3. Disclosure

HCF will not share data with any other agencies or companies, other than legitimate circumstances where the law allows HCF to disclose data (including sensitive data) without the data subject’s consent.   

These are:

1. Carrying out a legal duty or as authorised by the Secretary of State 
2. Protecting vital interests of an Individual User or other person
3. The Individual has already made the information public
4. Conducting any legal proceedings, obtaining legal advice or defending any legal rights  
5. Monitoring for equal opportunities purposes – i.e. race, disability or religion
6. Providing a confidential service where the Individual’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill individual to provide consent signatures.

HCF will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 2018, specifically:

1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met, 
2. Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
3. Shall be adequate, relevant and not excessive in relation to those purpose(s) 
4. Shall be accurate and, where necessary, kept up to date,
5. Shall not be kept for longer than is necessary 
6. Shall be processed in accordance with the rights of data subjects under the Act,
7. Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
8. Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.

HCF will, through appropriate management and strict application of criteria and controls: 

• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: 

o The right to be informed that processing is being undertaken,

o The right of access to one’s personal information

o The right to prevent processing in certain circumstances and 

o The right to correct, rectify, block or erase information which is regarded as wrong information)

• Take appropriate technical and organisational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information

4. Data Collection

Informed consent is when

• An Individual clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data 
• And then gives their consent.

HCF will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, HCF will ensure that the Individual:

1. Clearly understands why the information is needed 
2. Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
3. As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
4. Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
5. Has received sufficient information on why their data is needed and how it will be used

5. Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is HCF’s responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

6. Data Access & Accuracy

All Individuals have the right to access the information HCF holds about them. HCF will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.

In addition, HCF will ensure that:

• It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection, although this is voluntary.