The Hospice of the Good Shepherd (HGS) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you. HGS is responsible for deciding how we hold and use personal information about you. This makes us a “data controller”. HGS will comply will all legislation including the relevant Data Protection legislation, guidelines and the Care Quality Commission (CQC) guidance on patient’s personal information (Regulation 17 Good Governance of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
About Hospice of the Good Shepherd
The hospice provides specialist palliative care services for residents of Chester, Ellesmere Port, Deeside, Neston and Western Cheshire. The services are provided free of charge to people living with life limiting illnesses, and those who are important to them, through an in-patient unit and out-patient services including The Living Well Centre, Medical Outpatients and Family Support Services.
Data Protection Law
We collect your personal information in order to provide you with the most appropriate care and to document care delivery. We may also collect personal data which relates to you from third parties eg. when you are referred to us by another professional involved in your care. We ensure that prior to processing your personal data for any purpose, that the law allows us to do this. We process your personal data in accordance with the Data Protection Act 2018 (DPA), General Data Protection Regulation (GDPR), or for other lawful reasons.
Data Protection law says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Stored securely.
In the limited circumstances where you may have provided your consent to hold and use your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact The Director of Clinical Services. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing.
Privacy of Information
Personal data is information that can identify an individual e.g. name, address, date of birth. Sensitive data is personal information such as the health, racial or ethnic origin, and religious beliefs.
HGS will safeguard patients’ privacy by only collecting the information we need in order to provide the right level of service. HGS will ensure that the information we collect is kept confidential and handled responsibly and in accordance with legal requirements. We will ensure data is kept up to date and reviewed regularly, to ensure data is both accurate and not kept longer than necessary.
All personal and sensitive information is treated as strictly confidential unless we have consent, or the law permits us, to share it in any way.
Keeping your personal information up-to-date
Always tell us when your information changes, such as your, GP, telephone number, next of kin/emergency contact details or if you feel we should add something about you to your records.
How we hold information about you
HGS hold records about you concerning any of our services you have received. A personal record will be set up to keep important information about the care you receive in any of our services. We use this information to make sure that you receive the best possible care. Some of your records are held in paper format and some on computer systems; all are kept securely.
Information we hold about you
- Basic details about you, such as your name, address, date of birth and NHS number.
- Contacts we have had with you.
- Notes and reports about assessments and care provided.
- Next of kin details, and other family and friends contact details.
- Letters to others relating to your care, e.g. GP or social services.
- Information from others involved in your care.
- This list is not exhaustive.
Records may include one or more of the following information:
Sensitive Personal Information
‘Special categories’ of particularly sensitive personal information require higher levels of protection eg. information about your health. We need to have further justification for collecting, storing and using this type of personal information.
We may process special categories of personal information in the following circumstances:
- Where it is needed to assess the care and support services for you.
- Where we need to carry out our legal obligations.
We do not need your consent if we use special categories of your personal information to carry out our legal obligations.
How we will use information about you
HGS use your personal data in various areas of our work, including:
- The provision of care and support services.
- To ensure the health and safety of staff other patients and the general public accessing our building.
- To provide you with information about other services available to you through HGS, and third parties connected with us.
- Monitoring of equal opportunities.
- Seeking views or comments on the services we provide.
- Notifying you of changes to our service.
- For audit purposes.
- To process and respond to requests, enquiries and complaints received from you.
- For statutory and regulatory compliance.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- To meet the contract provision of care and support services.
- Where we need to comply with a legal obligation.
- 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 protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Data Information Sharing
Information is primarily shared to enable us to provide a service to our patients, although there are times when we are legally obliged to share data. Where we share data we always make sure that the organisations understand that the information must be used for the reasons we have specified and must be kept safe and secure. In some cases, where the law allows, we may have to share your data with third parties, such as:
- Local authorities and Social Services
- The NHS via the Clinical Commissioning Group
- The Care Quality Commission
- Health and Social Care professionals
- The Ambulance Service
- Legal advisers
- Fire and Rescue Services
- Government departments
We may share your personal information with third parties where required by law, where it is necessary to co-ordinate services for you or where we have another legitimate interest in doing so.
We require third parties to take appropriate security measures to protect your personal information in line with the law.
Transferring information outside the European Union
We will not transfer the personal information we collect about you outside the EU. There are some exceptions to this eg. if you ask us to provide information about you to a company outside of the United Kingdom or the EU.
