June 2024

During the course of its activities, Royal Trinity Hospice collects, stores and processes personal information. 

We process personal information about our patients and their family members, carers, or friends; about those who volunteer with us in the hospice or in our charity shops; about our donors and supporters; and about prospective, current and former staff. We also collect, store and process some personal information about people in organisations with which we work closely, such as other healthcare professionals. 

We recognise the need to treat personal and sensitive data in a fair and lawful manner. No personal information held by us will be processed unless the requirements for fair and lawful processing can be met. 

Access to personal and sensitive data is controlled, and only available on a ‘need to know’ basis. All staff receive training on the principles of data protection and information security. 

Data Protection laws give individuals rights in respect of the personal information that we hold about you. These are: 

  • To be informed why, where and how we use your information.
  • To ask for access to your information.
  • To ask for your information to be corrected if it is inaccurate or incomplete.
  • To ask for your information to be deleted or removed where there is no need for us to continue processing it.
  • To ask us to restrict the use of your information.
  • To ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information.
  • To object to how your information is used.
  • To challenge any decisions made without human intervention (automated decision making) 

Our records management policy sets out the criteria we use for data retention. We will retain personal data for the minimum period required by legislation or national guidance provided by statutory authorities. When no longer required for day-to-day processing, personal information will be archived, either electronically or if in hard copy, stored in a secure archive held offsite and then destroyed when the retention period has ceased.  

Should you have any queries about the retention periods for personal data or on any aspect of the use of your information, please contact our Data Protection Officer, Jason Coleman by email on [email protected], by phone on 020 7787 1000, or write to him at Royal Trinity Hospice, 30 Clapham Common North Side, London, SW4 0RN 

Should you wish to lodge a complaint about the use of your information, details of our complaints policy can be found on our website here or please email Emily Carter, Chief Executive, on [email protected] or call 020 7787 1000. 

If you are still unhappy with the outcome of your enquiry you can write to The Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or call 01625 545700. 

We publish a version of this policy specifically written for children and young people. It is available to read here.  

This privacy notice sets out in more detail how we process personal information in the following categories: 

  1. Care records
  2. Employment, volunteering and training records
  3. Donor and supporter records 

1. Care Records 

We aim to provide you with the highest quality care. To do this, we must keep records about you and the care we provide for you.  

Royal Trinity Hospice collects, stores and processes personal information about prospective, current and former patients who have been referred to the hospice for any care service provided by the hospice. We also collect, store and process personal information about prospective, current and former family members, carers or friends of patients, where these details have been provided to us for the purposes of providing care. 

1.1 What types of personal data do we handle? 

The personal data we process in relation to our care is provided to us both by the individual and by a third-party healthcare professional who has referred the individual to us for care. 

  • Personal demographics (including gender, race, ethnicity, sexual orientation, religion)
  • Contact details such as names, addresses, telephone numbers and emergency contact(s)
  • Medical information including physical health or mental condition, medications, previous treatments and records of care given by other health and social care organisations. 

Health records are held on paper and electronically and we have a legal duty to keep these confidential, accurate and secure at all times in line with Data Protection Laws. 

1.2 What is the purpose of processing this data? 

The legal basis for the processing of data for these purposes is that Royal Trinity Hospice has a duty to care for its patients and is contracted to provide healthcare by the NHS. Processing this data is necessary for the provision of health and social care and the treatment of patients, and for the management of health or social care systems and services. 

Information collected about you to deliver your healthcare is also used to assist with: 

  • Making sure your care is coordinated and of a high standard.
  • Assessing your condition against a set of risk criteria to ensure you are receiving the best possible care.
  • Using statistical information to plan services to meet the needs of the population.
  • Preparing statistics on our performance for NHS commissioners, the Care Quality Commission and other regulatory bodies.
  • Helping train staff and support research.  
  • Supporting the funding of your care.
  • Reporting and investigation of complaints, claims and untoward incidents.
  • Reporting events to the appropriate authorities when we are required to do so by law. 

If we need to use your personal information for any reason beyond those stated above, we will discuss this with you. You have the right to ask us not to use your information in this way. However, there are exceptions to this. 

