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Privacy notice for volunteers

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 NHS Volunteer Responder Scheme aims 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. Volunteers may also be asked to provide assistance to health care organisations, such as GPs and hospitals, with transport

To run the NHS Volunteer Responder Scheme, Royal Voluntary Service will need to collect, use and store personal data relating to members of the public who apply to become and members of the public who are accepted as, NHS Volunteer Responders. Under UK data protection law, Royal Voluntary Service will be the controller of such personal data. This means that Royal Voluntary Service is required to explain to such members of the public how their personal data will be processed and what data protection rights they have.

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, it explains the role of and our and your relationship with GoodSAM Limited in relation to the NHS Volunteer Responder Scheme.

Key terms

In this privacy notice, for convenience, we use the following defined terms:

Individuals individuals who receive support from NHS Volunteer Responders under the Scheme
GoodSAM App            the volunteering app owned and run by GoodSAM
GoodSAM Data has the meaning set out in the section ‘Our and your relationship with GoodSAM
GoodSAM Limited GOODSAM LIMITED (a company incorporated in England and Wales with registered number 8742979) whose registered office is at 1 Curtain Road, London, EC2A 3JX
GoodSAM Website the volunteering website owned and run by GoodSAM and found at goodsamapp.org
NHSE NHS England
Our data protection officer Name: Geraint Jugessur
Address: Beck Court, Cardiff Gate Business Park, Cardiff CF23 8RP
Email address: dataprotection@royalvoluntaryservice.org.uk
Telephone: 029 2073 9184
personal data any information relating to an identified or identifiable living individual
SAP Concur has the meaning set out in the section ‘Our expenses system
Scheme the NHS Volunteer Responder Scheme
Shared Data has the meaning set out in the section ‘Our and your relationship with GoodSAM
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 8RP
You, your a member of the public who applies to become an NHS Volunteer Responder or a member of the public who is accepted as an NHS Volunteer Responder, and at whom this privacy notice is directed

 

Personal data we will collect

When you apply to become an NHS Volunteer Responder, we will need to collect/obtain the information listed below from you:

  • Your full name;
  • Your address, email address and telephone number;
  • Information to enable us to check and verify your identity (e.g. a copy of your passport or driving licence);
  • Details of which volunteering roles you wish to opt for; and
  • If you volunteer: (i) to provide support to Individuals with transport to hospital or other medical appointments; (ii) for our Community Support Plus role (i.e. an NHS Volunteer Responder who is cleared to deliver Community Support tasks to vulnerable adults); or (iii) for our Check in and Chat Plus role, a copy of an Enhanced DBS check dated within the last 12 months. In relation to (i) and (ii), we will also require a Children’s or Adults’ Barred list (or both), dated within the last 12 months. Alternatively, we may ask you to provide evidence of the required level of DBS clearance using an online DBS service.

If you are accepted as an NHS Volunteer Responder, we will also receive the following personal data about you:

  • As a result of our and your use of the technology which underpins the Scheme (see the section below ‘Our and your relationship with GoodSAM’), we will receive data about the volunteering tasks you accept and perform;
  • If you submit a claim to us for expenses, we will need to obtain information from you to enable us to verify the expenses you are claiming (such as copies of receipts and details of journeys you have taken when performing your role as an NHS Volunteer Responder). We will also need your bank details so that we can reimburse you. Further information about how our expenses system will work is set out below in the section below ‘Our expenses system’);
  • Personal data you provide to us if you telephone our call centre or email us with a query or issue and/or personal data provided to us by Individuals or other persons or organisations you interact with as a result of your role as an NHS Volunteer Responder; and

We will also obtain certain personal data about you if you use our NHS Volunteer Responders website (for example, your IP address and cookie data). For more information about this, please refer to our NHS Volunteer Responders Website Privacy Notice.

