Privacy Notice

At Highland Hospice, we are committed to protecting your personal information and privacy. We comply with all legislation regarding the collection and use of personal data. This Privacy Notice describes how we collect and use your personal information.

We may update this Privacy Notice from time to time so please check back periodically. We will notify you of significant changes by placing a notice on our website.

If you have any queries about this Privacy Notice, please contact our nominated person responsible for Data Protection who is our Head of People on 01463 243132 or generalenquiries@highlandhospice.org.uk.

In this Privacy Notice, ‘Highland Hospice’ means Highland Hospice (registered as a charity in Scotland, No SC011227 and a company limited by guarantee (SC093464) and/or Highland Hospice Trading Limited (registered company SC110041), whose offices are at Ness House, 1 Bishops Road, Inverness IV3 5SB. We are registered with the Information Commissioner’s Office, registration reference Z691694X.

We collect personal information about you when you interact with us (e.g. in person, by phone or online) in order to:

• access one of our clinical, educational, social care or support services
  
• be acknowledged as the next of kin of one of our service users
• apply to work or volunteer with us
• enquire about our activities and services
• make a donation
• participate in an event
• donate to our shops
• buy from our online shop

We may also receive information about you from third parties that we work with or support, for example the NHS The Highland Council, GP's, our service users, Local Hospice Lottery, JustGiving, pension providers or Disclosure Scotland.

Service Users and Next of Kin

The types of information we might collect from patients and clients and their family members include names, postal addresses, email addresses, phone numbers, date of birth and next of kin as well as information of a medical and personal-sensitive nature.

This information is collected for the purposes of providing clinical and social care services to those referred to us and could be used and shared between departments within the organisation as well as with other health and social care service providers under strict guidelines. We may also receive further information from the NHS and The Highland Council which is only shared with us under strict guidelines and where information sharing could improve the delivery of care or is necessary for direct care.

We may also use more sensitive types of personal information, including information about racial or ethnic origin; religious or philosophical beliefs; health or sexual orientation.

Employees and Volunteers

The types of information we might collect from employees and volunteers include your name, postal address, email address, phone numbers, date of birth, next of kin, employment history, disabilities relevant to your employment or volunteering role, and character or employment references.

We may collect personal-sensitive information including but not limited to race, faith, gender, religion, disability and family life for statistical and reporting purposes but these will be anonymised and no individual will be identifiable.

Supporters

The types of information we might collect from supporters include your name, postal address, email address, phone numbers, date of birth, next of kin, communication preferences, credit or debit card details, and whether you are a tax payer so that we can claim Gift Aid. We also hold records of your donations and fundraising efforts alongside the communications that we have had with you.

We will not store credit or debit card details after they have been processed.

We do not collect personal-sensitive data such as race or disability, about our supporters unless there is a legitimate reason for this (e.g. if you participate in an event for which we may need to provide support.)

Service Users and Next of Kin

The lawful basis for processing service users and next of kin data is the legitimate purpose of providing a health and social care service. Special category data held on service users is processed for the purposes of providing a health and social care service.

If you, a relative or a friend, are cared for or supported by Highland Hospice, the personal-sensitive information you provide to us will be used only for the purposes of offering access to and providing you with services including bereavement support, for training our staff or for monitoring the volume and quality of our services. Highland Hospice will not disclose your personal information to any third party without your consent, except in the following circumstances:

• to health and social care professionals and organisations involved in the provision of your care, and always within the appropriate regulations governing sharing of your health and social care records.
• to the NHS Scotland Information Services Division as part of a statutory return on our activity.
• exceptionally, to professional bodies or otherwise as required by law, regulation or codes of practice.
  
• from time to time, Highland Hospice may participate with partners in research projects for the furtherance of work in the field of palliative care. We will only ever use service user data with the explicit consent of the individual.