  • If the public interest is thought to be of greater importance: for example, if a serious crime has been committed, if there are risks to the public or our staff, to protect vulnerable children or adults.
  • Where we have a legal duty, for example reporting some infectious diseases, wounding by firearms and complying with court orders.
  • If we need to use the information for medical research, we must ask permission from the Confidentiality Advisory Group (appointed by the NHS Health Research Authority). 

Our staff are trained to handle your information correctly and protect your confidentiality and privacy; we do not undertake automated decision-making such as profiling.  

We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never collected for direct marketing purposes, and is not sold on to any other third parties. Your information is not processed overseas. 

1.3 Sharing your information 

Sometimes your care may be provided by members of a care team, which might include people from other organisations such as health, social care, education, or other care organisations. 

We ask for your consent to share your information with other organisations so that we can provide effective care to you. If you do not want us to do this, you have the right to ask us not to, and we will discuss with you the implications this may have for your care. 

We will not routinely disclose any information about you without your express permission. However, there are circumstances where we must or can share information about you owing to a legal/statutory obligation. 

If you have previously agreed to information sharing with your GP, Royal Trinity Hospice staff involved in your care will be able to access your GP records.  

If you want further information about the handling of care records and patient information, please contact the Caldicott Guardian and Medical Director, Dr Sam Lund by phone on 020 7787 1000 or by email at [email protected]. 

1.4 NHS National Data Opt-Out 

The National Data Opt-Out was introduced for the health and social care system in 2018.  

The service allows patients to opt out of their confidential patient information being used for research and planning purposes. Information about your health or care that is anonymised so that you can no longer be identified is not considered to be confidential patient information. 

We review our data processing on an annual basis to assess if the national data opt-out applies. This is recorded in our Record of Processing Activities. All new processing is assessed to see if the national data opt-out applies. If any data processing falls within the scope of the National Data Opt-Out, we use MESH to check if any of our service users have opted out of their data being used for this purpose. 

At this time, we do not share any data for planning or research purposes for which the National Data Opt-Out would apply. We review all of the confidential patient information we process on an annual basis to see if this is used for research and planning purposes. 

Patients can view or change their National Data Opt-Out choice at any time by using the online service at www.nhs.uk/your-nhs-data-matters or by clicking on "Your Health" in the NHS App, and selecting "Choose if data from your health records is shared for research and planning".  

The choice you make does not apply when your information is used as part of your care. 

2. Employment, volunteering and training records 

Royal Trinity Hospice collects, stores and processes personal information about prospective, current and former staff, including applicants, employees (and former employees), workers (including agency, casual and contracted staff), volunteers, trainees and those carrying out work experience. 

2.1  What types of personal data do we handle? 

The personal data we process in relation to employment, volunteering and training is provided to us by individuals at the point of application for a role at Royal Trinity Hospice, or by the agency where we engage agency staff. 

In order to carry out our activities and obligations as an employer we handle data in relation to: 

  • Personal demographics (including gender, age, race, ethnicity, sexual orientation, religion) 
  • Contact details such as names, addresses, telephone numbers and emergency contact(s)
  • Employment records (including professional membership, references and proof of eligibility to work in the UK and security checks)
  • Bank details
  • Pension details
  • Medical information including physical health or mental condition (occupational health information)
  • Information relating to health and safety
  • Trade union membership
  • Offences (including alleged offences), criminal proceedings, outcomes and sentences
  • Employment Tribunal applications, complaints, accidents, and incident details 

Our staff are trained to handle your information correctly and protect your confidentiality and privacy; we do not undertake automated decision-making such as profiling.  

We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never collected or sold for direct marketing purposes and it is not processed overseas. 

2.2 What is the purpose of processing this data? 

We have a legal basis to process this as part of your contract of employment or agreement (either permanent or temporary) or as part of our recruitment processes following data protection and employment legislation.  

We process your data for the following reasons: 

  • Staff administration and management (including payroll and performance) 
  • Pensions administration
  • Business management and planning
  • Accounting and Auditing
  • Accounts and records
  • Crime prevention and prosecution of offenders
  • Provision of education and training
  • Health administration and services 

The provision of personal data is therefore part of a contractual requirement, including the fulfilment of an agreement to volunteer or be a trainee at Royal Trinity Hospice. Failing to provide the personal data required would consequently mean we would be unable to complete our recruitment processes and we could not engage you in a contract of employment. 

