Care Privacy Policy

Privacy Policy – Care Service Users

At Hope House Children's Hospices, we are committed to protecting and respecting your privacy, so this policy explains when and why we collect personal information, how we use it, when and why we might share it and how we keep it secure. It also details your rights in relation to your personal information. We will regularly review this policy and post any updates to our website. Please check periodically in order to keep up to date with any changes.

Who are we?

Hope House Children's Hospices has two children's hospices; Hope House in Oswestry and Tŷ Gobaith in Conwy, is a registered charity in England and Wales (charity number 1003859), and a registered company in England and Wales (company number 2588103). We have two subsidiary companies - Hope House (Trading) Ltd. and Hope House (Lottery) Ltd. This policy will refer to 'Hope House' as a shorthand for the three combined companies.

Getting in touch

Should you have any questions about this policy or your rights regarding your personal information, or if you would like to update your contact preferences, please use the following contact details:-

Hope House
Nant Lane, Morda
Oswestry, SY10 9BX
01691 671 999
care@hopehouse.org.uk

Tŷ Gobaith
Tremorfa Lane, Groesynydd
Conwy, LL32 8SS
01492 651 900
care@tygobaith.org.uk

How do we collect personal information?

We may collect your information in writing, via email, over the phone, or in person. Examples include when you or your child stays at Hope House or Tŷ Gobaith, when we call you for medicines reconciliation or when you or your child register to participate in an organised activity or event, such as an away day for brothers and sisters. Information might be provided in digital form, verbally or in writing, and be received directly from you or from a third party where appropriate, such as your GP or a hospital consultant.

What personal information do we process?

Personal information is anything which enables us to identify you in some way, such as your name, address, email address, date of birth, phone numbers and emergency contact details. Where we are providing nursing and medical care or other care services we will also require 'special category' or sensitive personal information such as medical and health information including details of diagnosis, medical history, medication, dietary needs and specific care preferences. We also collect information about bereavement from any family member referred to the Bereavement Support and Counselling Service. If you require assistance in obtaining financial or social support we may require details regarding your personal and household finances.

Why do we collect personal information?

In order to provide care and support to you, your child and other members of the family, we need you to share some personal information with us. We only collect the minimum amount of information required and it may be used in a number of ways, including:-

  • Replying to an enquiry you have made to Hope House via phone, text, email or post;
  • Providing safe and appropriate care and support to you and your family;
  • Assisting you in securing support from agencies, authorities and other charities;
  • Sharing with other health and social care providers to ensure continuity of care;
  • Sending you information about the charity and our activities;
  • Meeting any legal or regulatory requirements that we are obliged to fulfil.

Hope House will only process your personal data where we have a legal basis for doing so as detailed in the current data protection and privacy legislation, namely:-

  • Where we have your explicit consent (see below)
  • In order to comply with a legal obligation
  • When performing official functions or tasks in the public interest
  • If it is in your or somebody else's vital interests
  • To fulfil contractual requirements
  • When to do so is in our legitimate interests (see below)

Consent

Consent means offering you a real opportunity to state whether or not you wish to allow the processing of your personal information. When processing your information on the basis of consent, we will ensure you are fully aware of what you are consenting to and only use your information for that purpose. You can withdraw your consent at any time using the contact details above. We have determined that processing your information on the basis of consent is lawful and legitimate when:-

  • Accessing your or your child's medical information to ensure continuity of care;
  • Taking and using photographs of you or your child to promote the work of the charity.

Legitimate Interests

Hope House may undertake data processing in pursuit of our legitimate interests, where to do so will not infringe your rights or interests as the data subject. To ensure this is correctly assessed, we undertake a balancing exercise to ensure that our processing will not adversely impact you. In the case of the following data processing activities, we have determined that the processing of your information for these purposes is lawful and legitimate:-

  • Processing referral & new user forms to ensure adequate information regarding care needs;
  • Updating information on you and your family as part of respite stay admissions;
  • The management of service user details on internal databases;
  • The maintenance of paper and/or digital care plans and records of care;
  • Sharing information with other medical professionals to ensure appropriate care;
  • Taking photographs to support care provision or as a record of your child's activities.

You have the right to object to the processing of your personal information on the grounds of legitimate interests as detailed below in 'Right to object'.

