Hospice Isle of Man is committed to protecting the privacy of everyone who uses our services: as business partners, patients, carers, employees and volunteers; and anyone who supports hospice through fundraising, retail or lottery activities. This notice explains what personal data we collect and process, how we collect it, whom we share it with, and why we do so. It also explains how we keep the data secure. If, after reading this Notice, you have any questions about it, or data processing in general, then please contact our Data Protection Officer whose details are provided at the bottom of this Notice.
We will treat your data with respect and in accordance with the requirements of the Isle of Man Data Protection Act 2018 (Also commonly referred to as the “Applied GDPR”).
By “Personal Data” we mean any information that might allow you to be identified, such as your name, address, date of birth, credit card details, I.P. address, photo or video image or voice recording. For patients, some of this data will be sensitive and relate to their health and wellbeing, ethnicity and religious views.
We are Hospice IOM. To enable us to run the charity efficiently, Hospice IOM uses a number of separate entities (with names that you may be more familiar with):
Hospice Care – Responsible for the effective running of Hospice IOM.
Hospice Isle of Man - The only provider of specialist palliative care on the Isle of Man.
Hospice at Home - Allowing adult patients to be nursed in the community.
Rebecca House - Our purpose-built children’s wing in the Hospice
Share the Care Ltd. - Responsible for the effective running of Hospice Shops IOM
Hospice Shops IOM - Our retail outlets including 7 shops and 1 warehouse
Hospice Properties Ltd. – Administration of properties bequeathed to the charity
This Privacy Notice applies to all the entities listed above.
Marketing, events, fundraising, visiting our shops and playing our lottery
The Personal Data we collect might include name, address, email address, telephone numbers, date of birth, I.P. address, credit card details and bank account details (for setting up regular direct debit or payment information).
If you volunteer with us we will need to collect Personal Data such as your name, age, address and gender.
If you use our clinical services we will need to collect Personal Data such as your name, age, address, gender, and possibly sensitive personal information concerning your health and wellbeing, ethnic origin and religious views. In order to provide complete care we also collect some data about family members and carers. We will make it clear what Personal Data we need when the situation arises.
If you apply for or take a job with us, we will store your contact data, bank details, and keep records of your employment history.
You may appear in still images or video footage using Closed Circuit Television (CCTV) that is used on some Hospice IOM sites for the safety and security of individuals and property.
If you use our website (we store data about your internet browser, I.P. address, the timings of your visits, and a record of which pages you looked at. Please refer to the “Cookies” section for more detail).
We may use your Personal Data for:
Where there is no legal obligation or legitimate business reason for us to collect, process, or store your Personal Data we will request your consent. We will give a clear explanation of the purpose(s) for which your Personal Data is being collected, processed, and retained. Where consent is necessary, we will ask for it to be given by a positive “opt-in” choice. Sufficient information will be provided for an informed choice to be made. The Personal Data will not be used for any other purpose without additional consent being obtained. We will also make clear how consent can be withdrawn.
We have in place physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect.
All of our business partners have provided statements on how they keep your personal data safe and secure in compliance with the relevant data protection legislation.
All our employees, volunteers, and business partners, who have access to, and who are associated with the processing of Personal Data, are legally obliged to respect its confidentiality.
Your Personal Data is not shared with other organisations unless we have your consent to share it; or where we have a legal obligation, or legitimate business reason, to do so. Your Personal Data is not sold to any organisation. There is data sharing of clinical data with other health care staff such as GPs and district nurses who are also involved in patient care.
Your Personal Data may legitimately have been provided to us by a third party (e.g. a person with parental authority, or another healthcare professional with whom we are obliged to share data). Although you may not have provided the Data it remains your Personal Data and you maintain the same rights over it. Please see the “Your rights” section.
We will only retain Personal Data for as long as we have a legal, or legitimate business reason, for doing so. We will not retain Personal Data if you have unsubscribed from one of our mailing lists or if you have exercised your right to have it erased.
A cookie is a small text file created by the web server and saved on your PC’s hard drive. The next time you visit the web site the web server will check to see if you have this cookie. If you do, the web server will be able to read its contents. If you do not want to receive cookies or if you would prefer to be prompted first you should check the settings in the ‘Internet Options’ of your web browser. If you are not sure on how to check or alter these setting you should contact your software provider or support engineer.
Some information is held and processed by our Internet Service Provider and Mailchimp, but it is only held and processed for and on our behalf and under our instruction.
Aggregate information is used to show us the total number of visits to our web site and which parts of the site are used the most. Aggregate information does not identify individuals, as it does not contain any personal data. This information helps us in developing our web site and improving the service we offer you.
Although, in respect of the services Hospice IOM provides you may be classed as a child, you have the same rights as adults over your Personal Data. However, where your consent is required, we will seek it from someone who has “parental consent” to ensure you do not mistakenly agree to us processing your Personal Data.
This Notice may be amended in the light of any changes in legislation, or as the result of guidance from the Isle of Man Information Commissioner.
The Applied GDPR gives increased provision for individuals to exercise their rights, namely:
It should be noted that these rights are not “absolute” and, whilst we make all reasonable efforts to comply with requests we receive, there may be reasons why the exercising of your right(s) cannot be complied with. If this is the case we will tell you.
If you wish to exercise your rights please contact us (See “How to contact us”) – or, alternatively, you can complete our Subject Access Request Form.
Please contact us if you have any questions or concerns about our Privacy Notice or the way we treat your Personal Data. You can contact us:
• By email: gdpr@hospice.org.im
• Or write to us at: Data Protection Officer, Hospice Isle of Man, Strang, Douglas, Isle of Man, IM4 4RP
We would hope that any queries or concerns that you may have regarding our use of your Personal Data can be easily resolved; however, we do recognise that sometimes things can go wrong – or you may feel that we have not acted as you think we should have. If this is the case, or you do not want to raise the matter with us first, you have the right to make a complaint to a supervisory authority. In the Isle of Man the supervisory authority is the Information Commissioner’s Office. Their contact details are as follows:
Isle of Man Information Commissioner
First Floor, Prospect House
Prospect Hill
Douglas
Isle of Man
IM1 1ET
Telephone: +44 (0)1624 693260
You can also access their website: www.inforights.im