We will not use your information for other purposes without your permission. If you tell us about your own experience with terminal illness or the experience of someone else we will explain how we will use that information. If you don’t want us to use such information for other purposes or change your mind at any time, it will not affect any services we provide.

If you receive education, training or mentoring we will use your personal details only for the purposes of offering access to and providing you with such services.

Employees and Volunteers

The lawful basis for processing employee and volunteer data is the legitimate purpose of managing the relationship between the Hospice and the employee or volunteer.

We use the information collected on our employee and volunteer application forms to identify if you are suitable to work for or volunteer with Highland Hospice. If your application is unsuccessful we dispose of your data within six months. If your application is successful we will retain a copy of your application form and your data will be stored electronically to allow us to manage the employment or volunteering relationship we have with you.

If you cease to be employed by Highland Hospice we will retain your personal data for a period of six years.

If you cease to volunteer with Highland Hospice we will retain your personal data for a period of one year.

Our Volunteer data is stored on a cloud-based programme called ‘Volunteer Impact’. The Volunteer Impact servers are based in Canada and so your personal data will be stored and accessed by us in Canada. The European Commission has determined that data storage in Canada offers an adequate level of data protection.

Supporters

The lawful basis for processing data held on recent (donation made within the past two years) supporters is the legitimate purpose of raising charitable funds to support the delivery of a health and social care service in the Highlands. If for a period of two years you stop making donations we only process your data with your consent.

We use the personal information collected from you for a number of purposes, including:

• to provide you with services, products or information you have requested;
• to process and acknowledge donations or payments we have received from you;
• to fulfil sales made online or through our shops;
• to record and administer your participation in events for which you have registered;
• to record your gifts of money or the sale of goods you donated to our shops and, if appropriate, to reclaim tax paid on these through the Gift Aid scheme;
• to keep a record and breakdown of our fundraising income which we may analyse to help us improve income in future years;
• for a period of two years following your most recent donation to send you newsletters and fundraising information unless you choose not to receive these. If a period of two years passes without a donation we will only continue to mail you with your consent (see section on ‘Your Updates and Preferences’ below).
• to analyse and improve our work, services, activities, products or information (including our website) or for our internal records;
• for fraud prevention, credit risk reduction or otherwise as required by law or regulation;
• to improve our communication with you and to contact you in the most appropriate and relevant way.

We may also use your details:

• to invite voluntary participation in research or surveys;

When you use our secure online donation or payment pages you will be directed to a specialist supplier company, who will receive your credit card number and contact information to process the transaction. We do not retain your credit or debit card details.

We use external companies to help us with larger mailings and to process Direct Debits, these companies are UK based and are data protection compliant. If you complete a Gift Aid declaration we will share your name and address and the value of your donations with HMRC for the purposes of reclaiming tax paid.

We will never sell or share your data with any other third party unless required by law.

It is important that we keep your personal information up to date. You can contact us on 01463 243132 or generalenquiries@highlandhospice.org.uk at any time if your circumstances change.

For our legitimate fundraising purposes we will mail you newsletters and fundraising information for a period of two years following your latest donation. If a period of two years passes without a donation we will contact you to provide an option to consent to continue to hear from us. Any consent provided will be valid for a period of five years without a donation.

You can stop receiving mail at any time by contacting the Fundraising Team on 01463 243132 or generalenquiries@highlandhospice.org.uk.

You can stop receiving emails or texts by clicking on the “unsubscribe” link in our marketing emails or sending us an “opt out” text message.

You can update your contact preferences by contacting the Fundraising Team on 01463 243132 or generalenquiries@highlandhospice.org.uk.

We will not use your details for fundraising or related purposes if you tell us not to, however, we will retain your details on our database to help ensure that we do not contact you again.

We will never sell your data to any third party. We will not share your details with other charities for marketing purposes.

We will only share information with other organisations where we have your permission to do so in accordance with this Privacy Notice, where it is necessary for a legitimate reason connected with the services we offer or where it is required by law or regulation.