How and why we use your personal data

Under UK data protection law, we can only use your personal data if we have a lawful basis for doing so. For example:

  • to comply with our legal and regulatory obligations;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a reasonable need to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use your personal data for and our lawful basis for doing so under UK data protection law:

 

Copies of the documents you provide to verify your identity 

To check your identity Our legitimate interest in ensuring you are who you say you are

Information relating to your level of DBS clearance and related criminal convictions data To ensure you have the necessary level of DBS clearance for certain volunteer roles

To make decisions about whether you are suitable to continue as a volunteer within the Scheme
Our legal obligation to ensure you are a suitable person to provide certain categories of volunteering support

Our legitimate interest in ensuring the safety and wellbeing of Individuals who receive support under the Scheme

The information you input into our online application form To register you as an NHS Volunteer Responder and keep a record of your details

Our legitimate interest in administering the Scheme effectively
Information we collect about volunteering tasks you accept and perform To ensure that Individuals receive the support they need and to enable us to keep track of the support provided by our volunteers

Our legitimate interest in ensuring that the Scheme is run effectively
The information you input into our online application form and the level of DBS clearance you have To appropriately match volunteers to Individuals Our legitimate interest in ensuring that Individuals are protected and kept safe

The information you input into our online application form So that we can deal with any queries we receive from you Our legitimate interest in ensuring that the Scheme is run effectively

The information you input into our online application form and the level of DBS clearance you have To ensure you are performing your role in accordance with our instructions and guidance and so that we can investigate any complaints we receive Our legitimate interest in ensuring that the Scheme is run properly and safely

Our legal obligation to investigate complaints
Your full name, telephone number email address and/or postal address So that we can communicate/correspond with you about the Scheme

Our legitimate interest in ensuring that the Scheme is run effectively
Information about expenses you are claiming and payment details to enable us to reimburse you

To enable us to process claims for expenses and reimburse you Your legitimate interest in being reimbursed for such expenses
Information we obtain about you if you telephone our call centre with a query or as a result of communications with Individuals or other third parties about your role and/or volunteering tasks you have performed To enable us to manage your role as an NHS Volunteer Responder, deal with your queries and respond appropriately to information provided to us by Individuals or other third parties Our legitimate interest in ensuring that the Scheme is run effectively

Your legitimate interest in having your queries dealt with appropriately

The legitimate interests of Individuals and other third parties (e.g. such as their interests in ensuring that complaints are dealt with promptly and appropriately)

Data we collect automatically if you use our NHS Volunteer Responders website To enable us to run the website effectively Our legitimate interests and, in relation to our use of certain cookies, your consent. You can find more information about the legal bases we rely upon when we collect personal data via our
NHS Volunteer Responders website
Your full name, telephone number, email address and/or postal address To contact you for the purposes described in the section ‘Promotional Communications

Your express consent
Information about your volunteering journey (for example, when you became a volunteer, how often you use the GoodSAM App and how often you accept volunteering tasks).

So that we can compile anonymous statistics to help us and NHSE make decisions about the Scheme Our and NHSE’s legitimate interests in ensuring that the Scheme supports as many individuals in need as possible and runs efficiently

 

Criminal Convictions Data

As we are required by law to screen volunteers who apply for certain volunteer roles for relevant criminal convictions (see the section above ‘Personal data we will collect’), it may be the case that we will process criminal convictions data about you. Where we do so, in addition to the legal bases referred to in the above table, we will rely on a condition under UK data protection law which permits us to process criminal convictions data where it is necessary to do so for the purpose of carrying out our obligations in the field of employment and social protection law.

If we obtain criminal convictions data about you after you have been accepted as an NHS Volunteer Responder (e.g. if you respond to a recruitment drive for CRV+ volunteers) we may use such criminal convictions data to assess your general suitability as an NHS Volunteer Responder (which could result in your role as an NHS Volunteer Responder being terminated). Where we use criminal convictions data for this purpose we will: (i) do so in accordance with internal guidelines based on best practice relating to the rehabilitation of offenders and (ii) rely on a condition under UK data protection law which allows us to process criminal convictions data where this is necessary for safeguarding purposes.

We are required to have ‘appropriate policy document’ in relation to our processing of criminal convictions data. If you would like to see a copy of our appropriate policy document, please contact us.

Promotional communications

We will only use your personal data (i.e. your name, telephone number, email address and/or postal address) to communicate with you about other volunteering opportunities with Royal Voluntary Service if you have given us your express consent to do so (for example, if you agreed to this at the time you applied to become an NHS Volunteer Responder or if, at the end of the Scheme, you give us permission to provide you with information about our other volunteering roles).

As a general rule, we will not share your personal data with other organisations for promotional or marketing purposes or contact you with promotional information about other organisations. However, when applying to become an NHS Volunteer Responders, some individuals will have been asked:

  • If they consent to Royal Voluntary Service contacting them about other volunteering opportunities with NHSE; and
  • If they consent to GoodSAM contacting them about becoming a GoodSAM cardiac volunteer responder.

