1. What is the purpose of this document?
2. Data protection principles
3. The kind of information we hold about you
4. How is your personal information collected?
5. How we will use information about you
6. Marketing preferences
7. If you fail to provide personal information
8. Change of purpose
9. How we use particularly sensitive personal information
10. Our obligations as a workplace provider
11. Information about criminal convictions
12. Automated decision making
13. Data sharing
14. Data security
15. Data retention
16. Rights of access, correction, erasure, and restriction
17. Data protection officer
Sue Ryder (registered company 00943228 and charity number 1052076 in England and Wales and SC039578 in Scotland) is committed to protecting the privacy and security of your personal information.
It is important that you read this policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
We will comply with data protection law. This says that the personal information we hold about you must be:
- 2.1. Used lawfully, fairly and in a transparent way.
- 2.2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- 2.3. Relevant to the purposes we have told you about and limited only to those purposes.
- 2.4. Accurate and kept up to date.
- 2.5. Kept only as long as necessary for the purposes we have told you about.
- 2.6. Kept securely.
Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (‘anonymous data’). There are ‘special categories’ of more sensitive personal data that require a higher level of protection.
We will collect, store, and use the following categories of personal information about all volunteers aged between 14 and 17:
Personal contact details such as your name, title, addresses, telephone numbers, and personal email addresses. We’ll use details like your email address to make you aware of any specific information about your role, and to send you a welcome email. We may use your postal address to send thank you cards and other forms of recognition for your contribution to Sue Ryder. We will not send any marketing information to volunteers under the age of 18.
- Your date of birth, so we can ensure you are not under the age of 14 and to help us celebrate special birthdays with you.
- Emergency contact information, so we can contact your parent or guardian in case of an emergency.
- Recruitment information, such as references and other information collected as part of the application process. This is so we can make a decision about your recruitment as a volunteer.
- Confirmation of whether or not you have criminal convictions for specified offences. This is to help us make a decision about your recruitment as a volunteer for the role you have applied for. We have four excluded offences, and there may be other specific requirements for particular roles.
- Performance information, to be used for references to provide to third parties if requested. Performance information can also be used as supplementary evidence if a complaint is received.
- Information about your race or ethnicity, religious beliefs and sexual orientation. This is so we can monitor our diversity and inclusion processes and identify trends.
- Information about your health, including any medical conditions, so we can comply with our health and safety obligations and enable any reasonable adjustments to be made.
Our lawful basis for processing this information is legitimate interest, with the exception of the last two points, where the lawful basis is consent.
If you are aged between 14 and 16, we will need to complete a risk assessment and we’ll require a copy of your council work permit. If required to do so, we will share the risk assessment with your local council. Our lawful basis for processing this information is legitimate interest. This doesn’t apply to volunteers aged 17 and over.
We will collect, store, and use the following categories of personal information about volunteers who work in our hospices and neurological care centres:
- DBS details when you first join as a volunteer, to check that you are not barred from working with vulnerable people. The date of your DBS check is kept on file.
- Training records, for compliance with our training policies and for insurance purposes.
Our lawful basis for processing this information is legitimate interest.
We collect personal information about volunteers through the application and recruitment process. We may sometimes collect additional information from third parties, including former employers, or when we need to carry out a DBS check if your role is a regulated activity i.e. working in one of our hospices or neurological care centres. We will collect additional personal information during your time with us as a volunteer, as part of some of the activities you may undertake in your role.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
5.1. To ensure we can deliver on the volunteering agreement we have with you and give you the best possible volunteering experience.
- 5.2. Where we need to comply with a legal obligation.
- 5.3. Where it is necessary for our ‘legitimate interests’ (or those of a third party), and your interests and fundamental rights do not override those interests. The legitimate interest we rely on is to fulfil the charitable purpose of Sue Ryder.
We may also use your personal information in the following situations, which are likely to be rare:
- 5.4. Where we need to protect your interests (or someone else's interests).
- 5.5. Where it is needed in the public interest or for official purposes.
Although we will ask you whether you want to hear from us by email/text or not hear from us by post/telephone, we will not send you any marketing communications with information about how you can support Sue Ryder whilst you are 18 or under.
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers and volunteers).
We will only use your personal information for the purposes it was collected for initially, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
‘Special categories’ of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- 9.1. In limited circumstances, with your explicit written consent.
- 9.2. Where we need to comply with our legal obligations.
- 9.3. Where it is needed to assess your volunteering capacity on health grounds, subject to appropriate confidentiality safeguards.
Where you have provided us with your particularly sensitive personal information, we will use it in the following ways:
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our employee and volunteer data protection policy.
Less commonly, we may use information relating to criminal convictions where it is necessary to protect your vital interests and you are not capable of giving your consent.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences as part of the recruitment process to assess whether you can work in any of our workplaces that have vulnerable people.
We are allowed to use your personal information in this way to carry out our obligations.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties as set out in this policy (please see the information in section 3, ‘The kind of information we hold about you’).
We require third parties to respect the security of your data and to treat it in accordance with the law.
If we do share your data with third parties, you can expect a similar degree of protection in respect of your personal information.
We have put in place appropriate technical and organisational measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put appropriate security measures in place to prevent your personal information from being accidentally lost, changed, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those volunteers, employees, agents, contractors and other third parties who need it. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting or reporting requirements. More information about how we do this can be found in our data retention policy, which is available on RyderNet (our colleague intranet site) or from your manager.
To decide how long we keep your personal data for, we consider:
- The amount, nature, and sensitivity of the personal data.
- The potential risk of harm from unauthorised use or disclosure of your personal data.
- The purposes for which we process your personal data and whether we can achieve this through other means.
- The applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a volunteer for the charity, we will retain and securely destroy your personal information in accordance with our data retention policy.
16.1. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
16.2. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Company Secretary in writing at:
16.3. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
16.4. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
16.5. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com or call our Volunteer Helpline on 01302 380 067. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Helen Organ, Company Secretary, by email at firstname.lastname@example.org, or write to her at: