End of Life Doula UK is committed to protecting your privacy. This document explains how we collect and use the personal information you provide to us whether online or via phone, mobile, e-mail, letter or other correspondence and documents.
- This document applies to all personal data processed by the End of Life Doula UK
- The Membership Secretary, Chair and Secretary of End of Life Doula UK shall take responsibility for End of Life Doula UK’s ongoing compliance with this policy
- Data subject access requests made to End of Life Doula UK shall be dealt with in a timely manner
- This policy shall be reviewed at least annually
Data protection principles
End of Life Doula UK is committed to processing data in accordance with its responsibilities under the General Data Protection Regulations (GDPR). Article 5 of the GDPR requires that personal data shall be
- processed lawfully, fairly and in a transparent manner in relation to individuals
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
End of Life Doula UK shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- End of Life Doula UK shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
Archiving / removal
- End of Life Doula UK will ensure that personal data is kept for no longer than necessary and shall put in place an archiving processes for each area in which personal data is processed and review this process annually.
- The archiving process shall consider what data should/must be retained, for how long, and why.
End of Life Doula UK shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- All data processed by End of Life Doula UK should be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in End of Life Doula UK’s systems
Personal data that we process
The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.
|Purpose||Data (key elements)||Basis|
|Enquiring about our association and its work||Name, email, email messages, telephone number, contact forms from our website and replies to contact forms by email||Legitimate interests - it is necessary for us to read and store your message so that we can respond in the way that you would expect.|
|Working with and being supported by an End of Life Doula||Name, email, email messages, address, telephone number, mentoring records and records of support received||Legitimate interests - It is necessary for us to read and store this information, so we can apply safeguarding principles of the support received and to maintain confidential records for reference by those at End of Life Doula UK involved in support and care|
|Subscribing to email updates and newsletters, about our work||Name, email||Consent - you have given your active consent.|
|Donating||Name, email, address, payment information||Legitimate interests - this information is necessary for us to fulfil your intention of donating money and your expectation of receiving a confirmation message.|
|Signing up and being accepted as a member||Name, email, email messages, address, telephone number, membership records||Contract - by paying your membership fees you have entered a relationship with us as set out in our membership terms and conditions.|
|Monitoring our policies on equality of opportunity, diversity and inclusion||Anonymised data for the purposes of monitoring||Legitimate interests to achieve our objective of inclusivity|
|Booking on our seminars, workshops and training||Name, email, address, payment information||Contract – by making a booking and paying your fees you have entered a relationship with us as set out in our booking terms and conditions.
|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 booking before you have fully completed the process.|
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 in the previous table.
When we share your data
We will keep any personal information that you give use safely and securely, in accordance with our processes, the Data Protection Act and General Data Protection Regulations.
To work effectively on your behalf, any appropriate End of Life Doula member, may access your information.
We may share your personal data with LWDW Training Ltd as part of the nature of our relationship with you.
Wherever possible, we will let you know if we need to share your information with another individual, agency or organisation.
There may be times when we are obliged to disclose information to other authorities such as the police, e.g. if a vulnerable person is at risk.
When End of Life Doula UK provides you with a service, your records are maintained and held within the organisation and the End of Life Doula(s) who are supporting you and his/her mentor. To give you the best possible assistance, an End of Life Doula UK may need to discuss your case with another colleague.
Where a client gives specific permission for other people to be involved (e.g. friend, partner, family member, advocate) we will share information with those parties. We will note that you have given consent in our records and we may, in some cases, ask you to sign a consent form for us to share this information.
We keep records of all clients receiving a service from End of Life Doula UK. Case notes will be kept following client contact. The notes are kept to provide a professional service, maintain continuity of service and in order to reference what has happened or been discussed.
How long we keep your data
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.
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 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 https://ico.org.uk/
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 several things, e. g remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, End of Life Doula UK will assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website). https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/personal-data-breaches/
We may modify this document from time to time and will publish the most current version on our website.