Your rights Expand You retain control of how we use your data and you have the right to ask us to stop processing your personal information, which we will do. At any time, you have the right to make a Subject Access Request which entitles you to your own personal data. In some circumstances, we may legally be required to retain your personal information for legal or audit purposes. However, this will be discussed with you depending on your requirements. Any requests for patient information will be processed in accordance with: Caldicott Guardianship Policy Child Protection and Safeguarding Policy Records Management and Record Keeping Policy You have the right to: Request a copy of the information we hold about you Update or amend the information we hold about you if it is wrong Change your communication preferences at any time Ask us to remove your personal information from our records: in these circumstances we would retain your name, home address and email address on a ‘suppression list’ of individuals with whom we will not make any future contact Object to the processing of your information for marketing purposes, or Raise a concern or complaint about the way in which your information is being used. If you wish to find out more about these rights, or to obtain a copy of the information we hold about you, please contact us at: Subject Access RequestData ControllerHaven House Children’s HospiceThe White HouseHigh RoadWoodford GreenEssex IG8 9LBTelephone: 0208 505 9944Email: [email protected]
Policy changes Expand We may update this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us, or by placing a prominent notice on our website. By continuing to use our website you will be deemed to have accepted such changes. Every four years we review our approach to consent and the balancing of legitimate interest with the rights and interests of the individual. If the balancing exercise indicates a different approach would be appropriate we change our approach accordingly. We will also review this policy if there is a change in the law that requires us to do so.
Cookies Expand A cookie is a small file of letters and numbers that we may put on your computer or mobile device when you access our website. Cookies allow us to distinguish you from other users of the website, helping us to provide you with a good experience when you browse our website and also allowing us to improve our site. For example, they will tell us whether you have visited our site before or whether you are a new visitor. Another example is enabling us to show you articles that you have recently read, so that you can access them again more easily. Haven House uses cookies to help track the success of our online advertising and monitor the usage of our website. We use Google Analytics for our web analytics and work with an agency called Clear Ads to monitor our online advertising results. With cookies, the information we collect and share is anonymous and does not personally identify you. It does not contain your name, address, telephone number, or email address. Cookies can be set by the website you are visiting (first-party cookies) or by other websites (third-party cookies) whose content we are hosting, e.g. YouTube. Most web browsers allow at least a degree of control over cookies through their settings. You can opt to receive an alert whenever a cookie is set or to disallow the setting of cookies altogether. You can also delete all existing cookies. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of Haven House’s website and many other websites that you visit. For information about how to manage or delete cookies for your particular browser, please refer to the browser’s help section. Alternatively, you can visit www.aboutcookies.org, which has comprehensive information on how to manage cookies on a wide variety of desktop browsers.
Our website and social media Expand By using our website, social media pages, entering a competition or providing your information you consent to our collection and use of the information you provide in the ways set out in this policy. If you do not agree to this policy please do not use our website, social media pages or services. For all areas of our website which collect personal information, we use a secure server. Although we cannot 100% guarantee the security of any information you transmit to us, we enforce strict procedures and security features to protect your information and prevent unauthorised access. We use Raising IT to help us with our web design, and to help us gather data submitted by our website users. Our domain is hosted by Fastnet. Our website contains links to other websites belonging to third parties and we sometimes choose to participate in social networking sites including, but not limited to, YouTube and Facebook. We may also include content from sites such as these on our website. However, we do not control the privacy practices of these other sites. You should make sure when you leave our site that you have read and understood that site’s privacy policy in addition to our own. Our websites use cookies to help them work well and to track information about how people are using them. More information on cookies can be found in the section below.
The accuracy of your information Expand Our aim is for all information that we hold about you to be accurate and, where necessary, kept up-to-date. If any of the information we hold about you is inaccurate and either you advise us of this or we become aware in another way of its inaccuracy, we will ensure it is updated as soon as possible. To update any of your details please contact us by emailing our Supporter Care team or by calling 020 8506 3436 (Monday-Friday, 9am-5pm). You can also update your details anytime via our online Keeping in touch form.