If you have consented to Royal Voluntary Service contacting you about other volunteering opportunities with NHSE, from time to time Royal Voluntary Service will use your name, telephone number, email address and/or postal address to provide you with information about other NHSE volunteering opportunities which are brought to our attention by NHSE as a result of our partnership with NHSE in relation to the Scheme. If you consent to GoodSAM contacting you about becoming a GoodSAM cardiac volunteer responder, we will share your name and email address with GoodSAM and GoodSAM will subsequently get in touch with you directly.

Please note that if you decide to volunteer for NHSE or GoodSAM, you will be doing so independently of your relationship with Royal Voluntary Service and any use of your personal data by NHSE or GoodSAM will not be controlled or overseen by Royal Voluntary Service and will be subject to the privacy notices used by those organisations.

You have the right to withdraw your consent to us contacting you about Royal Voluntary Service or NHSE volunteering opportunities at any time. To do so, please contact us in any of the ways set out in the section ‘How to contact us’ below.  However, if you consent to us sharing your name and email address with GoodSAM but you subsequently change your mind about becoming a GoodSAM cardiac responder, you will need to contact GoodSAM directly to withdraw your consent. 

Our and your relationship with GoodSAM

The effective operation of the Scheme relies upon technology made available to NHSE, Royal Voluntary Service and you by GoodSAM.

In particular:

  • To apply to become an NHS Volunteer Responder, you will need to fill out the online application form on the GoodSAM Website;
  • If you are accepted as an NHS Volunteer Responder, you will need to download, install and use the GoodSAM App so that we can notify you of volunteering tasks in your area and you can accept and perform volunteering tasks; and
  • We will use a software platform made available to us by GoodSAM (which will interface with the GoodSAM App) to help us run the Scheme.

This means that we will need to share your personal data with GoodSAM. It also means that you will provide some personal data to GoodSAM directly. Consequently, GoodSAM’s role under UK data protection law will vary depending on what personal data it is processing and why. In this section, we provide more information about our and your relationship with GoodSAM.

GoodSAM as our data processor

In relation to the following personal data, GoodSAM will act as our data processor and process your personal data on our behalf:

  • GoodSAM’s use of the personal data you provide to us when you apply to become an NHS Volunteer Responder;
  • Other personal data about you which is input into the GoodSAM software platform as a result of your dealings with us as an NHS Volunteer Responder; and
  • Personal data relating to the acceptance and performance by you of volunteering tasks which we obtain as result of the interface of the GoodSAM software platform with the GoodSAM App.

Where GoodSAM processes your personal data as our data processor, GoodSAM will be subject to contractual obligations to us only to process your personal data in accordance with our instructions, not to use your personal data for other purposes and to keep your personal data safe and secure.

GoodSAM as joint controller

If you are accepted as an NHS Volunteer Responder, to enable GoodSAM to create an account for you on the GoodSAM App, Royal Voluntary Service will need to make available to GoodSAM your full name and email address (‘Shared Data’).

GoodSAM and Royal Voluntary Service will then become joint controllers of the Shared Data. This means that both Royal Voluntary Service and GoodSAM will have certain rights to use the Shared Data but must also comply with the obligations and restrictions set out in UK data protection law.

For the duration of the Scheme, GoodSAM will be subject to contractual obligations to us only to use the Shared Data for the purposes of providing and running the technology which underpins the Scheme. However, once the Scheme has come to an end, GoodSAM’s use of the Shared Data will be in accordance with its privacy notices and policies (subject to its obligation to use the Shared Data in accordance with UK data protection law). GoodSAM should be able to provide you with a copy of such notices and policies.

While the Scheme is ongoing, you may submit a request to exercise any of the rights referred to in the section ‘Your rights’ below in relation to the Shared Data to either GoodSAM or Royal Voluntary Service.

GoodSAM as sole controller

In relation to your use of the GoodSAM Website and the downloading, installation and use by you of the GoodSAM App, you will have a direct relationship with GoodSAM. This means that, in relation to GoodSAM’s collection and use of the following personal data, GoodSAM will be acting as sole controller:

  • Personal data automatically collected from you by GoodSAM as a result of your use of the GoodSAM Website (for example, your IP address and cookie data);
  • Personal data collected from you by GoodSAM when you download, install and use the GoodSAM App (other than personal data that relates to your volunteering role in relation to the Scheme). For example, data relating to your mobile phone or other device, location data and any profile you create on the GoodSAM App.

