St John Guernsey Privacy Notice

At St John we take your privacy very seriously and are committed to protecting the security of your personal information.

This Policy explains how we, The Commandery of the Bailiwick of Guernsey of the Most Venerable Order of the Hospital of St John of Jerusalem (“we” or “The Commandery”), and our affiliated companies, St John Guernsey (“SJG”), St John Commercial Services (trading as St John Training Services and St John Healthcare and Equipment Centre), (“SJCS”), St John Property (“SJP”) may collect and use the information you give us, the conditions under which we may disclose it to others and how we keep it secure. It should be noted that although the St John Ambulance & Rescue Service (trading as St John Emergency Ambulance Service) (“SJARS” or “SJEAS” or “EAS”) sit under The Commandery as one of their affiliated companies, they have their own privacy policy and this should be referred to for privacy matters concerning them.

We may change this Policy from time to time so please check this page occasionally to ensure
that you’re happy with any changes. By using our websites, you agree to be bound by this Policy.

A Data Protection Officer has been appointed, who can help you with any queries about the information in this privacy policy with respect to The Commandery, St John Guernsey or St John Commercial Services. A separate Data Protection Officer has been appointed to deal with privacy information on behalf of the St John Ambulance & Rescue Service and it’s trading entity the St John Emergency Ambulance Service. Contact details for each Data Protection Officer can be found in section 12 of this document.

This Policy contains the following sections:

1. WHO WE ARE

The Commandery of St John is a registered charity in the Bailiwick of Guernsey (charity number CH469). We are also a company limited by guarantee (company number 55251) and have wholly-owned trading subsidiaries, St John Guernsey, a registered charity in the Bailiwick of Guernsey (charity number CH121). St John Guernsey is also a company limited by guarantee (company number 55259). St John Commercial Services (company number 46097), which trades as St John Training Services and St John Healthcare and Equipment Centre. St John Property, which is a company limited by guarantee (company number 64391). St John Ambulance & Rescue Service, a registered charity in the Bailiwick of Guernsey (Charity number CH227) and whose company number is 35886 trades as the St John Emergency Ambulance Service. All companies act as data controllers. St John Guernsey processes data on behalf of The Commandery, St John Commercial Services and for St John Emergency Ambulance Service.

St John Emergency Ambulance Service processes data on behalf of St John Ambulance & Rescue Service and for St John Guernsey.

The information in this Privacy Policy relates to personal information which is obtained by the above entities and for which St John is the Data Controller under data protection legislation as set out in “The Data Protection (Bailiwick of Guernsey) Law, 2017”.

2. WHAT TYPE OF PERSONAL INFORMATION IS COLLECTED FROM YOU

The personal information we collect from you is limited to what is necessary to enable us to carry out the purposes for which it is collected. The type of personal information we collect depends on the context of your interactions with St John and the choices you make, including your privacy settings.

The data we may collect, store and use can include the following:

  • If one of our First Aiders, Community First Responders or ambulance crew provided by SJEAS attends to you, we will collect information about you to help us identify and treat you. This will be recorded on a Patient Report Form or other form of patient clinical record along with details of your symptoms and condition and any treatment we give you.
  • Name and contact information. We may collect your first and last name, title, job title and company name, email address, postal address, phone number and other similar contact data.
  • Passwords, password hints and similar security information for authentication and account access.
  • Payment information. We collect data necessary to process your payment if you purchase one of our goods or services or make a donation, such as your payment instrument number (such as a credit card number or bank account number) and the security code associated with your payment instrument.
  • Any personal information which you choose to provide us with in correspondence with you.
  • Photographs, videography and CCTV footage.
  • Your I.P. address (or Internet Protocol Address). This is a unique address that computing devices such as personal computers, tablets, and smartphones use to identify itself. An I.P. address is analogous to a street address or telephone number and could therefore be used to identify you.
  • We may collect other online identifiers including cookies information (for more information please see section 11), the internet browser and devices you are using and the pages you visited on our website and how long you visited us for

You have choices about some of the personal information we collect. When you are asked to provide personal information, you may decline. Please note that if you choose not to provide personal information that is necessary to enable us to carry out your request- for instance, to make a donation, for information or to purchase one of our products or services- we may not be able to fulfil that request.

