Transform Healthcare Cambodia
reviewed Nov 2020
Data Protection and Privacy Policy
We work to strengthen health care systems in Cambodia. We are a registered charity in the UK
In the course of our work we gather items of personal information and data for various individuals, in line with our specific business needs. THC takes the protection of your data seriously and operates a policy that is in full compliance with the General Data Protection Regulation.
The responsibility for data protection at THC is held collectively by the board of directors who also have overall accountability. We are not required to appoint a Data Protection Officer.
This policy explains how we gather, use and share information about you, and respect your privacy rights. It will be kept under review and always accessible on our website.
1. What is our lawful basis for gathering & processing your data?
The lawful basis we have for gathering and processing your data will vary depending on the business operational need:
· We have a legitimate interest in holding basic personal data in support of our Customer ( / Partner) Relationship Management (CRM) process, and we also seek consent to promote the work that we do to interested individuals.
· We have a legal and contractual obligation to process data relating to anyone who works or volunteers for us in order to fulfil the terms of their contracts, as well as any payroll and statutory HMRC requirements, that may occur. We also have a legitimate interest in retaining information, for a period of time, for anyone who applies for a job or as a volunteer with us to assess against future opportunities.
· We have a contractual obligation to our partners to process some data in order to satisfy the requirements of our business arrangement with them.
2. What Personal data do we hold and process and the basis of this
· enquiries about our organisation and voluntary or work opportunities
name and contact details email mob no,
it is necessary for us to read and store your message so that we can respond in the way that you would expect.
· volunteers
name, contact details, including email mob no, whats app, emergency contact details, relevant health issues, dietary requirements, CV details for the application, skills and experience references photographs, disability information DBS checks needed to manage whilst volunteering abroad, ensure safety of people working with and self and evidence that we have done due diligence
· subscribing to email updates about our work
name and email
in giving email have given active consent
· Making a donation
Name, email, address, payment information and information required by HMRC re gift aid etc Legitimate interests - this information is necessary for us to fulfil your intention of donating money and your expectation of receiving a confirmation message
· website functionality
Website activity collected through cookies
Legitimate interests- it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.
By submitting this information, you are providing your consent that all of the personal data you submit can be processed in the manner in which you expect.
3. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out at the top of this policy.
For example, we may use your personal information to:
● reply to enquiries you send to us;
● support business planning or organisational capability
● handle donations or other transactions that you initiate;
● where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.
4. When we share your data
We will only pass your data to third parties in the following circumstances:
● you have provided your explicit consent for us to pass data to a named third party;
● we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or
● we are required by law to share your data.
In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation
5. How we protect your data
we store your data on "sync"data storage platform which is highly rated for data protection and includes end to end encryption. The area in Sync where personal data is held is only accessible by directors of THC with high secure log on credentials
We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.
6. Rights you have over your data
You have a range of rights over your data, which include the following:
● Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).
● You have the right to ask for rectification and/or deletion of your information.
● You have the right of access to your information.
● you hava right to Ask for the transfer of your data electronically to a third party
● You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
7. Cookies & usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at http://www.google.com/privacypolicy.html
8. Modifications
We may modify this Privacy Policy from time to time and will publish the most current version on our website.
If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.
If you have any comments or questions about this notice, feel free to contact us at:
info@transformhealthcarecambodia.org.uk TBC or, in writing:
Data Protection Officer
Transform Healthcare Cambodia
290 Heysham Rd,
Heysham,
Morecambe LA3 1PZNew Paragraph