Who we are

Shooting Star Children’s Hospices is a children’s hospice charity caring for babies, children and young people with life-limiting conditions, and their families. Whether lives are measured in days, weeks, months or years, we are here to make every moment count. We support families from diagnosis to end of life and throughout bereavement with a range of nursing, practical, emotional and medical care. As an organisation, Shooting Star Children’s Hospices is registered with the Information Commissioner (Z7764577) in accordance with the General Data Protection Regulations. Our registered charity number is 1042495.

Making contact

If you would like to discuss anything in this privacy notice, please contact:

Data Protection Officer
Shooting Star Children’s Hospices, Shooting Star House, The Avenue, Hampton, TW12 3RA
01483 230960

dataprotectionofficer@shootingstar.org.uk

The categories of personal information that we process include:

• personal and contact information (such as name, date of birth, address and contact information & preferences)
• financial information and giving history (for example your bank or credit card information that you provide to make a donation and your tax status for Gift Aid purposes)
• wealth and financial profile (created from publicly available sources such as news articles, companies house or property registers)
• records of other support that you have given (such as events that you have attended or campaigns that you have engaged with.)
• interests and preferences (e.g. services and event types that you are either interested or not interested in, or information that you provide in surveys or other feedback)
• technical information (such as IP address or in cookies when visiting the website)
• photos, video and other media (if you consent for this to be used)
• basic health information (such as dietary requirements or allergies if you were to attend an event)

We process this information in order to:

• promote the work of Shooting Star Children’s Hospices and to encourage support and giving.
• understand more about you as an individual so we can focus conversations we have with you about fundraising, volunteering, campaigning and other things in the most effective way.
• accept and manage financial gifts including claiming and managing Gift Aid.
• to process and manage non-financial gift, particularly charity-shop donations.
• take payment and send online shop purchases.
• plan and run events, or assist supporters in running events, including ticketing and providing refreshments at event.
• monitor website usage and help improve the user experience.

The Lawful basis for processing the personal data.

• Most of the routine processing of data around donations and gifts is in order to fulfil that contract or meet other legal obligations to record keeping.
• Most marketing and awareness raising is processed with your consent. Some marketing (for example postal and some social media marketing) is delivered as a legitimate interest activity of the charity.
• Fundraising research into individuals, including wealth profiling is undertaken under the legal basis of legitimate interests.
• Where this data is classed as “special category” data (mainly health information for events) this is processed under the specific legal basis of adequately protecting the public

Where is the data obtained from:

Most information we process will have been provided by you directly. In some circumstances information is provided to us via a third party. Most commonly this is from:

• a fundraising site (e.g. Just Giving) when you agree to allow them to share your details with us.
• an employer or payroll provider where you provide financial support through payroll giving.
• directly or via a third-party gathered from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers and news archives.
• the fundraising lottery, where you support Shooting Star by playing the Tuckwell Chase Lottery.

Sharing with other people

There are times when information is made available to other people who process that data on our behalf. These are:

• Services that send marketing communications such as Mailchimp and mailing houses that send our postal mail.
• Financial processing services such as Stripe, Paypal and associated banking services.
• Specialist wealth intelligence and trusted research agencies who help us focus our fundraising efforts correctly
• Social media services that provide analytics and marketing services such and Google and Facebook
• Event planning and ticketing services such as Active Network
• Standard IT service providers such as the providers of our IT support systems, and staff communications service providers
• Other organisations like the police or social services need it to detect or investigate crime or when a formal court order has been made.

International transfers

All data is processed within the United Kingdom or the EEA. As part of disaster recovery plans for some IT services it is possible that data may be transferred to a different geographic region temporarily as part of the recovery procedures.

Storage, retention and erasure

Data is primarily stored and access controlled in a secure centralised donor management system, our CRM.

We will only retain your personal information for as long as necessary and to fulfil the purposes we collected it for, including for the purposes of satisfying any legal and accounting requirements.

We may keep information for longer than this for the purposes of reporting and analysis.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may de-identify 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. We will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.

Should you wish to have your information deleted before this, please make contact and we can process this request as long as there is no overriding legal obligation for us to keep the records (e.g. for financial reporting obligations)

Your data protection rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• 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, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at the detail provided at the top of this privacy notice if you wish to make a request.

Freedom of Information Requests

Shooting Star Children’s Hospices is not a “public authority” as defined under the Freedom of Information Act and we will therefore not respond to requests for information made under this Act.

Making a complaint

If you have any concerns about our use of your personal information, you can make a complaint to us, please contact our Data Protection Officer using the details provided above.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Who we are

Shooting Star Children’s Hospices (SSCH, us, we) is a children’s hospice charity caring for babies, children and young people with life-limiting conditions, and their families. Whether lives are measured in days, weeks, months or years, we are here to make every moment count. We support families from diagnosis to end of life and throughout bereavement with a range of nursing, practical, emotional and medical care. As an organisation, Shooting Star Children’s Hospices is registered with the Information Commissioner (Z7764577) in accordance with the General Data Protection Regulations. Our registered charity number is 1042495.

