This Policy has been brought about by and is in line with The Data Protection Act 25/5/18
Who are Abergele Hospital league of Friends (AHLOF)?
We have served Abergele Hospital since 1963 when we first became a league, becoming a Registered Charity in 1976. We raise funds by operating a Tea Bar at the hospital which is staffed entirely by volunteers. We also hold other Fund-raising events during the year, including a Choir performance, Summer Fete and Coffee Morning. All funds raised are used to support the hospital in a variety of ways.
We take privacy seriously
AHLOF as a “data controller” is committed to preserving your privacy and is committed to the protection of your personal data. This privacy notice will inform you as to how we will look after your personal data and tell you about your privacy rights and how the law protects you.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
AHLOF complies with the General Data Protection Regulation (GDPR) 2018 in relation to personal information that you give us and ensures it is not misused. The regulation defines a set of rules and guidelines we must follow when handling your information. These are referred to as the General Data Protection principles and ensure personal information shall be:
- a) processed lawfully, fairly and in a transparent manner in relation to individuals
- b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest , scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes
- c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- d) accurate and ,where necessary, kept up to date; every reasonable step must be taken to ensure that personal information is accurate, having regard to the purposes for which they are processed, are erased or rectified without delay
- e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed; personal information may be stored for longer periods insofar as the personal information will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
- f) processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss, damage or destruction, using appropriate technical or organisational measures.
How we use your personal information
Patients or people who donate funds or items to the League:
AHLOF will never retain any data from hospital patients. Consent will always be requested to use a name. Any patient giving a donation will be mentioned at Committee meetings but not noted in the minutes. Another example would be displaying a plaque using a name linked to a donation or a particular service-consent would always be sought for this.
Volunteers and Committee members:
How we use your personal data: We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- Where we need to perform the agreement we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation (ie. The Charity Commission)
Information we collect from you
We will collect information from you when you join our business, for example when applying to volunteer as a member of our tea bar staff. When you contact us you may be asked to provide certain information about yourself including your name and contact details.
We may collect, process and store such information as:
- Names, date of birth (Committee members only) contact details and preferences (ie days you may be willing to work)
- Volunteering Application forms
- Signed agreements and declarations (ie as a trustee of the League)
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so that we can support you in your role. Generally the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you).
We may apply markers to your information (for example, in relation to your application to volunteer) to enable us to ensure it applies to you. It is important that you notify us of any changes to your personal information.
When using the website http//www.abergele-friends.co.uk no personal information will be recorded other than information provided to us by you (i.e Officers of the League, or recording of events)
How we will use the information about you
We will process your personal information in accordance with the principles of the GDPR. We will treat your personal information fairly and lawfully and we will ensure the information is:
- Processed for limited purposes;
- Kept up to date and not excessive;
- Not kept longer than is necessary;
- Kept secure.
We collect personal information about you to process applications to volunteer and become a member of the Committee.
Unless required or permitted to do so by law, we will not otherwise share any of the personal information you provide us with without your consent.
Sharing your personal information
Access to your personal information will normally be limited to ourselves. AHLOF will only disclose your personal information to third parties with your consent, however we may sometimes need to share information without your consent to comply with any legal obligation or to fulfil the purposes for which it was submitted.
Photographs may be taken at our public events which may be used for publicity purposes. Notices will be posted at public events asking volunteers or service users to inform us directly if they are unwilling to allow their photographs to be used in this way. Individuals who are photographed alone will always be asked for their permission to use their photographs in any publicity material, or for any other purpose.
AHLOF will never transfer your personal information outside of the E.U
We will share specific and relevant information with law enforcement and government agencies or
Public bodies (where we are legally required to do so).Examples may include:
- The prevention and detection of crime and fraud
- The apprehension or prosecution of offenders
- Sharing in connection with legal proceedings
- Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm
We may also share your information with Emergency services and local authorities where this is necessary to help them respond to an emergency situation that affects you.
Security and data retention
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition we limit access to your personal data to those volunteers, agents, contractors or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
AHLOF have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We aim to ensure that members do not misuse any confidential information, or pass on this information improperly to a third party. We protect personal information by structuring and implementing policies and procedures, and regularly reviewing our processes.
- Paper files and records containing personal information are kept in a secure location. Members are provided with guidance on secure handling of records when taken from the hospital.
- We ensure any information on our computer system is secure, accurate, relevant and necessary. All our computers are secured with passwords, and members are fully trained on our systems, this includes any personal computers/devices used by volunteers for conducting AHLOF business.
- If a member is to retire they will be required to purge all this information held within their personal storage.
When a member of the public contacts us by phone, the information is only disclosed to the correct members. Information such as name, phone number and query will be dealt with by an appropriate member of the League of Friends. Following completion of activity/query this information is destroyed unless required by AHLOF to be kept for future purposes i.e events, fund-raising, short-term storage of volunteering enquiries.
If someone contacts us to raise a complaint on your behalf we will always seek your permission first. This is because in responding to the complaint, the person claiming to represent you might view some of your personal data.
How long will you use my personal data for?
We will only retain your data for as long as necessary to fulfil the purposes we collected it for, including the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data and whether we can achieve those purposes by other means, and the applicable legal requirements.
We will never collect or retain any data from hospital patients, apart from a name for the purpose of dealing with an enquiry or complaint.
Your rights under GDPR
Under certain circumstances you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data when there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes
you want to object to processing on this ground that you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenario’s: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) you have objected tour use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Access to your information
If you wish to exercise any of the rights set out above, please contact the Data Protection Officer on the details provided below. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We want to make sure all the personal information we hold about you is accurate and up to date. You may ask us to remove or correct information you think is inaccurate.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case we will notify you and keep you updated
How to contact us
By e-mail to email@example.com (Gill Gascoigne- Data Protection Officer for the League.)
You have the right to complain to the Information Commissioners Office (ICO) if you think there is a problem with the way in which AHLOF is handling your information. To contact the ICO, please call 0303 123 1113 or visit their website at https://ico.org.uk