that we obtain about you and/or any other person whose details you provide will be recorded, used, and protected by us in accordance with current data protection law and this Privacy Policy. We will primarily use the personal data for the following purposes:

To provide the products and services you request (including taking payments) and to communicate with you in the event that any products or services requested are unavailable, or if there is a query or problem with your request, to process your application for a job or volunteer role with us
Charity fundraising. To administer any donations (including taking payments) you agree to make, including complying with Gift Aid requirements and to communicate with you in the event of a query
personnel matters. To administer your employment or voluntary work where you become an employee or volunteer
fraud prevention. To detect and reduce fraud and credit risk
market research. To carry out market research so that we can improve the products and services we offer
demographic analysis and preferencing. To create an individual profile for you (including analysing demographic and geographic information) so that we can enhance your experience and relationship with us, understand and respect your preferences and to provide information and details of relevant offers and opportunities where you have agreed to receive them. We may undertake in-house research and engage third party organisations such as fundraising agencies to help us identify people who may be able to support us with a larger gift or in other ways, using publicly available records. We may also collect information on your interests, for example board memberships, hobbies, or articles about you in the media. We use this information to tailor our communication with you and invite potential supporters to meetings, groups and events which may be of interest to you.
Charity Regulation. To comply with our obligations as a Charity.
website monitoring. To use IP addresses and monitor website use to identify locations, block disruptive use, record website traffic or personalise the way information is presented to you

Consent and lawful processing of personal data

The legal basis for the collection and use of your personal data is you have given your consent and/or it is in our legitimate interests to contact you. We need to do so in order to support Hospice needs in the area; your rights and freedoms are not prejudiced by this. Please see the table above for further information.

Disclosing your personal data

We do not sell personal data.

In order to provide our products and services, we may, occasionally, appoint other organisations to carry out some of the processing activities on our behalf. These may include, for example, technology hosts, event administration, printing companies and mailing houses. In these circumstances, we will ensure that your personal data is properly protected and that it is only used in accordance with this Privacy Policy and our instructions.

We use third party electronic payment providers to administer some transactions. They have their own privacy policies and we encourage you to read them. St Margaret of Scotland Hospice is registered as compliant with PCI DSS (Payment Card Industry Data Security Standards) and this is renewed annually. The data security standards were designed to ensure that ALL companies that accept, process, store or transmit credit card information maintain a secure environment and to reduce credit card fraud.

On very rare occasion, we may be required to disclose your details to the police, regulatory bodies or legal advisors or to comply with a court order or a legal obligation. In these circumstances we would be careful to only provide information that we are required to provide.

SPECIAL CATEGORIES OF DATA

By the nature of what we do, we may need to process ‘special categories’ of data for clinical purposes. A special category of data would include details about your race or ethnicity, sex life, sexual orientation, and information about your health and genetic data.

St Margaret of Scotland Hospice is a local, independent Charity and we are not part of the NHS, but we do work very closely with all NHS services in Glasgow/West Dunbartonshire and East Dunbartonshire. Clinical information is part of the NHS records system. This allows us to share information securely with your GP and other care professionals.

If you are a patient or service user, we may contact you with important information regarding your care or support available to you, in the way that you have requested.

If you are the next of kin of a patient, we may contact you in the event of the death of a patient with further information on our services, for example, to offer bereavement support.

If you have agreed to take part in a clinical research study, the information about your health and care may be provided to researchers running other research studies in this organisation and in other organisations. These organisations may be universities, NHS organisations or companies involved in health and care research in this country or abroad.

In accordance with NHS guidance, the Hospice has an appointed Caldicott Guardian; a senior member of staff responsible for protecting patient confidentiality and enabling appropriate sharing. The sharing of sensitive personal information is strictly controlled by law. We will consult you before information about you is shared to ensure we act with your consent. If you are unable to consent for any reason, we will only share information where it is in your best interests to do so.

If you are unable to consent to the processing of your personal data for any reason, for example if you are physically or legally incapable of giving your consent we will only share your information on the basis that it is necessary in order to protect your vital interests, and it is also necessary in our legitimate interests in providing our proper care to you.

We may also process special categories of data about you if we need to assess your health needs such as to administer medicine to you or for the purposes of medical diagnosis. We would process your data in this way on the basis that it is necessary for the purposes of preventative or occupational medicine, or for medical diagnosis, as well as it being in our legitimate interests in providing our proper care to you.

WEBSITE

IP addresses

In order to understand how users use this website and our services, we may collect your Internet Protocol addresses (also known as IP addresses). Your IP address is a unique address that computer devices (such as PCs, tablets and smartphones) use to identify themselves and in order to communicate with other devices in the network.

Cookies

We use cookies on the Hospice website to make your browsing experience more efficient and enjoyable.

Cookies are small text (.txt) files containing basic information about a particular website and user. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.

If you would like to disable cookies, you can change your browser settings to reject cookies. However, this may negatively affect how some of our content is displayed and how our website functions.

For more information about cookies, visit www.aboutcookies.org.

Links to other websites

Please note this website may contain links to other websites that are not controlled by us. These links are provided for your convenience. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are only responsible for our privacy practices and our security. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit and each organisation that holds your personal data.