Keeping your data secure
HGS value your privacy and confidentiality. All information you provide is stored in accordance with the Data Protection Act 2018.
We undertake to treat any personal information (which means data from which you can be identified, including your name, address, email addresses and the like) that you provide to us or that we obtain from other people, in accordance with this Privacy Notice and the provisions of the Data Protection Act of 2018, or any amendment to it. We may analyse the personal information supplied, on an anonymous basis, to improve the services we offer. We will make every endeavour to ensure the security of your information.
HGS will ensure data is kept securely using:
- Locked filing cabinets kept in secure office accommodation.
- Secure computer systems. Any records held electronically will be protected by appropriate security arrangements that prevent unauthorised access.
To prevent unauthorised access and to maintain data accuracy, HGS uses reasonable physical, electronic and managerial procedures to safeguard and secure the information it collects. HGS recognise the importance of safeguarding personal information in our possession from theft, inappropriate use or improper distribution. It should, however, be recognised that no organisation can absolutely protect personal information at all times.
We have put in place procedures to deal with any suspected or actual data security breach and will notify you where we are legally required to do so.
How long we keep your information for
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we follow the Records Management Code of Practice for Health and Social Care 2016, which is a guide to use in managing records, based on current legal requirements and professional best practice. You can see this at: https://www.gov.uk/government/publications/records-management-code-ofpractice-for-health-and-social-care
From this, the HGS has created a Data Records and Retention Policy.
We may continue to process your personal data after you leave HGS for a short period, e.g. for audit and financial reasons. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Under certain circumstances, by law you have the right:
- To be informed – This enables you to be informed how we process your data, by way of this Privacy Notice.
- Of access – This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- To rectification – This enables you to have any incomplete or inaccurate information we hold about you corrected.
- To erasure – This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- To restrict processing – This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- To data portability – This enables you to transfer your electronic personal information to another party.
- To object – This enables you to object where we are processing your personal information for direct marketing purposes.
- In relation to automated decision making & profiling – This enables you to be told if we process your data using automated software.
Right of Access
The Data Protection Act gives people the right to see the information we hold on them by making a ‘Subject Access Request’. You will need to apply for your records in writing. We will provide copies of your records within one calendar month.
In general, we will provide access to everything we hold about you. Any information relating to another patient or individual will be withheld. Certain exemptions may apply, which means we have to withhold information that may cause you or anyone else harm.
You will not have to pay a fee to access your personal information). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
To make a request, you can apply to: Liz Taylor, Director of Clinical Services.
- By email: email@example.com
- By post: Hospice of the Good Shepherd, Gordon Lane, Backford, CH2 4DG
A form will be sent to you to confirm receipt of your request. Please give as much information as possible to help us respond to your request, including:
- Your full name, address and contact telephone number
- Proof of identity
- Details of the specific information you require and any relevant dates
Your information is kept confidential at all times and is only shared with people who need the information to support you effectively. All HGS staff are bound by strict professional and contractual codes of confidentiality and by UK law.
We will review our Privacy Notices regularly in order to continuously improve our services and performance.
Equality and Diversity
For HGS diversity is about respecting the differences of our individual patients, partners and staff, ensuring that all people that come into contact with us have access to the same high standards of behaviour and service.
We will communicate with patients in the way that suits them wherever possible. We aim to provide information that is easy to understand and to communicate in an appropriate way.
For Further Information
If you have a question about your information you can discuss this with the person providing your care. If you have any other concerns relating to this Privacy Notice, please contact: Liz Taylor, Director of Clinical Services.
- By email: firstname.lastname@example.org
- By post: Hospice of the Good Shepherd, Gordon Lane, Backford, CH2 4DG
If you are not happy with how HGS process your data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
The ICO contact details are:
- Web: https://ico.org.uk/
- Helpline: 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers)
- Live Chat: allows you to have an online conversation with someone at the ICO.
The ICO helpline and live chat services are usually available between 9:00am – 4:30pm, Monday to Friday (excluding public holidays).
Email: To ask the ICO something by email, just fill in the form at: https://ico.org.uk/global/contact-us/email/
Changes to this Privacy Notice
HGS may, in its sole discretion, amend this Privacy Notice at any time without direct notice to you. We suggest that to protect your interests you visit our website and check the Privacy Notice on a periodic basis.