Privacy policy

North London Hospice has completed a Data Security and Protection Toolkit self-assessment in June 2023 which demonstrates we are practising good data security and that personal information is handled correctly. 

During the course of its activities, North London Hospice (‘we’ or ‘us’) collects, stores, and processes personal data. We are committed to protecting and respecting your privacy. This Notice, together with any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

We aim to be an exemplar in all areas of data management and abide by the Fundraising Regulator’s guidance, Information Commissioner’s Office’s guidance, any relevant Codes of Practice, and the Charity Commission, Chartered Institute of Fundraising and Hospice UK’s guidance and best practice.

The North London Hospice address is 47 Woodside Avenue, London, N12 8TF. North London Hospice’s website is, www.northlondonhospice.org, and it is owned and operated by North London Hospice.

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

All staff receive training on the principles of confidentiality, data minimisation, purpose limitation, data protection and information security.

Personal Data

Personal data is defined in the UK General Data Protection Regulation (UK GDPR)  ‘any information relating to an identified or identifiable natural person (‘data subject’), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.

The Data Controller

North London Hospice is the data controller.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the data protection legislation. We have outsourced this service to Moore ClearComm. (dataprotection@mooreclear.com)

Lawful Processing

The lawful bases for processing are set out in Article 6 of the UK GDPR. We rely on one of the following  when we process personal data:      

• Consent: you have given North London Hospice freely, specific, informed, or unambiguous consent for your personal data to be processed for a specific purpose.
• Contract: the processing is necessary for the performance of a contract you have with the North London Hospice.
• Legal obligation: the processing is necessary for North London Hospice to comply with the law.
• Vital interests: the processing is necessary to save someone’s life.
• Legitimate interests: the processing is necessary for North London Hospice’s legitimate interests, or the legitimate interests of a third-party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

DATA SUBJECT RIGHTS

You have the following rights:

• The right of access.
• The right to rectification.
• The right to erasure or right to be forgotten.
• The right to restriction of processing.
• The right to be informed.
• The right to data portability.
• The right to object.
• The right not to be subject to a decision based solely on automated processing.

Please get in touch with us if you want to exercise any of these rights on nhl@northlondonhospice.co.uk

Data Retention

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. We take into account various criteria when determining the appropriate retention period including

• The purposes for which we process your personal data and how long we need to keep the data to achieve these purposes.
• How long the personal data might be relevant to possible future legal claims.
• Any applicable legal, accounting, reporting or regulatory requirements which specify how long certain records must be kept.

Care records 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  data protection lead on nlh@northlondonhospice.co.uk.

How we use your personal data

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

• Care records including family members, carers, and friends of patients.
• Donor and supporter records.
• Retail Gift Aid Records.

Care Records

What types of personal data do we handle?

The personal data we process in relation to the care we provide is given to us both by the individual and/or 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); and
• Medical information including physical health or mental condition, medications, previous treatments, records of care and other personal information given by the individual or 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 the UK GDPR.

What is the purpose of processing this data?

North London Hospice has a duty to care for its patients and is contracted to provide healthcare by the National Health Service (‘NHS’). Processing this data is necessary for the provision of health and social care, the treatment of patients, and for the management of health or social care systems and services.

Information collected about you to deliver your health care 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 data for any reason beyond those stated above, we will discuss this with you.

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

Sharing your information

In the main, we will only share your personal data without consent where we have a legal duty to ensure your personal health and well-being.

The need to share information between members of different care teams and between different organisations involved in your healthcare provision will be explained, if considered appropriate. This is particularly important where disclosure extend to both NHS and non-NHS bodies, such as District Nurses or Social Services.

We work with partners and have access to the London Care Record (formerly Health Information Exchange HIE) which holds a record of care which can be accessed (read only) by a health or social care professional for the purpose or providing your care.

North London Hospice can see relevant parts of your clinical records and it is role-based access only. This means that a doctor sees different information to a health care assistant or a social worker and each professional only sees information relevant to your direct care.

Some sensitive information will not be included in your record such as fertility treatment records, attendance at sexual health clinics and any previous records for individuals who have obtained a gender recognition certificate.

There is a data sharing agreement in place to support the sharing of personal data on this system.

In all other cases we will not routinely disclose any information about you without your express permission. However, there are circumstances where we may need to share personal data without your permission such as:

• 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 have to ask permission from the Confidentiality Advisory Group (appointed by the NHS Health Research Authority) to do this.

If you want further information about the handling of care records and patient information, please contact the Caldicott Guardian and Medical Director at North London Hospice by phone on 020 8343 8841.

Donor and Supporter Records

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

What personal data do we collect?

The personal data we hold in relation to donors is provided by individuals at the point at which they choose to support North London 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 personal data in relation to:

• Contact details such as names, addresses, telephone numbers and emails, social media identity, including updates from third party sources where you have given permission.
• Date of birth.
• Gender.
• Bank account and credit card details where you provide these to make a payment or donation.
• Information as to whether you are a taxpayer to enable us to claim Gift AidEstate information where you have left us a legacy and any information relating to a next of kin you may have provided us to administer this.
• Communication preferences.
• Next of Kin information.
• Relationships, family connections.
• Communication history.
• Past donations.
• Skills such as running for those that like to fundraise for us by running marathons for example.
• We also collect information from third parties where you have given permission such as when setting up fundraising pages or sponsoring a fundraising page.
• When a friend or family member signs you up to one of our events.
• Any other personal information you provide to us.

