Privacy notice for referrers
In order to help NHS England cope with the pressures of the coronavirus crisis, Royal Voluntary Service has been appointed by NHS England to run the NHS Volunteer Responder Scheme (the ‘Scheme’). The aim of the Scheme is to recruit and deploy a network of volunteers throughout England who are willing and able to provide certain categories of support to:
- Individuals who are self-isolating for age or health related reasons (‘Individuals’); and
- Healthcare organisations, such as pharmacies, GP practices and hospitals (‘Organisations’).
Where an Individual requires support, they may self-refer into the Scheme or a third party (such as a GP practice, health care worker, hospital or pharmacy) may make a referral into the Scheme on their behalf. Where an Organisation requires support (for example, assistance with the transport of equipment), a referral into the Scheme can be made by an employee or other member of staff on behalf of that Organisation. A person who makes a referral into the Scheme on behalf of an Individual or an Organisation is referred to in this Privacy Notice as a ‘Referrer’.
In the course of running the Scheme, Royal Voluntary Service will collect, use and store certain personal data relating to Referrers. Royal Voluntary Service will be the ‘controller’ of such personal data, which means that it is required to explain to Referrers how their personal data will be processed and what data protection rights they have.
The purpose of this Privacy Notice is to provide such information to Referrers. Please read over this Privacy Notice carefully because it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
In addition to the terms defined above, we use the following defined terms in this Privacy Notice:
|We, us, our
||ROYAL VOLUNTARY SERVICE (a company incorporated in England and Wales with registered number 2520413, and a registered charity with number 1015988) whose registered office is at Beck Court, Cardiff Gate Business Park, Cardiff CF23 8R
|Our Data Protection Officer
||Name: Geraint Jugessur
Address: Beck Court, Cardiff Gate Business Park, Cardiff, CF23 8RP
Email address: email@example.com
Telephone: 029 2073 9184
||Any information relating to an identified or identifiable living individual
||A request for support from an NHS Volunteer Responder made by a Referrer on behalf of an Individual or an Organisation
||An individual who is a Referrer and at whom this privacy notice is directed
What Personal data we will collect about you
If you are an employee or other member of staff making a Request on behalf of an Individual or on behalf of the Organisation you work for, we will collect/obtain the following personal data about you:
- Your full name;
- Your contact information; and
- Who you work for and your job title.
It is also possible that we will obtain additional personal data about you as a result of ad hoc telephone conversations or other communications we have with you.
We will also collect certain personal data about you if you browse our NHS Volunteer Responders website. For further information about this, please refer to our NHS Volunteer Responders Website Privacy Notice.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so. One of the reasons we can rely upon is if we need to use your personal data for our legitimate interests or those of a third party, so long as this is not overridden by your own rights and interests.
To process your personal data, we will be relying on our legitimate interests in running the Scheme on behalf of NHS England and the legitimate interests of the Individuals and Organisations who stand to benefit from the Scheme.
We may also need to use your personal data to comply with our statutory and regulatory obligations.
In addition, we record telephone calls for training and monitoring purposes. Where we do so, we will again rely upon our legitimate interests as our lawful reason for using your personal data. This is on the basis that we need to ensure that staff who handle telephone calls deal with such calls appropriately and in accordance with our instructions and so that we can identify any training requirements.
Who we will share your personal data with
We will only share your personal data:
- Within our organisation, as necessary to administer the Scheme;
- With other organisations where necessary to comply with our statutory or regulatory obligations (for example, if you report a safeguarding issue relating to an Individual or an NHS Volunteer Responder, we might need to share your personal data with the police or social services); and
- With certain trusted service providers used by us to provide necessary services in relation to the Scheme (such as GoodSam Limited, who provides us with IT services and Ventrica Limited who provides us with call centre services).
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us.
Where your personal data is held
Your personal data will be stored within the software system made available to us by GoodSam Limited. GoodSam is one of the service providers we refer to in the section above (see above: ‘Who we will share your personal data with’). Your personal data will not be processed by GoodSam outside the EEA.
How long your personal data will be kept
Our general retention policy will be to retain your personal data only for the duration of the Scheme. It is envisaged that the Scheme will run for a period of 6 months from the beginning of April 2020. However, it is possible that NHS England will extend the duration of the Scheme. If this happens, we will review our general retention policy and consider whether we can delete any personal data about you which is no longer required by us.
Our general retention policy referred to above is subject to the following exceptions:
- We may need to retain your personal data for a longer period to enable us to deal with any complaints, grievances, investigations or legal claims or actions which arise. In this situation, we will retain such personal data as is necessary to deal with the relevant compliant, grievance, investigation or legal claim or action;
- In certain circumstances, we may need to retain your personal data for a longer period to enable us to comply with our statutory or regulatory obligations;
- Recordings of telephone conversations for training and monitoring purposes are retained for a period of 6 months; and
- We will retain information relating to the Scheme for the purposes of archiving in the public interest and historical research. Such information may include your personal data. Any such retention and subsequent processing of your personal data will be in accordance with the National Archives Guide to Archiving Personal Data 2018.
Once it is no longer necessary for us to retain your personal data, we will ensure that it is permanently and securely deleted or anonymised.
Under data protection law, you have a number of different rights which you can exercise free of charge. These are described in the table below. Some of the rights only apply in certain circumstances and not all of the rights will be relevant in relation to our use of your personal data:
||The right to be provided with a copy of your personal data (the right of access)
||The right to require any mistakes in your personal data to be corrected
|To be forgotten
||The right, in certain circumstances, to require that your personal data is deleted
|Restriction of processing
||The right, in certain circumstances, to require use of your personal data to be restricted (for example, if you contest the accuracy of the data)
||The right, in certain circumstances, to receive your personal data in a structured, commonly used and machine-readable format and/or transmit that data to a third party
||The right to object to your personal data being processed for direct marketing (including profiling) and the right, in certain circumstances, to object to the continued processing of your personal data on the basis of legitimate interests
|Not to be subject to automated individual decision making
||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of your rights, please email, call or write to our Data Protection Officer (see below: ‘How to contact us’). Please note that we will ask you to:
- Let us have enough information to identify you;
- Provide us with proof of your identity and address (e.g. a copy of your driving licence or passport); and
- Let us know what right you want to exercise and the information to which your request relates.
Keeping your personal Data safe
We have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal data.
If we are unable to resolve any query or concern you have to your satisfaction, please note that the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy Notice
This privacy notice was first published on 14 April 2020.
This version of the privacy notice was published on 5 August 2020.
We will make updated versions of our privacy notice available on our NHS Volunteer Responder website.
How to contact us
Please contact our Data Protection Officer by post, email or telephone if you have any questions about this privacy notice or the personal data we hold about you.
Our contact details are shown below: