About Us

Privacy Policy

Aim of the Policy

Accord Hospice needs to collect and keep certain information on its employees, volunteers, representatives, service users and donors in order to operate, to meet its objectives and to comply with legal obligations.

The organisation is committed to ensuring any personal data will be dealt with in line with the Data Protection Act 1998. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

This policy applies to all employed staff, volunteers and representatives, i.e. those working on behalf of Accord Hospice.

Personal information is information relating to an identifiable living individual.

Information relating to identifiable deceased individuals must be handled with care, particularly if the information is confidential. Access to health records is covered by the Access to Health Records Act 1990.

The Data Protection Act 1998 applies to person-identifiable information that relates to living individuals contained in records such as; HR/personnel, payroll, medical, etc. It covers both manual (paper-based, microfiche/film, photographs) and electronic forms (computer files, databases, digital images/media, etc.) of information.

In line with the Data Protection Act 1998 principles, Accord Hospice will ensure that personal data will:

1. Be obtained fairly and lawfully and shall not be processed unless certain conditions are met

2. Be obtained for a specific and lawful purpose

3. Be adequate, relevant but not excessive

4. Be accurate and kept up to date

5. Not be held longer than necessary

6. Be processed in accordance with the rights of data subjects

7. Be subject to appropriate security measures

8. Not to be transferred outside the European Economic Area (EEA)

The definition of ‘Processing’ is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computer.

The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. Accord Hospice will seek to abide by this code in relation to all the personal data it processes, i.e.

Accountability: those handling personal data follow publicised data principles to help gain public trust and safeguard personal data.

Visibility: Data subjects should have access to the information about themselves that an organisation holds. This includes the right to have incorrect personal data corrected and to know who has had access to this data.

Consent: The collection and use of personal data must be fair and lawful and in accordance with the DPA’s eight data protection principles.

should only be used for the purposes agreed by the data subject. If personal data is to be shared with a third party or used for another purpose, the data subject’s consent should be explicitly obtained.

Access: Everyone should have the right to know the roles and groups of people within an organisation who have access to their personal data and who has used this data.

Stewardship: Those collecting personal data have a duty of care to protect this data throughout the data life span.

Notification

The needs we have for processing personal data are recorded on the public register maintained by the Information Commissioner. We notify and renew our notification on an annual basis as the law requires.

If there are any interim changes, these will be notified to the Information Commissioner within 28 days.

The Data Controller/Caldicott Guardian within our organisation as specified in our notification to the Information Commissioner is the Chief Executive Officer, Helen Simpson.

Responsibilities

Under the Data Protection Guardianship Code, overall responsibility for personal data in a not for profit organisation rests with the governing body. In the case of Accord Hospice this is the Board of Directors.

The Data Controller is responsible for:

 understanding and communicating obligations under the Data Protection Act

 identifying potential problem areas or risks

 producing clear and effective procedures

 notifying and annually renewing notification to the Information Commissioner, plus notifying of any relevant interim changes

All employed staff, representatives and volunteers, who process personal information, must ensure that they not only understand but also act in line with this policy and the data protection principles.

Breach of this policy will result in staff, representatives and volunteers being disciplined and, where relevant, possible dismissal from the Hospice.

Implementation

To meet our responsibilities staff, representatives and volunteers will:

 Ensure any personal data is collected in a fair and lawful way;

 Explain why it is needed at the start;

 Ensure that only the minimum amount of information needed is collected and used;

Ensure the information used is up to date and accurate;

 Review the length of time information is held;

 Ensure it is kept safely;

 Ensure the rights people have in relation to their personal data can be exercised

We will ensure that:

 Everyone managing and handling personal information is trained to do so.

 Anyone wanting to make enquiries about handling personal information, whether a member of staff, volunteer or service user, knows what to do;

 Any disclosure of personal data will be in line with our procedures.

 Queries about handling personal information will be dealt with swiftly and politely.

Training

Training and raising awareness about the Data Protection Act and how it is followed within this organisation will take the following forms:

 Induction

 Mandatory Training – annually

 Communications – emails, meetings, etc.

 Access to Policies and Procedures – via the library (paper-based) and on the shared data drive on the server (electronic)

Data Security

The organisation will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:

 Processes and procedures – appropriate, reviewed and updated

 Secure storage – lockable stores, password protected systems

 Access restricted to only those with the correct authority

 Training provided to all staff and volunteers

Any unauthorised disclosure of personal data to a third party by an employee, volunteer or representative may result in disciplinary action.

Access Requests

Anyone whose personal information we process has the right to know:

 What information we hold and process on them

 How to gain access to this information

 How to keep it up to date

 What we are doing to comply with the Act.

They also have the right to prevent the processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.

Individuals have a right under the Act to access certain personal data being kept about them on computer and certain files. Any person wishing to exercise this right should apply in writing to the Data Controller at Accord Hospice.

The reason and information access required, as well as proof of identity, may be required before access is granted.

Queries about handling personal information will be dealt with swiftly and politely.

We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 40 days required by the Act from receiving the written request.

Review

This policy will be reviewed at intervals of 3 years to ensure it remains up to date and compliant with the law.