Storing your information Expand Information is stored by us on computers located in the UK. We may transfer the information to other offices and to other reputable third party organisations as explained above. We may also store information in paper files.For financial and technical reasons we may, on occasion, need to use the services of a supplier outside the European Economic Area (EEA). If this were to occur we would ensure that your information is held in compliance with the Data Protection Act and the General Data Protection Regulations. By submitting your personal information you agree to this transfer, storing or processing at a location outside the EEA. We will take all reasonable steps to ensure that your data us kept secure and in accordance with this privacy policy.We will keep your information for as long as we need to, in order to deliver our services. We will take into consideration our legal obligations and tax and accounting rules when determining how long we should retain your information. We place great importance on the security of all personal data and information associated with our supporters, customers and beneficiaries. We have security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, only authorised personnel are permitted to access user information and we use secure server software (SSL) to encrypt financial and personal information you input before it is sent to us.While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to try to prevent this. We will keep your information only for as long as we need it to provide you with the goods, services or information you have requested, to administer your relationship with us, or the preferences of our supporters, to comply with the law, or to ensure we do not communicate with you if you have asked us not to do so. When we no longer need information we will always dispose of it securely.
Sharing your information Expand We will only share your information if: We are legally required to do so, e.g. by a law enforcement agency legitimately exercising a power or if compelled by a Court order. We believe it is necessary to protect or defend our rights, property or the personal safety of our staff and volunteers, or visitors to our premises or websites. We are working with a carefully-selected partner that is carrying out work on our behalf. These partners may include our lottery agency, marketing agencies, IT specialists and research firms. The kind of work we may ask them to do includes processing, packaging, mailing and delivering purchases, answering questions about products or services, sending postal mail, emails and text messages, carrying out research or analysis, and processing card payments. We only choose partners we can trust. We will only pass personal data to them if they have signed a contract that requires them to: Abide by the requirements of the General Data Protection Regulations Treat your information as carefully as we would Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation) Allow us to carry out checks to ensure they are doing all these things Many of our supporters who participate in events to raise funds for Haven House set up a personal page on a specialist website (JustGiving or Virgin Money Giving) designed to help individuals and charities raise money and maximise the use of Gift Aid. Personal data provided by Haven House supporters for this purpose to JustGiving and Virgin Money Giving is passed to Haven House. We store this information in our database and use it to communicate with our supporters about their fundraising activities. Some of our fundraising activities are set up for young children to participate in with their parent or guardian. Parents or guardians entering their children in one of these events will be asked on the relevant fundraising page (Haven House website, JustGiving or Virgin Money Giving), or on their sponsorship form, if they wish to share the child’s first name with us. If the parent or guardian gives us the child’s name, we will not add it to our database and we will never make contact with the child. We will tell parents why we are asking for the child’s name and they will have the option not to share that information with us.
