Royal Hospital Chelsea Group (RHCG)
The Board of Commissioners of the Royal Hospital Chelsea ('we', 'us' or 'our' ‘RHCG’) is committed to protecting and respecting your privacy.This policy, together with any other documents referred to in it, sets out the basis on how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and the care in which it will be handled.
Depending on the purpose for which you are providing your personal data to us, through any means listed within the Policy for the purpose of the Data Protection Act 2018 (the 'Act') and GDPR, the data controller (or entity responsible of the data collected) will be either:
- Royal Hospital Chelsea Appeal Ltd of Royal Hospital Road, Chelsea, London SW3 4SR and/or
- Chelsea Pensioner (RH) Ltd of Royal Hospital Road, Chelsea, London SW3 4SR and/or
- Tricorne Traders Ltd of Royal Hospital Road, Chelsea, London SW3 4SR
(together the Royal Hospital Chelsea Group).
The website https://www.chelsea-pensioners.co.uk is owned and operated by RHCG.
Under the EU’s General Data Protection Regulation (“GDPR”): Personal Data is defined as “any information relating to an identified or identifiable natural person ('data subject'); by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Who is the Data Controller?
A Data Controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. We are the data controller as defined by relevant data protection laws and regulation.
The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever personal data is to be processed:
(a) Consent: you have given RHCG clear consent for your personal data to be processed for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with RHCG has asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for RHCG to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for RHCG to perform a task that is in the public interest or for its official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for RHCG legitimate interests, or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data that overrides those legitimate interests.
What are your rights in respect of your personal data?
- The right of access.
- The right to rectification.
- The right to erasure or right to be forgotten.
- The right to restriction of processing.
- The right to be informed.
- The right to data portability.
- The right to object.
- The right not to be subject to a decision based solely on automated processing.
Under the Act and GDPR, you may ask for a copy of the information we hold about you and you may request changes be made to this information if it is inaccurate or not up to date. Please write to The Data Protection Officer (DPO), The Royal Hospital Chelsea, Royal Hospital Road, London, SW3 4SR or email DPO@chelsea-pensioners.org.uk in these circumstances. If you want to change the details that you have registered online with us, follow the instructions for each individual application.
What information we collect
Information that you provide by completing forms in writing, email, through our web site or social media. This includes information provided at the time of registering with us, to use our Website (where applicable), to become a Chelsea Pensioner, to become a member of staff, to enter into a contract for our services, to support or subscribe to our services (where applicable), to request materials or to request further services. We may also ask you for information when you enter a competition or promotion sponsored by any member of the Royal Hospital Chelsea Group, when you respond to a survey and/or when you report a problem with any of our communication channels or services.
We collect the following classes of information:
- Name(s) and address, email, phone number(s) and other relevant personal details and preferences
- Relevant historic and current Information about each Chelsea Pensioner
- Staff details relevant to their employment status with us
- Use of social media relating to the Royal Hospital Chelsea Group (e.g. following our Twitter feed)
- Records of donations
- Records of volunteering
- Photographs, recordings (audio and video) and associated information lent or given to the Royal Hospital Chelsea Group
- Information about our relationship with you, correspondence, meeting notes, attendance at events etc.
- Occupation, skills and professional activity, network(s) and interests where relevant to our needs
- Financial information where relevant to our needs
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out and of the fulfilment of your orders
- Details of your access to our databases or other materials.
- Providing CVs or other information about yourself for specific purposes such as employment, volunteering or becoming a Chelsea Pensioner. For further details please contact Health and Wellbeing Department regarding becoming a Chelsea Pensioner and the HR Department for employment and volunteering.
- To help us improve our services, if you send us personal information which identifies you via email, we may keep your email, your email address and 'screen' name. We may also collect information that is available from your browser.
- Details of your visits to our Website including; but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to either the Royal Hospital Chelsea Group or our advertisers/partners. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
Information others may share with us about you:
As a fundraising organisation, we undertake in-house research and routinely engage specialist agencies to gather information from publicly available sources to identify individuals who may have an affinity to our cause, but with whom we are not already in touch. Such publicly available sources include, but are not limited to, the electoral register, Companies House, company websites, political and property registers, news archives, ‘rich lists’ and social media networks e.g. LinkedIn. This research helps us to understand more about our donors and potential donors, as individuals, so we can focus our fundraising communications in the most effective way possible and provide our supporters with an experience that’s appropriate to them. You have the right to opt out of this processing at any time (see ‘Data Subject Rights’ section below). Our trusted third-party partners also use information from publicly available sources to carry out due diligence on donors in line with our Gift Acceptance Policy and to meet money laundering regulations.
Where we store your personal data:
The data that we collect from you will be processed at our servers located in the UK. It may also be processed by organisations operating in the EEA that RHCG has instructed.
If Personal Data is transferred outside the UK or EEA to a country without a designated adequacy rating RHCG will request the data subject's consent before processing the data. Consent will not be sought where the Processor's Binding Corporate Rules stipulate that the data will be processed in accordance with GDPR.
Third party sites
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
How long we keep your information:
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Disclosure of your information:
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements; or to protect the rights, property, or safety of RHCG, or others. This includes exchanging information with other organisations for the purposes of safeguarding or other statutory regulations we have to comply with.
Accessing your Information:
You can request to see a copy of the information we hold about you via the form provided on the website. Please complete and send the form to email@example.com We will endeavour to respond to your request within 30 days of confirming your identity.
RHCG may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns and does not identify any individual.
Please see our Cookies Policy https://www.chelsea-pensioners.co.uk/cookies for more information.
Right of the Care Quality Commission (CQC) to access records
Under the Health and Social Care Act 2008, the Care Quality Commission (CQC) has powers to access and use personal information where they consider this is necessary for them to carry out their functions as the regulator of health and adult social care services in England.
During an inspection of our regulated services (i.e. the Medical Centre, Nursing and Residential Wards, and our Domiciliary Care Service), an inspection team will ask to see certain records. Where possible, the inspection team will explain why they are required to access them and allow any concerns and objections to be raised.
Further information on how the CQC ensures compliance with data protection law (including GDPR) when carrying out its regulatory function, and its Privacy Statement, can be accessed via the following link: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Questions, comments and requests should be addressed to:
The Data Protection Officer (DPO)
Royal Hospital Chelsea,
Royal Hospital Road,
London SW3 4SR
or email firstname.lastname@example.org
For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
Information Commissioner's Office
Tel: 0303 123 1113 (local rate)