We want everyone who supports us, or who comes to us for support, to feel confident and comfortable with how their personal information will be looked after or used. We are committed to treating you with respect and openness as outlined in our mission and aims, and as part of this commitment to you, we have also appointed a Data Protection Officer whose role it is to monitor the hospice’s compliance with data protection legislation.
Who we are
Nightingale House Hospice is a registered charity that strives to provide high standards of Specialist Palliative Care for patients with life-limiting illnesses in North East Wales and the border area, whilst at the same time, supporting their families and friends in a caring setting.
What information we may collect and how we use it
We may collect personal information about you when you take part in one of our fundraising events or challenges, organise a fundraising event yourself, make a donation, play our lottery or raffles, buy or donate items to our shops, use any of our clinical services, apply to work or volunteer with us or use a third party online donation facility or events platform, such as JustGiving or Ticket Tailor or the Charities Aid Foundation, via our website.
We are registered with the Information Commissioner’s Office and our registration number is Z7435017.
Care and support services
If you are referred to one of our clinical services, including bereavement support, we will also collect data from you so that we can provide you with treatment and support. This will include information such as your name, age, address, gender, and possibly sensitive personal information concerning your health and wellbeing, ethnic origin, sex life, and religious views. It may also be necessary to take still images of you for medical purposes, such as in the case of pressure ulcers. In order to provide complete care, we may also collect some information about family members and carers.
We also may receive information about our patients and their families and carers from other healthcare providers who are involved in their treatment.
We will not use your information for other purposes without your permission including the sharing of your data with our fundraising and marketing teams, unless you specify this.
Using your information to improve our services
We use information held within your records to help improve the services that we provide. We can do this by collecting information from the records of groups of patients who have similar conditions or have received similar treatments and comparing this with what we know are the best standards of care. This helps us to identify areas where we need to make improvements. For example, if we find that some patients are waiting too long to be seen in a particular clinic, we can try to change the appointment system or increase the number of clinic appointments we have available.
This process of checking care records against best practice is known as clinical audit. It is usually carried out by the staff who have provided you with care, or by support staff who work closely with them. They will only collect your personal identifiable information (e.g. your name, or date of birth, or postcode) if it is necessary. For example, they may need to make sure that they are collecting the correct information about the same patient from different sources, such as your paper clinic records and your electronic records of blood tests.
Any information that could identify you as an individual will be removed from the record of the clinical audit as soon as it is possible to do so. Reports of clinical audits may be shared with the management of the (hospital/service/etc.) and others, but only after information that could identify you or any other patient has been removed. The record of the clinical audit will be protected by security measures such as computer passwords to limit access and destroyed after five years. There are other ways in which the information that we collect about your care can be used to help us improve our services, but we will always keep any information that could be used to identify you as an individual confidential.
If you support the Hospice in raising funds, we may collect your contact information, including email addresses and telephone numbers for administration purposes and so we can contact you in the future. This will include how you would prefer to be contacted, i.e. by post, email, etc., and also the types of activities you are interested in.
We may also collect your financial information such as your debit / credit card or bank details so that we can process payments and donations. Your date of birth, whether you are a UK taxpayer, details of your donations including Gift Aid and any relevant information required for events i.e. your t-shirt size, medical conditions, dietary requirements or emergency contact details.
If your child enters any events, for example, a fun run, then their basic personal details and any relevant information will also be retained on our systems however, we would never directly contact them as all contact, would be made via yourself.
If you sponsor an individual who is raising money for the hospice and your contact details are captured on, for example, a sponsorship form we will retain these details in line with statutory requirements. However, we will not use these details to contact you about any future fundraising activity, unless you have previously consented for us to do so. We would also never pass on your details to other third parties.
If you join our lottery we will collect your contact information, including your telephone number and bank details in order that a standing order may be set up. Following receipt of your completed application form, we may contact you by telephone to confirm the details. We may also, in the future, send you raffle tickets for draws that we think you may be interested in supporting. If you would prefer not to receive these raffle tickets please contact us so we may update our records accordingly.
If you donate items to one of our shops, we may ask you to sign up for ‘Gift Aid’. As part of this process we have a legal obligation to collect certain information about you and hold it for a period of 6 years. The information you provide will only be used for this purpose unless you consent to receiving our fundraising information.
We will also collect your details when you wish to have a piece of furniture delivered or items collected from you home. This information will only be kept until the delivery or collection has been made and the items have been processed accordingly. Again, you will not be sent any of our fundraising material unless you have consented to it.
We may occasionally undertake customer surveys to gather feedback, on for example, our Meals Matters service to help shape our service moving forward. Any data collected will be held anonymously.
If you visit the hospice or any of our retail outlets, we may collect your image on a Close Circuit Television (CCTV). This information will be retained by the hospice for up to 31 days after the recording was made. However, if we receive an enquiry about a recording on our CCTV system, we will consider retaining that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be for a number of years. However, as soon as it is no longer required, we will then delete the personal information.