2.3 Sharing your information 

Any disclosures of personal data are always made on a case-by-case basis, using the minimum personal data necessary for the specific purpose and circumstances and with the appropriate security controls in place. Information is only shared with those agencies and bodies who have a "need to know" or where you have consented to the disclosure of your personal data to such persons. 

There are a number of reasons why we share information. This can be due to: 

  • Our obligations to comply with legislation
  • Our duty to comply any Court Orders which may be imposed 

We may use the information we hold about you to detect and prevent crime or fraud. We may also share this information with other bodies that inspect and manage public funds. 

We will not routinely disclose any information about you without your express permission. However, there are circumstances where we must or can share information about you owing to a legal/statutory obligation. 

To enable effective staff administration, we share your information with some specific external organisations to comply with our obligations as an employer. 

Our Human Resources team can provide further details. They can be contacted by email at [email protected] or by phone at 020 7787 1000. 

3. Donor records 

Royal Trinity Hospice collects, stores and processes personal information about prospective, current and former donors and supporters of the charity. 

3.1 What personal data do we hold? 

The personal data we hold about donors is provided by individuals when they choose to support Royal Trinity Hospice through fundraising donations or via the donation of Gift Aid on the sale of donated goods in one of our charity shops. 

In order to carry out our activities in relation to donors and supporters, we handle data in relation to: 

  • Contact details such as names, addresses, telephone numbers and emails.
  • Bank account and credit card details
  • Estate information 

Our staff are trained to handle your information correctly and protect your confidentiality and privacy; we do not undertake automated decision-making such as profiling.  

We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is only collected for our own marketing purposes and is never collected for or sold to other organisations. Our Donor Charter sets out in more detail the standards we adhere to in fundraising. 

We always try to work with organisations which operate within the European Economic Area (EEA). Where we work with a supplier operating outside the EEA, we ensure they provide an appropriate level of protection. This is called an “adequacy decision”, and is guaranteed by schemes such as the Privacy Shield Framework. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA. If you want more information about the non-EEA suppliers we use, please contact our Fundraising team, at [email protected] or via our switchboard 020 7787 1000. 

3.2 What is the purpose of processing this data? 

We have a legal basis to process this on the basis of your explicit consent to provide us with this information. You may withdraw your consent for us to process this data at any time.  

We process your data for the following reasons: 

  • Fundraising activities, soliciting donations and support in kind
  • Marketing and communication about the activities of Royal Trinity Hospice, including events
  • Securing your consent to the donation of Gift Aid to Royal Trinity Hospice on the sale of donated goods. 

Should you wish to withdraw your consent to our processing your data, please contact our Fundraising team at [email protected] or fill in our preferences form at www.royaltrinityhospice.london/forms/preferences. If you wish to withdraw your consent to our processing your data in respect of Gift Aid donations in our shops, please contact our Retail team at [email protected]. Both departments can also be contacted via our main switchboard 020 7787 1000. 

3.3 Sharing your information 

Any disclosures of personal data are always made on a case-by-case basis, using the minimum personal data necessary for the specific purpose and circumstances and with the appropriate security controls in place. In order to process your information and donations to the highest possible standards, we will sometimes need to give other organisations access to your data. Examples include database storage, printers and email software providers. 

There are a number of reasons why we share information. This can be due to: 

  • Our obligations to comply with legislation
  • Our duty to comply with any Court Orders which may be imposed 

We may use the information we hold about you to detect and prevent crime or fraud. We may also share this information with other bodies that inspect and manage public funds. 

We will not routinely disclose any information about you without your express permission. However, there are circumstances where we must or can share information about you owing to a legal/statutory obligation (such as HMRC for Gift Aid records).  

For more details, please contact our Fundraising team at [email protected] or for details of information-sharing in respect of Gift Aid donations in our shops, please contact our Retail team at [email protected]. Both departments can all also be contacted via our main switchboard 020 7787 1000.