Our staff are trained to handle your information correctly and protect your confidentiality and privacy.

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.

We always try to work with organisations that operate within the European Economic Area (EEA). Where we work with a supplier operating outside the EEA, we will ensure they provide an appropriate level of protection. By submitting your personal data  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 Department at fundraising@northlondonhospice.co.uk or via our switchboard 0800 368 7848.

What is the purpose of processing this data?

We process your data for the following reasons:

• To administer your donations or support your fundraising.
• Processing Gift Aid.
• To keep a record of your relationship with us.
• To respond or fulfil any requests, enquiries, complaints or queries you make.
• Manage our events.
• Checking for updated contact details against third party sources so we can stay in touch if you move address (see “Keeping your information up to date” below).
• To further our charitable objectives.
• To communicate with you and to send you direct marketing and appeals for donations and attendance at events.
• Identify potential supporters and donors.
• Audit and administer our accounts.
• To meet legal obligations to regulators, government and/or law enforcement bodies.
• Carry out fraud prevention and money laundering checks.
• Establish, defend, or enforce legal claims.
• To thank and acknowledge donations.
• Tailoring and targeting our fundraising communications and events to you.
• To report and analyse the data to gain insights into our fundraising activities.
• To research and estimate potential giving capacity based on their relationship with the hospice and giving history.
• Updating records that we know are next of kin to a patient or recently deceased patient to ensure that communications are appropriate at sensitive times. See more in the section called ‘Next of Kin.

We rely on either your consent or ‘legitimate interests’ for the processing of your personal data for these purposes. You may opt out of processing your personal data at any time by contacting us on email fundraising@northlondonhospice.co.uk or by calling 0800 368 7848.

Keeping your information up to date

We may need to check the post office national change of address and or the public electoral roll in order to keep our records up to date and to stay in touch. We also ask that you notify us if you are changing address so that our records are accurate and up to date

Profiling

As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies to gather information from publicly available sources, for example, Companies House, the Electoral Register, annual reviews, corporate websites, social networks such as LinkedIn, property registers and news archives.

We may use trusted third party partners to fast track this research. This is to better understand supporters and potential supporters, who have links to North London Hospice.

We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations.

All our research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor that is appropriate for you, by tailoring and targeting our fundraising communications to those most likely to be interested in them.

This allows us to be more efficient and cost effective with our resources and also reduces the risk of someone receiving information that they might find irrelevant, intrusive, or even distressing.

If you would prefer us not to use your data in this way, please email us at fundraising@northlondonhospice.co.uk or call 0208 446 2288.

Next of Kin Data

Personal data of the next of kin of a service user or patient who has died will be provided to our fundraising team to ensure the next of kin does not receive inappropriate communications at a sensitive time. It is important that if our supporters are also a next of kin, we recognise this connection and we communicate with them in an appropriate way, or if they contact us directly, we can immediately identify their relationship with the Hospice.

If the next of kin is already on our supporter database, we will update the record accordingly.

Our fundraising team might contact the next of kin to:

• Let them know how to arrange funeral or memorial collections or set up online tribute funds.
• Process donations & thank them for donations collected in memory of a loved one.
• Let them know about other ways to remember their loved ones, such as our Tribute Tree, Light up a Life & Sow a Special Sunflower.
• Fulfil a legitimate interest such as sending our latest newsletter and information about our charitable objects and fundraising activities.
• Inform them about fundraising efforts we undertake to raise money for our charity.

Sharing your information

Any disclosures of personal data are always made on 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.

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

• Our obligations to comply with legislation; and
• Our duty to comply with any Court Orders that 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 may also disclose your information to third parties in connection with the purposes set out in this policy. These third parties may include Business partners, suppliers, mailing houses, sub-contractors who may process information on our behalf.
• If you are a legacy giver, we may share information with co-beneficiaries.

There are also circumstances where we are required to share information about you to comply with legal/statutory obligation (such as HMRC for Gift Aid records).

Processors

We may contract with data processors to provide services. Any personal data shared with a data processor for this purpose will be governed by appropriate safeguards and contracts under data protection law.

Location of processing

The personal data that we collect from you will be processed within the UK. It may be necessary, in some cases, to transfer personal data to the EEA and any such transfers will be fully compliant with the requirements of the legislation. If personal data is to be transferred outside the UK or EEA to a country which is not designated as ‘adequate’ then, if we are not relying on consent, we will ensure that appropriate safeguards are in place such as the International Data Transfer Agreement to ensure that we comply with the UK GDPR. We will take all reasonable steps to ensure that your personal data is treated securely, in accordance with this privacy notice. 

Complaints

We hope you don’t need to, but should you wish to lodge a complaint about the use of your personal data, please contact North London Hospice in the first instance on 0800 368 7848 email: complaints@northlondonhospice.co.uk or write to North London Hospice, 47 Woodside Avenue, London, N12 8TF.

North London Hospice also had a Data Protection Officer, who can be contacted at dataprotection@mooreclear.com or North London Hospice, 47 Woodside Avenue, London, N12 8TF.

If you are unhappy with the outcome of your enquiry you can write to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or call 0303 123 1113.

Changes to North London Hospice Privacy Notice

This privacy notice was last updated 15 February 2024.

For more details about the work we do, please contact our Fundraising Department at fundraising@northlondonhospice.co.uk or for details of information sharing in respect of Gift Aid of sales proceeds of goods given to our shops, please contact our Finance Department at accounts@northlondonhospice.co.uk. Both departments can be contacted via our main switchboard 0800 368 7848.