This policy describes how and why Victoria hospital incorporated uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.
We are a small charity that uses personal information in order to operate. Our use of personal information allows us to make better decisions and, ultimately, helps us to fulfil our mandate to use the charity's income to help those who need for assistance with medical or medically-related expenses in the Bailiwick.
This policy is effective from 25th May 2018.
We collect information in the following ways:
Information you provide to us directly
You may give us your information in order to claim for assistance, or when you assist someone else in doing so, or if you are a Committee member or if you otherwise communicate with us.
When you use our website, we may collect your personal information using “cookies” and other tracking methods. .In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
Information you provide to us indirectly
Your information may be shared with us by third parties, for example by people applying for asistance on your behalf. We also may receive data about you from subcontractors acting on our behalf who provide us with technical services, and from business partners, advertising networks and search/analytics providers used on our website.
We collect, store and use the following kinds of personal information:
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.
We only collect this type of information to the extent that there is a clear reason for us to do so, for example asking for health information if you are claiming for assistance with a particular condition.
Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and what it will be used for.
We will use your personal information to:
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current Guernsey data protection legislation.
Consent is where we ask you if we can use your information in a certain way, and you agree to this. Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Information Commissioner or to use information we collect about you for due diligence purposes.
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities VHI carries out with personal information.
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for legal purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details.
VHI has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations.
We will never sell or rent your information to third parties for marketing purposes. However we may disclose your information to third parties in connection with the other purposes set out in this policy. These third parties may include:
Some of our suppliers run their operations outside the European Economic Area (EEA) - this may include a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
Under Guernsey data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, send a description of the information you want to see by post to us or by email to [email protected]
You have the right to have inaccurate or incomplete information we hold about you corrected. If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.
You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: if some information we hold on you isn’t right; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done.
If we are processing your personal information based on our legitimate interests or, you have a right to object to our use of your information.
If you want to exercise any of the above rights, please contact us by post or by email to [email protected]. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the Guernsey Data Protection Commissioner (link is external).
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve.
You also have the right to lodge a complaint about any use of your information with the Guernsey data protection commissioner.
If you have any questions, comments or suggestions, please let us know by contacting the Honorary Secretary.