We may provide links via St John’s websites to other websites or you might independently visit the website of a third party who provides services on our behalf. The privacy practices of these third-party websites are outside our control and in these cases, you should check the privacy notices of any third-party websites before disclosing any personal information.

In some cases, you might make a donation to us via a third-party payment processor, in which case you should check the privacy policy of that third party as the data controller of your personal information.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

There are various ways you might share your personal information with St John, depending on how you interact with us. At present we offer the following channels of communication (though not all may be available to you and will depend on the reason for your contact with us):

  • Patient contact
  • Websites- online forms
  • Paper forms
  • E-mail
  • Telephone
  • Text
  • Face to face

For instance, if you are attended to by any of our First Aiders, Community First Responders or professional ambulance crews, we will obtain information about you which will help us identify you and treat you. We will record details of this contact on a Patient Report Form or other patient clinical record along with details of your symptoms and condition.

You might provide personal information when making a donation to us through our websites, by text, by telephone or by completing a direct debit form which you send to us by post.

You might send us an e-mail requesting support with a product or service, and personal information might be collected by us to enable us to deal with your enquiry.

When you contact us via our contact numbers, such as for customer support or to place an order, telephone conversations with our representatives may be monitored and recorded.

Some of our premises and vehicles are monitored by CCTV and footage may be captured for security and safety purposes.

We may also obtain personal information from third parties. We protect data obtained from third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:

  • First Aiders, medical persons or other such people who may provide initial patient
    treatment or care prior to the arrival of St John personnel or ambulance staff who will
    continue your treatment or care.
  • Someone who may have nominated you for an award.
  • Someone who may post a photograph or information relating to you to our social media
    platforms.
  • Partners with which we offer co-branded services or engage in joint marketing
    activities.
  • Publicly-available information such as newspaper or online media items; public posts on LinkedIn or social media; open government databases such as the Guernsey Registry; databases of grant-funding opportunities and other data in the public domain.

4. HOW WE USE YOUR PERSONAL INFORMATION

There are various ways in which we may use or process your personal information. We list these below and the legal basis we rely on in each case.

Consent

Where you have provided your consent, we may use and process your personal information to:

  • Provide you with medical diagnosis and treatment.
  • Contact you from time to time about our campaigns, activities, ways you can support St John (such as volunteering opportunities and fundraising appeals), events, products, services, youth programmes or information and know-how which we reasonably think may be of interest to you. Please be assured that we will not spam you and such communications will be aligned to the consent you have given us.
  • Promote St John campaigns, activities, ways to support St John (such as volunteering opportunities and fundraising appeals), events, products, services, youth programmes or information and know-how, using a review you have written, a case study about you, photograph or video footage featuring you (or a child aged under 13). These may be featured in social media, printed and digital media, television and radio communications.
  • Set up and administer a membership for our Cadets or Badgers programmes in relation to a person aged under 18.

You can withdraw your consent at any time by contacting us using the details provided within section 12 below using guidelines as set out in section 5 (‘Your Right To Withdraw Consent To Processing Of Personal Information’).

Contractual performance

We may use and process your personal information to perform a contract with you (or a contract made with someone else which requires us to provide goods or services to you, such as a training course) and to fulfil and complete your ordersfor goods, services, venue hire, and other transactions entered into with us.

Legitimate interests

We may use and process your personal information where it is necessary for us to carry out activities which are in our legitimate interests as a charity. The main legitimate interests we rely on are:

(i) to fulfil the charitable purposes of St John by fundraising through donations, events, sales of supplies and training courses and by sustaining and raising the profile of our organization through careful marketing and other activities.

(ii) to operate lawfully and effectively and to administer all aspects of our business as a charity.

(iii) to offer and provide First Aid and medical support including treatment and diagnosis either as part of our business of providing such support at various events that we are requested to attend or as a result of one of our Community First Responders responding to an emergency.

