Sisters Hospitallers of the Sacred Heart of Jesus Charitable Trust (the Charity) is committed to protecting and respecting your privacy. For the purposes of the General Data Protection Regulations (GDPR) and any subsequent UK legislation covering data protection the Data Controller is the Charity.
This Policy sets out why we collect personal information about individuals and how we use that information. It explains the legal basis for this and the rights you have over the way your information is used.
This Policy covers the Charity in relation to the collection and use of the information you give us. We may change this Policy from time to time. If we make any significant changes we will advertise this on the website or contact you directly with the information. Please check this page occasionally to make sure you are happy with any changes.
If you have any questions about this Policy please contact The Provincial who will direct your question appropriately. Contact details: telephone 0207 373 3054, email firstname.lastname@example.org or by post to Sisters Hospitallers of the Sacred Heart of Jesus, 42 Roland Gardens, London SW7 3PW.
If you have any questions concerning your personal information please contact in the first instance The Manager at your Care Home address or The Provincial (details above).
What type of personal information we collect
The type and amount of information we collect depends on why you are providing it
As part of the services we offer, we are required to process personal data about our staff, our service users and, in some instances, the friends or relatives of our service users and staff. “Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
The information we collect when you make an enquiry includes
- Your basic details and contact information eg your name, date of birth, email address, postal address, phone number and next of kin
- Your financial details, eg details of how you pay us for your care and your funding arrangements
We also record the following data which is classified as “special category”
- Health and social care data about you, which might include both your physical and mental health data.
- We may also record data about your religion so that your wishes regarding religious life may be respected.
- Our Regulator for Health and Social Services requests race, ethnic origin and sexual identity on their notifications.
How we collect information
We may collect information from you whenever you contact us or have any involvement with us for example when you:
- visit our website (see our Cookies policy)
- donate to us or fundraise for us
- enquire about our activities or services
- apply for a job role with us
- volunteer for us
- attend a meeting with us and provide us with information
- contact us in any way including online, email, phone, SMS, social media or post
Where we collect information from
We collect information:
- From you or your legal representative(s) when you give it to us directly: You may provide your details when you ask us for information or make a donation, volunteer, attend our events contact us for any other reason.
- Third parties eg local social services.
- When it is in available on social media: Depending on your settings or the privacy policies applying for social media and messaging services you use, like Facebook, Instagram or Twitter, you might give us permission to access information from those accounts or services.
We do this face to face, via phone, e-mail, post, application forms and via our website
How we use your information
We will use your personal information in a number of ways which reflect the legal basis applying to processing of your data. These may include:
- providing you with the information or services you have asked for
- processing donations you make, including processing for Gift Aid purposes
- organising volunteering activity you have told us you want to be involved in and in relation to the fundraising for us you are involved in
- sending you communications with your consent that may be of interest including marketing information about our services and activities, campaigns and appeals asking for donations and other fundraising activities and promotions for which we seek support
- when necessary for carrying out your obligations under any contract between us
- seeking your views on the services or activities we carry on so that we can make improvements
- maintaining our organisational records
- analysing the operation of our website and analysing your website behaviour to improve the website and its usefulness
- processing job applications
Our legal basis for processing your information
The use of your information for the purposes set out above is lawful because one or more of the following applies:
- Where you have provided information to us for the purposes of requesting information or requesting that we carry out a service for you, we will proceed on the basis that you have given consent to us using the information for that purpose, based on the way that you provided the information to us. You may withdraw consent at any time by emailing us at [insert contact details]. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.
- It is necessary for us to hold and use your information so that we can carry out our obligations under a contract entered into with you or to take steps you ask us to prior to entering into a contract.
- It is necessary to comply with our legal obligations – generally under the Health and Social Care Act 2012 or Mental Capacity Act 2005
- In regard to your special category data it is necessary due to social security and social protection law (generally this would be in safeguarding instances) or for us to provide and manage social care services;
- We are required to provide data to the Care Quality Commission (CQC), as part of our public interest obligations.
- Where the purpose of our processing is the provision of information or services to you, we may also rely on the fact that it is necessary for your legitimate interests that we provide the information or service requested, and given that you have made the request, would presume that there is no prejudice to you in our fulfilling your request.