Working for us
If you apply for or take a job with us, we will store your contact information, bank details, and keep records of your employment history. You may appear in still images or video footage using Closed Circuit Television (CCTV) that is used on our hospice site for security purposes. We sometimes use photos and video footage to promote and celebrate the work that we do, for which we ask your consent as staff members. This consent can be withdrawn by you at any time.
Volunteering with us
If you apply for a volunteering role with us, we will store your contact information and any other information you have given us as part of your application, including emergency contact details and details of the type of volunteering in which you are interested in and your availability. You may appear in still images or video footage using Closed Circuit Television (CCTV) that is used on our hospice site for security purposes. We use photos and video footage to promote and celebrate the work that we do for which we ask your consent as volunteers. This consent can be withdrawn by you at any time.
The legal basis for processing your personal data
Where we are processing your personal information for the purpose of providing healthcare to you then we will rely on data protection legislation’ statutory powers. These allow us to process health and social care information for the treatment of patients and the management of services.
As a charity, there are other lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the hospice has a legitimate interest in processing your information in this way to help us achieve our vision of supporting patients with life-limited illnesses, ensuring that they, their families and carers, get the support and respect they need.
Whenever we process your personal information under this lawful basis, we make sure that we take into account your rights and interests. Where we consider that these rights will be disadvantaged in any way we will look for another lawful basis, which may include seeking your consent.
In some cases, we may also process your personal information because we need to use it in order to fulfil a contract with you (for example, you have registered to join the lottery or you have signed up to Gift Aid with our retail outlets). There may also be occasions where we are required to collect your information for the purpose of protecting public health functions, such as the current Covid-19 pandemic NHS Wales test, trace and protect strategy.
Where they are no relevant statutory powers, we will only use your personal information where we have your consent to do so, for example, where we wish to contact you by email.
Please note, that where we have obtained your consent to process your personal data, you have the right to withdraw that consent at any time.
Keeping your information safe
We take looking after your information very seriously. We have implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
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 and we ensure that robust contracts are in place.
We screen our data to ensure it is kept up to date and enable us to be more efficient by targeting based on your interests or likely interests. On occasion, we may improve the quality and accuracy of the information you have provided such as your contact details by checking against publicly available sources. This helps us ensure our records are fully up-to-date and to avoid mis-directing communications. However, we would really appreciate it if you could let us know if your contact details change.
Online financial transactions are processed using SagePay which has the highest level of Payment Card Industry Data Security Standards (PCI DSS) compliance and any personal information you provide is encrypted.
How long we keep your information
Sharing your information
We will not normally share your information with any third parties without your consent unless we have statutory powers that allow us to do so.
If you are a patient at the hospice, we may share relevant information with other health and social care providers that are involved with your care, this may include sharing some information with our Chaplains so they may support you and your families / carers.
We may also share limited information with our Trustees where there is a business need to know. They will only process your personal data in line with our policies and procedures and they are subject to the same duty of confidentiality as our staff members.
We are required by law to share certain records with external agencies on activities such as investigation of a complaint, administer a gift in Will or HMRC audits.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor will we sell any information about your web browsing activity.
We will share your information with our third-party service providers who we contract to carry out certain tasks on our behalf. However, we only disclose relevant personal information that is necessary to deliver the service and we ensure we have a robust data processing contract in place to control how they manage the data they may collect or have access to. We currently use a number of third-party service providers to provide the following services (this list is not exhaustive):
- To post our supporter newsletter, gift aid mailings and event mailings
- For IT support
- To host our lottery and finance and HR databases
- To host our website
- For disposal of our confidential waste
Our website uses what are known as ‘cookies’. Our cookies are not sinister – they are simply small files, placed on your computer by your browser, to help us provide a better service. We do this to help us understand things such as how many people visit the various parts of our website. Our cookies do not identify you personally.
What information do we collect?
Your interaction with this website
We use online forms to collect data for enquiries. We store this data on our IT systems and will retain this data normally for six years, in line with our record retention and destruction schedule.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over any other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. You should exercise caution and look for the privacy statement applicable to that website.
You might also provide us with feedback or information about your experience of our services or fundraising activities that we may use to improve them or for marketing purposes. We do not identify you when we use your information in this way.
Profiling: making our work more unique to you
We want to improve how we talk to you and the information we provide through our website, services, products and information. To do this we sometimes use profiling and screening methods so that we can better understand our supporters, your preferences and needs to provide a better experience for you.
We may carry out targeted fundraising activities using profiling techniques based on the information that we hold about you and sometimes information that is available in the public domain. We do not use any third party organisations to carry this out on our behalf.
We will only contact you about our work and how you can continue to support the hospice by phone, email or text message if you have agreed for us to contact you in this manner.
However, if you have provided us with your postal address, we may send you information, such as our newsletter, by mail unless you have told us that you would prefer not to hear from us in this way.
