This charity privacy notice is in addition to, but does not override, our primary privacy notice.
1. Who ‘we’ are
When we outline to you how we take care of your data you will notice we use the words ‘the clinic’, ‘we’, ‘us’ or ‘our’. This means we are referring to The London Clinic (also known as Trustees of The London Clinic Limited). We are a limited company and charity registered in England and Wales. Find out more information about our company and charity status.
For the purposes of you using our website we are the ‘Data Controller’ of your personal data. We are responsible for deciding how we hold and use your data, for taking care of your data and ensuring that anyone we work with, who might need to access your data, also takes care of it and follows our rules. If there is ever a situation where another organisation or person is the Data Controller of your data, we will let you know.
Before we explain what data we collect, why we collect it and what we do with your data, if you have any questions or concerns, you can reach our Data Protection Officer via email@example.com.
What we do with your data
Yes, if you are a current, previous, or potential donor, a person in honour or support of whom a donation has been made of a person who has been notified of a donation.
No, special category data is not necessary for this website.
Yes, via various physical and digital methods, including this notice.
Yes, under privacy and electronic communications rules we must ensure we have your consent to send you marketing.
Yes, we will use information about you in our legitimate interests to tailor our messages to you and/or carry out background research on you.
Yes, but only with your consent.
Yes, The London Clinic has an extensive Records Retention Policy to ensure we only keep information only for as long as we need to.
Yes, alongside applying industry best practice, the clinic are Cyber Essentials certified and compliant with the NHS’s Data Security and Protection Toolkit (‘DPST’).
Yes, all staff receive training on a regular cycle.
Yes, we only permit access to those with a legitimate power or reason to access your information.
Yes, where your rights apply, we will process your request accordingly, and where they do not apply, we will explain this to you.
2. What data we collect from you
We will need different pieces of information from you for different purposes which will be driven by your interaction with us. We will always keep the data we need down to a minimum, and internally will ensure that only those with a legitimate need to see your data can do so.
As a summary, the sorts of data we collect from you for charitable purposes falls into the following categories:
This will include your basic contact details and ways for us to identify you. For example, your name, home address, email address, date of birth etc.
We need to be able to identify you to contact you.
This will include details of any marketing preferences you have selected.
We need this information to be able to contact you via the right channel to let you know about our activities, services and how you can support the clinic.
This will include details of your financial background or other charitable activities you are involved in.
We will process this data for our legitimate interests to do background research and get to know more about you.
3. How we lawfully process your data
We want to use information about you for the following reasons:
- With your permission, to keep you up to date on our services and activities and ask you to support our various charitable initiatives
- For conversations and requested communications with you about your Legacy Will and the ways you could help us to continue to advance healthcare. This is necessary for our legitimate interests
- To carry out background research, with the use of publicly available information, on you. This is necessary for our legitimate interests
- To qualify you and manage your status as a donor. This is necessary for our legitimate interests
- To tailor our messages to you so you only receive messages that are relevant to you. This is necessary for our legitimate interests.
4. Where we get your data from
We very rarely obtain information about you without your prior knowledge. We may collect information about you online. A donor may also provide us with your contact details in order to notify you of a donation you may be interested in.
6. Where in the world your data is physically sitting
We use systems, technology and/or support vendors who may store or have access to physical or cloud storage which resides both in the UK and abroad. This includes countries both within the European Economic Area (‘EEA’) and, in limited circumstances, those further afield, for example the United States of America.
Where we store or share personal data with a third party in a country outside of the UK or EEA, we will put appropriate safeguards in place to protect that data in accordance with the applicable Data Protection Laws and the ICO’s guidance. These range from a contract with that third-party supplier through to technical measures to protect it while it gets there.
7. How long we keep your data
We only keep your data as long as it is required either by English Law, codes of practice or our own legitimate business needs in line with our corporate policies. As a general principle, we only keep your data as long as is necessary and always ensure that any personal data is securely destroyed when it is no longer required.
8. How we protect your data
As you can appreciate, we cannot give you the full list of specific measures we have in place to prevent your data from being accidentally lost, used, accessed in an unauthorised way, altered or disclosed. However, please rest assured that we are committed to ensuring a high level of protection for your data while it is in our management.
Examples of some of the measures we have in place include:
- Agreed organisation-wide standards on security and data handling
- IT technical controls to limit access to your personal information only to those employees, agents, contractors and other third parties who have a business need-to-know
- Physical security controls on our buildings and wards
- Contractual controls with third parties (‘our house, our rules’)
- Training and awareness for all employees and Consultants
- Key roles in our organisation with specialist knowledge on Information Governance, Data Protection and Cyber Security to ensure your information is always protected.
9. What your rights are in connection with your data
Where we use your information with your consent you have a lot of control of how that data is used and shared by The London Clinic. However, where we are using your data under a legal obligation or other grounds, your rights under Data Protection Laws are more restricted. For example, where we feel we need to share or use data to save your life very few of the Data Protection rights apply.
A summary of all the Data Protection rights and how they apply to your interactions with us is below:
This is known as a data subject access request whereby you can receive a copy of the personal data that we hold about you. This right applies in all circumstances, however there might be some scenarios where we cannot provide you with some of the information requested (i.e. to protect the rights of others or due to legal privilege/confidentiality). If that is the case, we will explain this to you as part of our response to your request.
You can correct any incomplete or factually inaccurate personal data that we hold about you. It is important to understand that this right does not extend to matters of opinion, such as medical diagnoses. This right applies in all circumstances, however there might be some scenarios where we cannot retrospectively edit your record. If that is the case, we will explain this to you as part of our response to your request.
We cannot always fulfil your request if there are specific legal reasons requiring us to retain your personal data. We will explain these to you, if applicable, when responding to your request.
You can ask us to delete or remove your personal data where:
There is no good reason for us continuing to use it
You have successfully exercised your right to object to us using it or you have withdrawn your consent
We may have processed your information ‘unlawfully'
We are required to erase your personal data to comply with English law.
You can object to our processing of your personal data if:
We are relying on legitimate interests and you feel it impacts on your fundamental rights and freedoms. We may be able to demonstrate compelling overriding legitimate grounds for the processing
We are processing for direct marketing purposes.
You can ask us to suspend processing of your personal data if:
You want us to establish the data’s accuracy
Our use of your personal data is unlawful, but you do not want us to erase it
You need us to hold the data to establish, exercise or defend legal claims, even if we no longer require it
You have objected to our use of your data, but we need to verify whether we have overriding legitimate interests to use it.
You can request that we provide you or your chosen third-party with your personal data in a structured, commonly used, machine-readable format (an excel spreadsheet for example). This right only applies to electronic/digital information that you have provided to us either with your consent or where we use the information to perform a contract with you.
If you give us consent to process your personal data, you can withdraw that consent at any time by emailing firstname.lastname@example.org.
At any time, you can complain to either us or the ICO about any concerns you have over how your data is being handled.
To register a complaint with us please email email@example.com.
To register a complaint with the ICO please visit their website at www.ico.org.uk or address a letter to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or call their helpline on 0303 123 1113.
How you can find out more information
If you have any questions or queries about how we handle your personal data at The London Clinic, please get in touch at firstname.lastname@example.org.
Version 2.0. This notice was last updated in February 2022.