Herts Patient Engagement Platform Privacy Notice
Introduction
We are committed to protecting your privacy and will only process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
In general, you can visit our web site without telling us who you are and without revealing any information about yourself. However there may be occasions when you choose to give us personal information, for example, when you choose to contact us or request information from us. We will ask you when we need information that personally identifies you or allows us to contact you.
We collect the personal data that you may volunteer while using our services. We do not collect information about our visitors from other sources, such as public records or bodies, or private organisations. We do not collect or use personal data for any purpose other than that indicated below:
This privacy notice tells you what to expect us to do with your personal information.
We store personal data securely and take appropriate steps to protect it.
Other Information
No financial information is required at any time for any reason. If you are asked to supply such information do not respond, it is not a request from the PEP.
Data Controller and contact details
The Herts Patient Engagement Platform is the Data Controller under the terms of the Data Protection Act. We are therefore legally responsible for ensuring that all personal information that we process i.e. hold, obtain, record, use or share about you, is done in compliance with GDPR.
Email: editor@thepatientengagementplatform.org.uk
What information we collect, use, and why
We collect or use the following personal information for membership purposes
· Contact details (eg name, address, telephone number or personal email address)
· Healthcare areas you are interested in volunteering for. Healthcare areas you are interested in hearing about. Names of other patient voice organisations you are members of.
We collect or use the following personal information for information updates, marketing or market research purposes:
· Names and contact details
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful basis for collecting or using personal information for membership purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful basis for collecting or using personal information for information updates, marketing or market research purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Where we get personal information from
· Directly from you
How long we keep information
We will retain personal data only for as long as necessary for the purposes for which it was collected, including the administration and operation of the Herts Patient Engagement Platform.
In most cases:
· personal data will be retained while an individual remains a member or participant;
· data will be deleted when an individual asks to leave the group or requests removal of their data;
· inactive contact details may be reviewed and deleted after a reasonable period of non-engagement.
We may retain limited information for longer where necessary to:
· comply with legal obligations;
· resolve complaints or disputes;
· maintain governance or audit records; or
· protect the security and integrity of our services.
We periodically review the personal data we hold and securely delete information that is no longer required. For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Joint data controllers
We have a joint controller relationship with Squarespace. We process your personal information with that joint controller for the following reason:
Our website is hosted by Squarespace. Squarespace collects personal information when you visit this website, including: information about your browser, network and device; web pages you visited prior to coming to this website; web pages you view while on this website; your IP address; Squarespace needs this data to run this website, and to protect and improve its platform and services and has its own privacy policy.
Sharing information outside the UK
Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Squarespace
Category of recipient: Website platform provider and host
Country the personal information is sent to: USA
How the transfer complies with UK data protection law:
Transfers are safeguarded using approved international transfer mechanisms including the UK International Data Transfer Addendum to the EU Standard Contractual Clauses and/or the UK Extension to the EU-US Data Privacy Framework.
The relevant Squarespace materials are:
· Squarespace Data Processing Addendum
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113