If you want to contact us about your marketing preferences please contact our Communications Coordinator on email@example.com
How we keep your information safe
We understand the importance of security of your personal information and take appropriate steps to safeguard it.
We always ensure only authorised persons have access to your information, which means only our staff, volunteers and contractors, and that everyone who has access is appropriately trained to manage your information.
No data transmission over the internet can, however, be guaranteed to be 100% secure. So while we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.
Who has access to your information?
- Third parties who provide services for us, for example
- other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, clinical commissioning groups
- the local authority
- organisations we have a legal obligation to share information with eg the CQC and the Safeguarding Commission
- our caterers for dietary requirements
- We select our third party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do.
- Analytics and search engine providers that help us to improve our website and its use.
- Third parties in connection with restructuring or reorganisation of our operations, for example, if we merge with another charity. In such event, we will take steps to ensure your privacy rights will be protected by the third party.
Owing to matters such as financial or technical considerations the information you provide to us may be transferred to countries outside the European Economic Area (EEA), which are not subject to the same data protection regulations as apply in the UK. This may be because data it is stored on servers outside the EEA. We meet our obligations under GDPR by ensuring that the information has equivalent protection as if it were being held within the EEA. We do this by ensuring that any third parties processing your data outside the EEA either benefits from an adequacy determination for GDPR purposes and/or, where appropriate, we have entered into a Data Processing Agreement which contains model EU clauses.
We may also disclose your personal information if we are required to do so under any legal obligation and may use external data for the purposes of fraud prevention and credit risk reduction, or where doing so would not infringe your rights, but is necessary and in the public interest.
Other than this, we will not share your information with other organisations without your consent.
Keeping your information up to date
We really appreciate it if you let us know if your contact details change. You can do so by contacting your Care Home Manager or The Provincial, contact details: telephone 0207 373 3054, email firstname.lastname@example.org or by post to Sisters Hospitallers of the Sacred Heart of Jesus, 42 Roland Gardens, London SW7 3PW..
“Cookies” are small pieces of information sent by a web server to a web browser, which enable the server to collect information from the browser. They are stored on your hard drive to allow our website to recognise you when you visit.
We appreciate that our supporters are of all ages. Where appropriate we will ask for consent from a parent or guardian to collect information about children (under 16s).
How long we keep your information for
We will hold your personal information for as long as it is necessary for the relevant activity. By way of example, we hold records of donations you make for at least six years so we can fulfil our statutory obligations for tax purposes.
Where we rely on your consent to contact you for direct marketing purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. This will usually be for two years. We may periodically ask you to renew your consent.
If you ask us to stop contacting you with marketing or fundraising materials, we will keep a record of your contact details and limited information needed to ensure we comply with your request.
You have the right to request details of the processing activities that we carry out with your personal information through making a Subject Access Request. Such requests have to be made in writing, after 25 May 2018 no charge may be made under GDPR except in very limited circumstances which will be explained to you if relevant. More details about how to make a request, and the procedure to be followed, can be found in our Data Protection Policy. To make a request contact The Provincial, Sisters Hospitallers of the Sacred Heart of Jesus, 42 Roland Gardens, London SW7 3PW.
You also have the following rights which were introduced in the UK under the GDPR in May 2018:
- the right to request rectification of information that is inaccurate or out of date;
- the right to erasure of your information (known as the “right to be forgotten”);
- the right to restrict the way in which we are dealing with and using your information; and
- the right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”);
- rights in relation to automated decision making and profiling including profiling for marketing purposes.
All of these rights are subject to certain safeguards and limits or exemptions, further details of which can be found in our Data Protection Policy. To exercise any of these rights, you should contact The Provincial at the above address.
If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner’s Office. Further details about how to complain can be found here.
This Policy may be changed from time to time. If we make any significant changes we will advertise this on our website or contact you directly with the information.
Do please check this Policy each time you consider giving your personal information to us.
This Policy was last updated 25th May 2018
 The Fundraiser Regulator states that the period should be assessed having regard to how long the individual would consider it reasonable to be contacted before they are asked to renew consent. (See Fundraiser Regulator’s Personal Information and Fundraising: Consent, Purpose and Transparency 21 February 2017 www.fundraisingregulator.org.uk).