If you would prefer not to receive updates from us or you would like to stipulate how we should get in touch with you, please contact us to let us know and we will update our records accordingly.
You have various rights in respect of the personal information we hold about you, including:
- Access to your personal information: You have the right to receive a copy of the personal data that we hold about you (this includes health records). 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. We normally expect to respond to requests within one calendar month of receiving them. You may request the data in printed or electronic format (pdf) but we will discuss this with you at the time.
- Right to object: You have the right to ask us not to process your information where we are relying on legitimate interests and there is something about your particular situation which makes you want to object to processing on that ground.
- Consent: You have the right to withdraw consent to direct marketing (including profiling related to direct marketing). You can exercise this right at any time and can ask us to update your preferences.
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Erasure: You can ask us to delete your personal information where you have withdrawn consent or where we have no lawful basis to process it.
If you wish to exercise any of these rights or make a complaint, you can contact our Data Protection Officer. If you feel that we have not dealt with your complaint satisfactorily, you can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, their details can be found at www.ico.org.uk.
How to Contact Us
If you would like to contact our Data Protection Officer with any concerns or queries you may have in relation to any of the information included in this policy, then please do not hesitate to contact Catherine using the details below.
Mrs Catherine Hughes
Nightingale House Hospice
Please also contact our Data Protection Officer if you would like to exercise any of your Rights.
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. If we want to make any significant changes in how we will use your personal data, we will contact you directly and, if required, seek your consent.
1. What is a cookie?
1.1. Cookies are small text files they are stored by your browser onto your computer or mobile device. A cookie allows your preferences or actions across a site (or across different sites) to be remembered on subsequent visits. Cookies are widely used in order to make websites work or work in a better, more efficient way. They can do this because websites can read and write these files, enabling them to recognise you and remember important information that will make your use of a website more convenient (eg by remembering your user preferences).
1.2. Most web browsers automatically accept cookies, but if you do not want information collected this way, there is a simple procedure in most browsers that allows you to deny or accept the cookies feature (please read section 5 below for more details about how to do this).
2. Cookie categorisation
To help you understand cookies, we have classified each cookie as one of the following:
(a) required cookie;
(b) analytics cookie
2.1. Required cookie
These cookies are essential to a website in order to provide the necessary functionality, such as remembering your consent preferences. Without required cookies, certain services on a website may not be made possible and a website may not perform as smoothly as it should.
2.2. Analytics cookie
Analytics cookies collect information about the use of a website and help to improve the way a website works. For example, analytics cookies may help us understand which pages are the most popular. Analytics cookies do not collect information that identifies a user personally and all information that is collected by these cookies is aggregated and anonymous.
3.1. Accepting strictly necessary cookies and performance cookies is a condition of using our website. If you reject these types of cookies then we cannot predict how our website will perform when you visit it.
3.2. You can control the use of functionality cookies, targeting cookies or advertising cookies. We explain how you can manage the different cookies we use on our website at section 5. If you prevent the use of these types of cookies then this may interrupt some services on our website.
4. Third parties cookies
4.1. In some cases, we may use third parties to manage our cookies but we do not allow any third party to use these cookies other than for the types of purpose listed in this policy.
4.2. We do not have access or control over the cookies placed on our website by third parties and use of their cookies is subject to their own privacy policies. We recommend that you review the privacy policies of each of our third parties and we have included details at the links below.
4.3. Cookies placed by third parties may serve different purposes. They may be strictly necessary, performance, functionality, targeting or advertising cookies. For more information on these different types of cookies and what they do, please see section 2.1 and 2.4.
4.4. You may manage your consent for the cookies on this site here. However, to disable or reject third party cookies you must go to the relevant third party’s website. We have explained how you can control third party cookies on your browser for the main web browsers at section 5.
5. Managing cookies
5.1. You can control which cookies you get and which you keep on your device. Unless you have adjusted your browser settings so that it will refuse our cookies, our system will issue cookies when you visit our website.
5.2. Many web browsers can be set up to ask for your prior consent before an individual cookie is set on your device. This will give you control over your cookies but naturally may interfere with your browsing experience ie if you have to accept each cookie on our website (and on other websites you visit).
5.4. Please note that by deleting cookies or disabling future cookies you may be unable to access certain areas or features of our website and it will mean that settings such as your stored username and password may have to be reset. If you adjust your cookie settings this will also affect the other websites you visit.
5.5. All of the major browsers offer tips and guidance for managing the cookies available on your browser including:
5.6. There are also lots of different third party browser plug ins and extensions available which you can download to make it easier to see and control your cookies. We have included a list of examples of these for the main browsers below.
6.Where can I get more information about cookies?
6.1. You can find out more information about internet advertising by visiting the following information websites:
6.2. Some of these sites enable you to opt out of online behavioural advertising and other tracking cookies (ie in addition to the control settings on your browser as set out in section 5).