Privacy for those we provide care and support to Expand Why we collect information about youWe receive information about your child from your child, you, your family and from other people involved their care (e.g. GP, health and social care professionals). We use this information to keep records about their care. These records are stored electronically or on paper and may include: Personal details like their name, address, date of birth, parent/guardian, legal representative Contacts we have with you like appointments and telephone calls Notes and reports about their health, treatment and care Relevant information from people who care for them or know them well Things we are told about wishes and preferences How records may be shared with other professionalsMembers of the Haven House Care team looking after your child may share relevant information from their records with each other. This team may include doctors, nurses, therapists, pharmacists, administration staff and people providing emotional and practical family support. It may also include students or trainees in medicine or health and social care who are working with our team. Often it is necessary to share relevant information from your child’s records with health or social care professionals in other services who are directly involved in their care. Such professionals may include GPs or district nurses, hospital teams, ambulance staff or social care services. In these circumstances, we only share relevant information from their records for medical purposes with your consent and if these people have a genuine need for it, or if we are under a legal obligation to do so. If you give us any specific instructions not to share their records in this way, we will respect this to the extent we are not prohibited from doing so by any legal obligation, although this may affect your child’s care. If it will affect care, we will let you know. Other reasons for sharing recordsYour child's records help us to review the care we provide and to make sure that it is of the highest possible standard. This includes routine audits of our care or investigating and responding to complaints, incidents or near misses. Our regulatory body, the Care Quality Commission (CQC), or NHS organisations who commission services from us, may also ask to view relevant information from these records and/or seek feedback from you about the service we provide. We may also share information with local organisations, or commissioners, to gain Commissioned care funding. If you don't want us to share relevant information from your child's records with these organisations or you don't want to provide feedback, they will respect your wishes where it is possible to carry out their checks without looking at relevant information from records and/or contacting you for feedback. Some relevant information in your child's records may also be shared with other professionals or other organisations. This might be to help teach health or social care professionals, to provide statistical information to national organisations with interests in health care or health care research. When relevant information from your child's records are shared in this way, we remove or disguise any personal or identifiable information about you wherever possible. Your wishes will be respected, and if you do not want us to share your child's records in this way it will not affect their care. Occasionally, we are required by law to share records and may therefore be prevented from respecting your wishes not to share these records. This includes when: Our regulator, the CQC, is carrying out an audit We find an infectious disease (like meningitis or measles) which may put others in danger A formal court order has been made Other organisations like the police or social services need it to prevent serious crime or where there is a child or adult at risk of abuse or neglect. How you can help usYou can help us by giving us the right details about yourself and your child, and by letting us know if you have any particular wishes about sharing your records. You can also help by letting us know when any of these details change. How we keep your records safeWe take our obligations to keep your child’s records safe very seriously. Everyone working for us, or who has received their records from us, has a legal duty to keep records confidential. They are monitored by the Caldicott Guardian, a senior clinician responsible for ensuring that people’s rights to privacy and confidentiality are respected. Haven House Children’s Hospice Caldicott GuardianEileen White – Director of CareHaven House Children’s HospiceThe White HouseHigh RoadWoodford GreenEssex IG8 9LBTelephone: 0208 505 9944Email: [email protected]
Vulnerable supporters Expand We recognise the importance of protecting our vulnerable supporters and follow the Code of Fundraising Practice in the UK issued by the Fundraising Regulator on treating donors fairly. We believe this helps to support our staff and professional fundraisers who come into contact with supporters to provide high quality customer care, ensuring anyone donating to the Charity is in a position to make a free and informed decision. If an individual appears vulnerable we will offer them a cooling-off period, or more time before taking a donation. If we believe the individual lacks the mental capacity to make a decision we do not take a donation.
In memoriam Expand Sometimes people choose to donate to Haven House in memory of a child or another loved one who has died. They may do this, for example: By setting up an ‘In Memoriam’ or ‘Tribute Fund’ page via HH website or JustGiving, or By writing to Haven House directly enclosing a cheque for funds donated at a funeral. We capture and process the information provided to us for this purpose to make sure we are sensitive and respectful in our communications with these supporters, for example empathising with their loss; thanking them for choosing to support Haven House; and letting them know who they can contact in Haven House for support and advice.
Children taking part in fundraising Expand We may process data about children under the age of 16, usually where such data is given to us by parents or guardians in the course of participating in fundraising events. For example, occasionally our sponsorship forms or our online participant forms may request the name of a child involved in raising money. Where a child’s name is disclosed to us we use the information only for the purpose of thanking them with consent of their parent or guardian. However, if we believe a supporter or donor may be under the age of 16 we take all reasonable care to establish whether their contact with us is made under the supervision of a teacher, parent or guardian. Younger children only participate in our events and fundraising activities in the presence of, or under the guidance of, a parent or guardian. Fundraising Parental Consent Form
Prospect research Expand Identifying prospective donors is necessary to securing donations from trusts and major gifts (currently defined as gifts of £500 or more) from individuals, so that we can grow our income and meet Haven House’s charitable objectives. Prospect research helps us to identify if a potential donor may have the capacity and propensity to give major gifts to Haven House; and identify how best to approach them. Prospect research includes manually gathering public and freely given information from the Internet, from Haven House contacts and from Haven House’s own donor records, and creating profiles to help us identify individuals, trusts, foundations and corporations able to give at this level. This means that we: Create short profiles of potential donors, using public and freely given sources of data to identify people who may be able and predisposed to give major gifts. These data sources may include: Charity Commission data (which identifies trustees of grant-giving trusts, and charitable aims) Other sources of information about charitable trusts’ giving, for example trustfunding.org.uk, trust websites, charity trade press Companies House data (which identifies company directors) Company and charity websites which profile, for example owners, senior partners, or Trustees News articles about business, financial or philanthropic decisions Public media where individuals have volunteered information about their interest or experience for example media interviews where individuals have spoken publicly Public social media accounts, e.g. a company’s Facebook or LinkedIn page, or an individual’s Twitter account which has a primarily professional function. Create queries on our database to identify past donors who may have given at major-gift level in the past, and therefore could do so again Review lists of individuals signing up to Haven House’s fundraising events (and have opted in to communications) to look at the reasons that people give, their job titles, their family name (if they are well-known/in the public eye) and postcodes. We use this information to target personalised invitations to engage further with Haven House at those who are most likely to be interested. Identify where our Trustees, Committees, Patrons, Ambassadors or staff may be able to help with an introduction, for example because they move in the same professional social circles as a potential donor. We do not seek consent to our prospect-research activities as defined above, because we believe we have legitimate interest which is not over-ridden by the individual’s fundamental rights. However, we will conduct a balancing exercise and review the potential processing to ensure that our use of legitimate interest is fair and lawful. If you would prefer us to not process your data for prospect research purposes, please let us know by emailing our Supporter Care team or by calling 020 8506 3634 (Monday-Friday, 9am-5pm). For prospect-research purposes we gather sensitive data only in the form of information about experience connected to the work of our hospice which the subject has willingly put in the public domain, or shared with Haven House. We do not: Gather data from personal sources such as personal Facebook and Twitter accounts Conduct automated wealth-screening using external agencies. We want all individuals who come into contact with Haven House to have a positive experience, whether or not they are donors. We believe that the way we carry out prospect research will help us to identify potential donors efficiently, and to avoid making inappropriate or excessive approaches.
Using your information for marketing Expand We will only send marketing information to individuals who have specifically said that they agree to us doing this or have a legitimate interest in our work, and we will only do so in the way(s) you have agreed to. We may contact you by mail, email, phone, text or social messaging; in some cases, this will require getting your consent. If you wish to update the way you hear from us you go to our Keeping in Touch page. If you are not currently receiving marketing communications from us and wish to do so, please let us know by emailing our Supporter Care team or by calling 020 8506 3634 (Monday-Friday, 9am-5pm). When we contact you by email, every message we send will include a link which gives you the choice to tell us that you do not wish to receive emails from us in the future through our online form. We may supplement or add to the information we hold about you with information that is available through, or we receive from, other sources, e.g. public registers, or third-party information services. This allows us to send you the most relevant information and promote those fundraising opportunities that we believe you are most likely to be interested in. If you share a personal story with us via our website or social media channels we may invite you to consent to future communications from us and to sharing your story more widely. Sometimes Haven House is invited by journalists to contribute to news stories relating to our cause, and in this situation we may invite you to participate or to allow us to use your story for these purposes. If you have asked us not to use your information for marketing purposes we will retain your name, home address and email address on a suppression list to ensure we do not continue to contact you.