Sometimes, we may need to share your information with a small number of trusted partners (service providers, agents and affiliated companies) for the purposes outlined above (e.g. a supplier that produces promotional material or delivers goods for us or a supplier that processes payments securely). Where we use third parties, we require them to adhere to appropriate controls to protect personal information.

We use Microsoft Office 365, Cybertill, SMI Staffcare, SPARK, Salesforce, Raiser’s Edge and OASIS which are multi-tenant cloud services, to store data. This means that internal documents and information which are generated at Highland Hospice are stored in cloud services which are hosted within the European Economic Area (EEA).

Our Volunteer data is stored on a cloud-based programme called ‘Volunteer Impact’. The Volunteer Impact servers are based in Canada and so your personal data will be stored and accessed by us in Canada. The European Commission has determined that data storage in Canada offers an adequate level of data protection.

If you participate in the Project ECHO telementoring service your details will be stored in the iECHO database located in the USA for the purposes of recording your participation in ECHO sessions. Storage of data in the USA may not meet the same standards as those in the UK and you will be asked to consent to this at the time we record your details.

We may, on an exceptional basis, use other tools or services which process data outside the EEA. In these cases we require suppliers to ensure adequate protection for personal data e.g. Microsoft may provide us with emergency support for Office 365 from outside the EEA in rare circumstances.

Highland Hospice is committed to keeping your personal information safe and secure and we have security policies and technical measures in place to help protect your information.

Unfortunately, no data transmission over the internet can be guaranteed 100% secure. As a result, while we strive to protect your personal information, Highland Hospice cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

As a user you can help protect the integrity of any data you transmit to Highland Hospice by taking common precautions such as regularly allowing patching for your operating system, ensuring you are running up to date and supported anti-virus software, and only transmitting data where HTTPS appears at the beginning of the page URL (this refers to the security technology Secure Sockets Layer (SSL) and indicates that the data is being transmitted securely).

You have the following rights with regard to the data we store about you:

• The right to be informed
• The right of access
• The right to rectification
• The right to erase
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling (we do not use automated decision making or profiling).

If you wish to exercise any of these rights please review our Subject Access Request Guidelines available here or contact our Head of People on 01463 243132 or generalenquiries@highlandhospice.org.uk for more information. If after speaking to us you are unhappy with our use of your personal data, you have the right to complain to the Information Commissioner’s Office.

The Caldicott Guardian, the Head of Clinical Services, is responsible for overseeing the request process and approving the release of information relating to patients/clients and former patients/clients of the Hospice.

If the patient/client is incapable, within the meaning of the Adults with Incapacity (Scotland) Act 2000 (asp 4) in relation to making or authorising the application, any person entitled to act on behalf of the patient/client may make a request.

Where the patient/client has died, the patient/client’s personal representative and any person who may have a claim arising out of the patient/client’s death may make a request.

If you wish to make a Health Record Request please review our Subject Access Request Guidelines available here or contact our Head of People on 01463 243132 or generalenquiries@highlandhospice.org.uk for more information.

We use these to improve the user’s experience of our website, temporarily store data and understand the parts of the website that users are visiting. Cookies help us gather statistics on the use of our website anonymously. You can set your browser to not accept cookies, but this may affect the functionality of the website. More about cookies can be found at www.allaboutcookies.org.

We are a partner in the Local Hospice Lottery which is run by Local Hospice Lottery Ltd. We have installed a Meta Pixel on our web page for the lottery which allows LHL Ltd to track marketing activity.

View our Cookie Policy and a full list of cookies on our site here.

This notice only applies to Highland Hospice and its subsidiary companies, so when you link through to our partner companies (e.g. to donate, register for an event or pay in the online shop) please read their own privacy notices.

If you have any queries in relation to our collection, storage, processing and use of personal information, please contact our nominated Data Protection Officer who is our Head of People on 01463 243132 or generalenquiries@highlandhospice.org.uk.