Photographs

Photographs may be taken of you or your family members during your interaction with Hope House for a number of reasons. These are shown in the below table, along with the lawful basis on which we will take and use these photographs and your rights regarding this usage:-

Types of PhotographsLawful BasisYour Rights

Photographs taken in a care setting to increase staff understanding and knowledge of a child's care needs

Legitimate interests

Objecting to the use of photographs for this purpose could limit our ability to provide appropriate care and so potentially lead to a withdrawal of service.

Photographs taken of service users enjoying activities at the hospice or on days out to share with parents and other family members

Legitimate interests

Photographs of this type are only taken for the enjoyment and information of service users and their families so could be stopped if required.

Photographs taken of service users to promote the work of the hospice in local media or through online channels

Consent

Photographs will only be used for this purpose with your explicit consent, which you can withdraw at any time.

Photographs used in situations where our actions are determined by a legal requirement or the safety of an individual

Vital interests and/or legal requirement

Objections would not prevent us from using photographs in these circumstances.

Who do we share personal information with?

Hope House will not share your information with third parties for marketing purposes and will not sell or rent your information to third parties. Some of the systems operated by Hope House are provided and/or supported by third party providers, for example, database management at remote sites accessed via the internet. Where services are provided by a third party data processor, your personal information may be shared with them under an agreed contract, which will fulfil the requirements of current data protection regulations and state how information is to be transferred, secured and destroyed, and the purpose(s) for which it can be used.

We may also share your personal information (including special category data such as health information) with third parties involved in your or your child's care where appropriate and where there is a lawful basis for doing so. These third parties may include GP's, consultants and other health and psycho-social care staff such as physiotherapists, nurses, social workers and counsellors. Occasionally we share personal details with health commissioners for the purpose of service planning and funding and with regulators and researchers.

We will disclose personal information if required to do so by law or if we have concerns regarding the safety of any individual.

Hope House may share your personal information with third parties outside of the European Economic Area if any of the exemptions detailed in the General Data Protection Regulation are met. In the case of data processors in the USA, only those certified under the U.S. Privacy Shield framework regarding processing of personal data will be utilised.

How do we protect personal information?

We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is necessary.

How long do we keep personal information?

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary or required for the original purpose.

What are your rights regarding your personal information?

Data protection regulations give individuals rights and (in some cases) control in regards to how their information should be managed. Requests in regards to these rights should be made using the contact details above and we will respond within one month unless there is a compelling reason to extend this response time. In certain circumstances, we may refuse a request we consider to be unfounded or excessively repetitive.

  • Right to be informed. You have the right to be informed about the collection and use of your personal data by Hope House Children's Hospices. We do this through this privacy policy which is updated periodically and always accessible via the Hope House website.
  • Right of access. You may obtain a copy of the personal information we hold about you by submitting your request using the contact details above. We may refuse a request in certain circumstances, in which case our justification will be communicated to you.
  • Right to rectification. You have the right to have any inaccurate personal information that we may hold for you rectified and to request that any incomplete information be completed.
  • Right to erasure. You can request that the information we hold about you be deleted if we no longer need it for the purpose for which we collected it, if our processing is based on consent and you withdraw that consent, if our processing is based on legitimate interests and you successfully object, if your information has been processed unlawfully, or if we have a legal obligation to do so. We may refuse a request for erasure if any of the specific provisions of the current data protection legislation apply.
  • Right to restrict processing. You can make a request for information we hold about you to be suppressed if you have objected to our processing or contested the accuracy of the information we hold and we are investigating, if your information has been unlawfully processed but you want to restrict rather than erase it, or you want us to keep your information after we need it in support of a legal dispute.
  • Right to data portability. You have the right to receive the information you have provided to us in a structured, commonly used and machine readable format and to have transferred directly to another controller. This only applies to information stored electronically, provided directly by you and which we process based on your consent.
  • Right to object. You have the right to object to the processing of your personal data in certain circumstances. We may continue if there is a compelling reason for doing so.
  • Rights related to automated decisions and profiling. Hope House does not conduct any automated decision making or automated processing/profiling.

Unauthorised sharing of information

Whilst we take reasonable measures to ensure your and your family's privacy, we may not always be able to prevent other individuals (e.g. other service users) sharing your name or photograph on their social media channels. Our 'Service Users ICT Policy' gives guidance on this issue, and when unauthorised sharing is brought to our attention we will ask that the information be removed. However, this remains outside of our control.

What should you do if you have a complaint?

If you have a complaint concerning Hope House's processing of your personal data, you can contact us using the information above. Data Protection legislation also gives you the right to lodge a complaint with a supervisory authority and more information can be found on the Information Commissioner's Office website at www.ico.org.uk.

June 2018