Consent and Legitimate Interest Expand For some data processing activities we may need your consent before we can contact you. For processing your data for different purposes (for example, sending direct marketing) we will always check we have an appropriate lawful basis. This will most often be ‘consent’ or ‘legitimate interest’. To do this, we consider both the content of the personal data that we collect and the way in which we wish to use that data. Consent For some direct marketing channels (email and text communications) we need to have your consent to send you direct marketing – e.g., by you ‘opting in’ to future communications. Where we ask for your consent, it will be a freely given, specific, informed and an unambiguous indication of your wishes and provided by a statement or by a clear affirmative action. Legitimate interest In some cases, Haven House will process personal information under the lawful basis of ‘legitimate interest’ as long as we are sure it does not override your individual privacy rights. To assess this, we will carry out a ‘balancing exercise’ to ensure that the communication is fair and lawful. For example, we may wish to contact a donor who has given to Haven House in the past to ask them for further support, because people who have previously given are statistically more likely to support the same charity again, and this will help us to increase our funds raised. Our balancing exercise shows that: We may contact such a supporter by post without seeking express consent, so long as the number of letters is proportionate to how recently the donor gave to Haven House (for example a donor who gave to us five years ago would not expect to receive more than one letter a year). But the donor’s right to privacy and reasonable expectations over-ride Haven House’s interest in continuing contact with them by telephone or by email, and we would not therefore make any contact by these means without express consent. Where we do not need an individual’s consent for future direct marketing, we may use legitimate interest to keep you up to date with the work of Haven House and give you further information on how you can support the charity. For example, where you have previously donated to Haven House, or requested to receive some information or services, we have legitimate organisational interest to use your personal information to respond to you and to contact you in the future. However, we will ensure there is no overriding prejudice to you by using your personal information for this purpose. The processing that we might carry out includes some or all of the following: Where the processing enables us to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our customers or supporters To identify and prevent fraud To enhance the security of our network and information services To better understand how you interact with our website To provide postal communications which we believe will be of interest to you To determine the effectiveness of promotional campaigns and advertising. Wherever Haven House process data for these purposes, we will always ensure that your rights take precedence. We will give you fair and clear information on how your data is going to be used and make clear that you have the right, at any time, to object to Haven House processing your data in this way.
How do we use the information we collect and process Expand These are examples of how we may collect and use your personal information: In the provision of services, products or information you have requested. For example: The processing of any sales transactions, donations or other payments, verify financial transactions an claim Gift Aid on your donations To ask you to help us raise money, donate money to our charity or provide non-financial assistance (but always in accordance with your marketing preferences) The provision of information about our work or our activities, that you have asked to receive To send you items you have requested by telephone or via our website To analyse and improve the services we offer For administration purposes. For example: We may contact you about a donation you have made or an event you have expressed an interest in or registered for We may send you information about a race or other event you are a participant in For internal record-keeping, such as the management of feedback or complaints To record website traffic or to personalise the way our information is presented to you. For legal purposes. For example: Where the processing is required or authorised by law For the purposes of credit risk reduction or fraud prevention (regrettably some people target charities for illegal purposes such as money laundering, and we are therefore required to monitor financial activity and report suspected fraud to the appropriate authorities). For marketing purposes. For example: We may supplement or add to the information we hold about you with information that is available through, or we receive from, other sources, e.g. public registers, or third-party information services. This allows us to send you the most relevant information and promote those fundraising opportunities that we believe you are most likely to be interested in We may contact you by mail, email, phone, text or social messaging; in some cases, this will require getting your consent If you share a personal story with us via our website or social media channels we may invite you to consent to future communications from us and to sharing your story more widely. Sometimes Haven House is invited by journalists to contribute to news stories relating to our cause, and in this situation we may invite you to participate or to allow us to use your story for these purposes We may use the information for prospect research purposes. Prospect research means gathering and reviewing freely given, publicly available data (from sources such as news articles, Charity Commission, Companies House) to identify individuals and organisations who may have the capacity and inclination to give a major gift to Haven House. Gathering such data helps us to approach potential donors in the right way, and avoid excessive and inappropriate approaches. For fundraising purposes. For example, if you are a fundraiser: We advise you on setting up a fundraising page We offer you fundraising materials to help you with your fundraising We advise you on the best ways to fundraise We make you aware of your obligations, where Haven House has purchased your fundraising place.