GoodSAM will use such personal data (referred to from here on as ‘GoodSAM Data’) in accordance with its own privacy policies and notices (subject to compliance by GoodSAM with the requirements of UK data protection law). Such policies and notices should be available on GoodSAM’s website and when you download and install the GoodSAM App. Any requests to exercise any of the rights referred to in section ‘Your rights’ below will need to be made to GoodsAM and any claims you have for misuse of the GoodSAM Data will need to be made against GoodSAM.

Our expenses system

As an NHS Volunteer Responder, you will be able to submit claims to us for the reimbursement of certain expenses (we will email you with details of what expenses you can claim and how to do this). To assist us with the administration and processing of expenses claims and payments, we will use an expenses system provided by Concur Holdings (Netherlands) B.V. (‘SAP Concur’).

The expenses system will work in the following way:

  • Once you have completed your first volunteering task, we will share your name, email address and your unique volunteer identification number with SAP Concur. This will enable SAP Concur to create a user account for you on its expenses system;
  • Before you can submit any claims for expenses, you will need to have downloaded and installed the SAP Concur App onto your mobile phone or other device. Once you have done so, to access your account on the SAP Concur App, you will need to verify your email address and unique volunteer identification number;
  • To submit an expenses claim you will need to access your account on the SAP Concur App and input details about the expenses you are claiming. The details will vary depending on what expenses you are claiming (for example, to make a mileage claim you will need to enter the start and end point of your journey and to claim for hand sanitiser you will need to upload a photograph of your sales receipt). In most cases, you will also need to provide the job identification number to which the claim relates. In addition, you will be asked to input details of the bank account into which you require any payment to you to be made.
  • If your expenses claim is accepted, we will pay the amount of expenses you are entitled to directly into your bank account.

We have entered into an agreement with SAP Concur relating to the provision of its expenses system. Under that agreement, SAP Concur will process any personal data relating to you which comes into its possession as a result of: (i) us sharing information with SAP Concur so that an account can be created for you; and (ii) you making an expenses claim (‘Expenses Data’) as the processor of Royal Voluntary Service. This essentially means that SAP Concur will be required to process Expenses Data strictly in accordance with our instructions and for no other purposes.

Under our agreement, SAP Concur has authorisation to share Expenses Data with sub-contractors that it uses to provide its expenses system, but any such sharing by SAP Concur must be on and subject to equivalent terms to those set out in our agreement with SAP Concur and will therefore restrict the processing of Expenses Data by such sub-contractors.

SAP Concur will retain Expenses Data for a period of 6 months following the end of our agreement with SAP Concur. After the expiry of this period, SAP Concur will erase your personal data.

As stated above, however, before you can make any claims for expenses, you will need to download and install the SAP Concur App. If you do so, you will be entering into a direct relationship with SAP Concur in relation to your use of the SAP Concur App. Also, SAP Concur will become a controller of certain of your personal data (such as data it obtains relating to the device on which you install and use the SAP Concur App and your location data). SAP Concur’s terms of use and privacy information relating to its App should be available to you at the time you download and install the SAP Concur App.

Sharing of your personal data with other third parties

As well as GoodSAM and SAP Concur, we will also need to share your personal data with certain other trusted organisations who are providing essential services to us in relation to the Scheme. This includes:

  • Ventrica Limited, the organisation which operates our NHS Volunteer Responder call centre, helps us to check the identity and DBS certificates of members of the public who apply to become NHS Volunteer Responders and undertakes certain other work on our behalf;
  • Our mailing partner, The Woods Group Limited;
  • The organisations which host our websites and software systems;
  • Our insurers and our banks; and
  • Our professional advisers (such as lawyers and accountants).

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may also disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

As stated above (see ‘How and why we use your personal data’), we will use information we obtain about your journey as an NHS Volunteer Responder to create anonymous statistics about the Scheme. For example, statistics about how many people have volunteered as NHS Volunteer Responders or how often our NHS Volunteer Responders use the GoodSAM App. We will include such statistics in reports we share with NHSE and other government bodies (who may, in turn, share those reports more widely). No personal data about you will be included in any such reports. 