HOW WE MIGHT CONTACT YOU

We may need to contact you for various reasons in a number of ways. If you have given consent or there is legitimate interest, we may use your data, including identity and contact data, technical data and marketing and communications data, to contact you with further information about the Hospice, our work, fundraising requests and any news or upcoming events. We will not send you such communications if we know that you are a child.

Email communications may contain tracking beacons/tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

We will usually try to tailor the communications we send to you so that they are relevant and in line with the preference options you have chosen which form part of the personal profile we will create for you.

Preferences / Subscribe / Unsubscribe

You and any other person whose personal data you have provided to us can change your/their mind about whether you wish to receive information.

You can change your preferences at any time by using any of the methods shown below (see the section ‘Updating and correcting personal data’) or by following the instructions with each communication you/they receive.

Please note it may take up to one month for your changes to be implemented and for communications to start or cease.

SECURITY

We take the security of personal data seriously. We employ security technology, including firewalls, and encryption to safeguard personal data and have procedures in place to ensure that our paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage.

Personal data in our databases is only accessible by appropriately trained staff and volunteers who need to access your personal data as an essential part of their role. All access is tracked through individual login credentials.

We only use third party service providers where we are satisfied that the security they provide for your personal data is at least as stringent as we use ourselves. They will only process your personal data on our instructions, for specified purposes, and are subject to a duty of confidentiality.

RETENTION

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, insurance or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and the applicable legal requirements.

In some circumstances, we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.

Everyone who has supported the Hospice in some way will hear from us at least once a year, unless you have opted out of communication from us. We will continue to do this until you tell us otherwise. We will always provide details in our communications of how you can opt out.

TRANSFER OUTSIDE OF EUROPE

If we ever need to transfer your personal data to other territories outside of the United Kingdom or the European Economic Area, we will take proper steps to ensure that it is protected in accordance with this Privacy Policy and applicable privacy laws.

CHANGES TO THIS POLICY

Privacy laws and practice are constantly developing and we aim to meet high standards. Our policies and procedures are, therefore, under continual review. We may, from time to time, update our security and privacy policies.

We will ensure our website has our most up to date policy and suggest that you check this page periodically to review our latest version

UPDATING OR CORRECTING YOUR DATA

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

In order to save the Hospice money, we may use data cleansing services to update us on people who have moved home or who have died. If you have registered a change of address with the Post Office’s National Change of Address database, we will update your details through this mechanism. Similarly, for relevant activity, if you use the Fundraising Preference Service to withdraw consent to receiving direct marketing from us, we will amend our records accordingly.

You may update or correct your personal data by contacting us at the address below, asking us to update your details. Please include your name, address and/or email address when you contact us as this helps us to ensure that we accept amendments only from the correct person.

If you are providing updates or corrections about another person, we may require you to provide us with proof that you are authorised to provide that information to us. You must also ensure that you have that person’s consent to pass on their details and make them aware of this privacy policy.

If you wish us to remove your data, please email remove@smh.org.uk

YOUR RIGHTS

You have a number of legal rights in respect of your personal data. Depending on the circumstances, these may include:

access. The right to receive a copy of the personal data that we hold about you. The same right applies to any other person whose personal data you provide to us. We will require proof of identity and proof of authority if the request comes from someone other than the person whose data we are asked to provide. This will ensure we only provide information to the correct person. In the first instance, please email rightofaccess@smh.org.uk or write to the Hospice Administrator or Data Protection Officer (See Contacts section). We normally expect to respond to requests within one month of receiving them.
withdraw consent to direct marketing. You can exercise this right at any time and can ask us to do update your preferences. See section ‘Updating and correcting your personal data’ above for details.
withdraw consent to other processing. Where the only legal basis for our processing your personal data is that we have your consent to do so, you may withdraw your consent to that processing at any time and we will have to stop processing your personal data. Please note, this will only affect a new activity and does not mean that processing carried out before you withdrew your consent is unlawful.
rectification. If you consider any of your personal data is inaccurate, you can correct it yourself or ask us to do it for you (see section ‘Updating and correcting your personal data’ above for details).
restriction. 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.
erasure. Where we have no lawful basis for holding onto your personal data you may ask us to delete it.
portability. 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.
to complain to the Information Commissioner’s Office. This is the UK supervisory authority for data protection issues. You can find information on how to make a complaint at www.ico.org.uk. We would however, like the opportunity to assist with any concerns before you approach the ICO, so please contact us in the first instance using the details above.

Exercising your rights

Please contact us if you wish to exercise any of your rights.

You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is considered unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will keep you updated.

CONTACT

St Margaret of Scotland Hospice is the Data Controller in respect of all personal data collected by us. We employ a specialist Data Protection Officer to ensure we comply with our legal duties.

The contact details are as follows:

Clare Murphy - Administrator
John McGlone CISSP CRISC - Data Protection Officer

St Margaret of Scotland Hospice Cyber Consultancy & Privacy Practice

East Barns Street 11 Market Street

Clydebank Stirling

G81 1EG FK8 1TU

Phone : 0141 952 1141 0333 305 6558

Email: clare.murphy@smh.org.uk DPO@MSCLtd.org

Policy

INTRODUCTION