When Hospice UK and/or its wholly owned trading subsidiary, Help the Hospices (Trading) limited (together "HUK") collect information from individuals either online or manually this is likely to be personal data within the meaning of the Data Protection Act 1998 ("the DPA"), and HUK will be a data controller under the DPA. This policy deals with the rights of individuals in relation to personal data under the DPA as well as general approaches to, and standards of, safeguarding privacy adopted by HUK.
- All HUK employees and representatives, whether permanent or temporary, must be aware of the requirements of the DPA when they collect or handle data about an individual.
- They will not disclose data except where the disclosure complies with the requirements of the DPA, or, where relevant, statutory guidance issued by the Information Commissioner's Office ("the ICO"), or any other statutory obligation. Data sent to outside agencies to process on HUK's behalf must always be protected by a written contract.
- HUK will only collect personal data that is relevant to the carrying out of the legitimate purposes and function of HUK.
- Supporters have the opportunity of opting out of marketing material from HUK and of either opting into or out of (depending on the circumstances) receiving offers and other information from other organisations with whom HUK has negotiated favourable member rates. This may be done by using the provided tick box option. These third party operated services may generate income, and other benefits, for HUK in pursuit of our aims.
- Mobile telephone numbers are never passed onto third parties for marketing purposes.
- We will strive to ensure that data collected is as accurate as possible. Individuals about whom data is held have the right to ask for details of the data held and to require the amendment or deletion of incorrect or outdated data within a reasonable time.
- Appropriate technical and organisational measures will be adopted to protect the security of all personal data held by HUK, including sensitive personal data.
- Information will be held in an environment as secure as possible. HUK employees and representatives will be responsible for ensuring that all standard data care procedures are fully and conscientiously followed.
- All ordered manual files and databases will be kept up-to-date and will have an agreed archiving policy.
- Data no longer required for the legitimate purposes of HUK will be regularly purged. A clear rationale will be supplied for personal data to be kept beyond six years.
- Where data is passed to a third party for processing, HUK will ensure that a written contract is in place that states that the agent will:
(a) process the data transferred only on the express instructions of HUK;
(b) ensure data is used in full compliance with the DPA; and
(c) implement appropriate security measures to protect the information transferred.
- Any request for data based on a legal requirement eg from police or other bodies, must, where possible, be put in writing and will be checked against the advice of HUK's Data Protection Officer (who make seek independent legal advice), before data is disclosed.
- All employees and representatives have a duty to protect individuals' data from accidental disclosure and are required to comply with the following obligations:
(a) not to give our passwords to other people, who will then have access to the data you are entitled to view;
(b) not to recycle reports that contain personal data;
(c) to take due care to ensure that data is not left about on laptops or in files either in or out of the office, where they can be accessed by unauthorised personnel.
- HUK will provide data subjects access to their personal information on request, accompanied by a fee of £10. If the data is subject to the DPA requirement that it must be disclosed, the data will be provided within 40 days of receipt of the written request and fee (time will start from the receipt of payment of the fee if this is later than receipt of the written request).
Hospice UK, Hospice House, 34-44 Britannia Street, London WC1X 9JG