How long your personal information will be kept

Unsuccessful applications

In the event that we are unable to accept your application to become an NHS Volunteer Responder, we will delete your application form from our system as soon as reasonably practicable. This will include any copy documentation you have provided to us to verify your identity and any copies of DBS certificates. We will, however, retain your name and email address for the duration of the Scheme. This is necessary for our general record keeping and audit purposes and so that we can compile statistics relating to the total number of applications received. 

Successful applications

If you are accepted as an NHS Volunteer Responder, our general retention policy will be to retain your personal data for the duration of the Scheme plus an additional period of 6 months. While the Scheme is still operational, we need to retain your personal data to enable us to run the Scheme effectively. Retention for a further period of 6 months after the Scheme has ceased to operate is necessary for our general business purposes (including audit and processing expenses claims) and to enable us to deal with any ad hoc queries and/or complaints which arise.

Please note that it is currently envisaged that the Scheme will run for a period of 6 months from the start of April 2020. However, it is possible that NHSE will extend the duration of the Scheme and if this happens, we will review our general retention policy and evaluate whether any personal data which is no longer required can be deleted at this stage.

Our general retention policy referred to above is subject to the following exceptions:

  • If you submit an expenses claim to us (see section above ‘Our expenses system’) we will retain Expenses Data for a period of 7 years from the end of the financial year in which the claim is submitted. This is necessary to enable us to comply with statutory requirements relating to accounting and taxation.
  • We may need to retain your personal data for a longer period to deal with any complaints, grievances, investigations or legal claims or actions involving or relating to you. In this situation, situation, we will retain such personal data as is necessary to deal fully with the relevant complaint, grievance, investigation or legal claim or action;
  • If a safeguarding concern arises, we will retain such personal data relating to you as may be necessary to deal with the issue and/or meet our obligations in relation to safeguarding (including any regulatory or legal obligations); 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.

In addition, if, at the end of the Scheme, you agree to take up a broader volunteering role for us, we will retain such of your personal data as is necessary to register you as a general Royal Voluntary Service Volunteer. Subsequently, our use and retention of your personal data will be in accordance with our general privacy notice and retention policy (you can find links to these documents on our main Royal Voluntary Service website).

Deletion of personal data

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.

Our retention Schedule

Further details about our retention policy can be found in our retention schedule relating to the Scheme. Please contact us if you would like to be provided with a copy of this.

Where your personal information is held

Your personal data will be held in the UK on the GoodSAM software platform. It will not be transferred by us or GoodSAM outside the UK and/or EEA.  

However, in relation to the GoodSAM Data, it is possible that GoodSAM may store or transfer your personal data outside the UK and/or EEA. Where GoodSAM does so, GoodSAM should make available to you information about how it safeguards your personal information.

Your rights

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:

 

Access The right to be provided with a copy of your personal data (the right of access)

Rectification 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)

Data portability 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

To object 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 information secure

If you are accepted as an NHS Volunteer Responder, the personal data you provide to us in your application form will be stored in a secure database made available to us by GoodSAM for the purpose of the Scheme. Your personal data will be kept separate from other personal data stored by GoodSAM.

In addition, we have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business 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.

 

Registering an interest

If, at the time you apply to become an NHS Volunteer Responder, we are not recruiting in your area, you will be given the option to register your interest in volunteering for the role. We will then automatically email you when we are next recruiting for NHS Volunteer Responders in your area.

If you decide to register your interest with us, please note the following information:

  • You will be required to provide us with your name, email address and your Local Authority;
  • We will retain this information for the duration of the Scheme;
  • We will only use this information to contact you for the purpose of notifying you that we are recruiting in your area;
  • We will rely on our legitimate interests as our legal basis for retaining and using the information;
  • The information will be securely held by one of our trusted service providers.

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.

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 https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was first published on 23rd April 2020.

This version of the privacy notice was published on 8th September 2020.

We will make updated versions of our privacy notice available on our NHS Volunteer Responders website.

How to contact us

Please contact us/our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the personal data we hold about you.

Our contact details are shown below:

Our data protection officer Geraint Jugessur
Our postal address Royal Voluntary Service, Beck Court, Cardiff Gate Business Park, Cardiff CF23 8RP
Our email address Email address: dataprotection@royalvoluntaryservice.org.uk
Our telephone number Tel:02920739184

 

 

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