What information do we collect, and why? Expand We will only ever collect the information we need – including data that will be useful to help improve our services. We collect information as follows: Personal data Personal data is information that can be used to identify an individual It may include your: Name Date of birth Email address Postal address Bank account details Job title and employer Mobile and landline telephone numbers Gender Marital status Your hospice experience or connection to us The reason you give us for supporting Haven House. It may also include: Details of any opt-in and opt-out preferences you have communicated to us Whether or not you are a UK tax-payer (so that we know whether or not we can claim Gift Aid) Details of any gifts you have given to Haven House Details of any Haven House events you have participated in Notes relating to our relationship with you. Examples of this could be: Correspondence between you and Haven House Connections between you and other individuals or organisations known to Haven House, and Data gathered through prospect research (see 'Prospect Research' section below for further information) Non-personal data Non-personal information such as pages accessed and files downloaded. This helps us to determine how many people use our website, how many people visit on a regular basis, and how popular our pages are. This information doesn't tell us anything about who you are or where you live. It simply allows us to monitor and improve our services Sensitive personal data Sensitive data, as defined by the GDPR, comprises: Physical or mental health or condition Sexual life Racial or ethnic origin Political opinions Religious or similar beliefs Trade union membership The commission or alleged commission by the data subject of any offence, or any proceedings for any offence that are ongoing. We collect sensitive personal data about our supporters only if there is a clear reason for doing so. For example: Where Haven House acts as an event organiser we collect information about any disability you may have if you are planning to participate. We pass this information on to our Events team, to ensure we provide appropriate support to enable you to participate. We collect sensitive personal data in the form of information about supporters’ loss of their child. We use this data on individuals’ personal experiences to ensure we provide a sensitive, caring and personalised supporter experience to them. Supporters appreciate it when we remember the name of their child that has died, and we could cause distress if we did not remember their experience. You may give us information about you when you: You may give us this information when you correspond with us by our website, phone, email or otherwise. We collect this information about you when: You ask about our activities register with us or set up an online account make a donation, fundraise on our behalf or register for an event, engage with our social media or message boards, request publications, newsletters or other information from us seek care, support and assistance from us (e.g. by contacting our Care team) volunteer with us or apply for a job (including sending us your CV) report a problem with our website otherwise give us personal information, or become known to us as someone who might consider connecting with Haven House in some way. Information we receive from other sources: We may also obtain personal information about you from other sources, such as if a family member, a friend or your GP contacts us on your behalf, or if a fundraiser passes on your details to us. We may also combine your personal information with other information we collect from third parties (e.g. for fundraising purposes). We will notify you when we receive information about you from them and the purposes for which we intend to use that information. If you are aged 16 or under, you must get your parent/guardian’s permission before you provide any personal information to us. If you do nothing other than read pages or download information from our website, we may gather information about this use, such as which pages are most visited and which events or activities are of most interest. This information can be used to help us improve our website and services and ensure we provide you with the best service. The information we use for this purpose is aggregated or anonymised, i.e. it will not identify you as an individual visitor to our website. In recording this information, we apply all the usual data protection principles outlined in this policy, so people sharing this information can feel confident that this information will not be used or stored inappropriately, and they retain the right to access this information or to request its removal at any time. If you use your credit or debit card to donate to us, buy something or pay online or over the phone, we will ensure that we manage this securely and in accordance with the Payment Card Industry Data Security Standard. If you sign up for a regular gift online, this information is held by GoCardless and access to your bank details is restricted so that only the team that processes details can access it. We do not store your credit or debit card details at all following the completion of your transaction: all card details and validation codes are securely destroyed once the payment or donation has been processed. Only those staff authorised to process payments will be able to see your card details. We do not store your financial information for longer than we need to.
Data Protection Regulation Expand In carrying out our day-to-day activities we process and store personal information relating to our supporters and we adhere to the requirements of the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations (PECR) 2003. We take our responsibilities under data protection regulation seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with those regulations above and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.