Making contact

If you would like to discuss anything in this privacy notice, in the first instance please contact:

People Team
Shooting Star Children’s Hospices, Shooting Star House, The Avenue, Hampton, TW12 3RA
01483 230960
HRteam@shootingstar.org.uk

You are also able to contact the Data Protection Officer regarding data protection issues.

dataprotectionofficer@shootingstar.org.uk

What is the purpose of this document?

This privacy notice describes how we collect and use personal information about you before, during and after your working or volunteering relationship with us, in accordance with data protection legislation. It applies to all employees, workers, volunteers and contractors.

Shooting Star Children’s Hospices is a “data controller” of your personal data. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers, volunteers and contractors. This notice does not form part of any contract of employment or other contract to provide services (though it may be referenced therein). We may update this notice at any time.

Data protection principles

We will comply with data protection law. This requires that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

• • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Identity and descriptive information including:
    • Date of birth.
    • Marital status
    • Next of kin and emergency contact information.
    • Proof of Identity documents (e.g. Driving licence or passport)
    • National Insurance number.
    • Photographs
  • Financial information such as
  • • Bank account details, payroll records and tax status information.
    • Salary, annual leave, pension and benefits information.
    • Compensation history.
  • Employment and/or Volunteering records(including job titles, work history, working hours, training records and professional memberships).
    • Start and leaving date.
    • Performance information.
    • Disciplinary and grievance information.
    • Information about your use of our information and communications systems, including access logs.
  • Recruitment or volunteer selection information
    • including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process.

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your health, including any medical condition, health and sickness records.
• Information about any criminal convictions and offences
• Ethnicity data

How is your personal information collected?

We collect personal information about employees, workers, volunteers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us, through reporting of sickness and as part of access control and reasonable monitoring activities.

How we will use information about you

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:

1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. 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.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you (Contract) and to enable us to comply with legal obligations (Legal). In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties (Legitimate interests), provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• Making a decision about your recruitment or appointment or volunteer placement (Contract).
• Determining the terms on which you work for us (Contract).
• Checking you are legally entitled to work in the UK (Legal).
• Paying you or reimbursing expense and, if you are an employee, deducting tax and National Insurance contributions (Legal and Contract).
• Liaising with your pension provider (Legal and Contract).
• Administering the contract we have entered into with you (Contract).
• Business management and planning, including accounting and auditing (Legitimate interests).
• Conducting appraisals, performance reviews, managing performance and determining performance requirements (Contract).
• Making decisions about salary reviews and compensation (Contract).
• Assessing qualifications for a particular job or task, including decisions about promotions (Contract and Legitimate interests).
• Gathering evidence for possible grievance or disciplinary hearings (Contract).
• Making decisions about your continued employment or engagement (Contract, Legal and Legitimate interests).
• To communicate with you about your role, potential volunteering opportunities or relevant work of the charity (Contract and Legitimate interests).
• To make arrangements for the termination of your working or volunteering relationship (Contract, Legal and Legitimate interests).
• Education, training and development requirements (Contract and Legitimate interests).
• Dealing with legal disputes involving you, or other employees, workers, volunteers and contractors, including accidents at work (Contract and Legal).
• Ascertaining your fitness to work or volunteer (Contract and Legal).
• Managing sickness absence (Contract and Legal).
• Complying with health and safety obligations (Legal).
• To prevent fraud (Legal).
• To monitor your use of our information and communication systems to ensure compliance with our IT policies (Contract, legal and Legitimate interests).
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution (Contract, legal and Legitimate interests).
• To conduct data analytics studies to review and better understand employee retention and attrition rates (Legitimate interests).
• Equal opportunities monitoring, dealing with regulators and quality assurance (Legal and Legitimate interests).

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. 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:

• In limited circumstances, with your explicit written consent;
• Where we need to carry out our legal obligations;
• Where it is needed in the public interest, such as for equal opportunities monitoring; and/or
• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations to you

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
• When we need your consent

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data, such as biometric data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you do consent, you can withdraw this consent at any time.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations. This is particularly relevant to our safeguarding obligations in providing care to vulnerable children and their families.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.

Data sharing

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK and the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and professional services firms) and investors. The following processing activities are carried out by third-party service providers on our behalf in relation to your personal data: pension administration, benefits provision, administration and IT / communications services, occupational health services, DBS checking services, HR and payroll services.

Volunteering roles may require us to share your information with third parties who are involved in organising or delivering an event or service, for example when you volunteer to work in a specific retail shop.

How secure is my information with third-party service providers?

All third parties with whom we share personal data are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We also limit the amount of your personal data they receive to that which is required.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

Applicants and unsuccessful candidates

The information you provide as part of any application process will normally be kept for six months after the decision point for that process. With your consent we may keep your details on record for longer, potentially to be used in future application processes. As a legitimate interest we will generally keep very high-level information (e.g. name and interview dates, but not interview notes) for planning and charity management purposes.

Current employees, workers, volunteers and contractors

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 consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

Past employees, workers, volunteers and contractors

Once you are no longer an employee, worker, volunteer or contractor of the charity we will retain and securely destroy your personal information in accordance with applicable laws, regulations and our legitimate business requirements.

Rights of access, correction, erasure, and restriction

Your responsibility to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. 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.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the HR Team using the details at the top of this notice.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). 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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information 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 HR Team using the details at the top of this notice. 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 so in law.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.