Processing donations and legacies

We will process your personal information to fulfill your request to make either a one-off or regular donation to us and to carry out reasonable administration of your donation, which could include thanking you and confirming your direct debit details with you. We will also process personal information where reasonably required to administer a legacy that has been left to St John.

Processing membership subscriptions

We will process your personal information to fulfill your request to pay for a membership of our Cadets or Badgers programmes relating to a child under 18 and to carry out reasonable administration of their  membership, including communicating with you about activities, camps and training.

Supporting customers and supporters with requests for information

We will process your information to fulfill your request for information about becoming a supporter (for example, a volunteer or donor), campaigns, activities, events, products, services, youth programmes or information and know-how.

Supporting customers with orders of first aid supplies, booking training courses and other
enquiries

We will process your personal information to respond to any correspondence you send us and fulfill the requests you make to us, both before and after purchase. We will also process your personal information to carry out reasonable administration of your order or booking.

Processing necessary for us to  understand and respond to customers’ and supporters’ needs

We may process personal information to analyse, evaluate and improve your customer/supporter experience of our services and web-sites and to improve our products and services (we will generally use data amalgamated from many people so that it doesn’t identify you personally).

You may choose to give us feedback on any of your experiences with St John and your feedback together with any personal information you provide will enable us to analyse, evaluate and improve your customer/supporter experience and to respond to you as appropriate.

We may undertake market analysis and research (including contacting you with customer/supporter surveys) so that we can better understand you as a customer/supporter and provide tailored information, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or in certain cases, if we have a legitimate interest in doing so.

Processing necessary for us to promote our business, products and services and measure the
reach and effectiveness of our campaigns

We may send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry, closed your browser with items in your shopping basket or requested other information of interest in a business context. We will only contact you with information about our own products, services and any other information we believe may be of interest to you (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time. Please see section 1 for information on how to do this (‘Your Rights in Connection with Personal Information’).

We may also contact you from time to time with marketing information (unless you object) if you are acting on behalf of a business or where we have obtained your business contact details public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing.

We may contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us.

We may process your personal information to identify and record when you have received, opened or engaged with our website or electronic communications. Please see Section 11 (‘Use of Cookies’) for more information.

We may process your personal information to administer competitions, promotions, lotteries or raffles that you enter with us from time to time and to distribute prizes.

We may use photographs or video footage which feature you, but which do not identify you by name, to promote St John.

Processing necessary for us to operate the administrative and technical aspects of our business
efficiently and effectively

We may have to share your personal information with third parties, as described in section 6
(‘Data Sharing’) below.

We may have to verify the accuracy of information that we hold about you and create a better understanding of you as a customer/supporter.

We may process your personal information for network and information security purposes, for example, for us to take steps to protect your information against loss, damage, theft or unauthorised access.

We may process your personal information to comply with a request from you in connection with the exercise of your rights. For example, where you have asked us not to contact you for marketing purposes.

We may process your personal information to inform you of updates to our terms and conditions and policies.

Processing necessary to protect our premises, property and people

We may process personal information for crime prevention and detection purposes and to keep our people safe. For example, some of our premises have CCTV cameras and CCTV is also installed on certain vehicles including some ambulances.

Legal obligation

We may process your personal information to comply with our legal requirements (for example, to contact you if there is an urgent safety or product recall notice and we need to tell you about it).

Other grounds for processing
Vital interest

Sometimes we will need to process your personal information if, for example, there is an urgent safety or product recall notice and we or the manufacturer of the product needs to tell you about it, or for life saving medical diagnosis and treatment purposes.

Change of purpose

We will only use your personal information for the purposes for which we collected it, 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 we will 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 accordance with this Policy, where this is required or permitted by law.

5. YOUR RIGHT TO WITHDRAW CONSENT TO PROCESSING OF PERSONAL INFORMATION

If you have consented to the collection, processing and transfer of your personal information for a specific purpose(s), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the relevant organisations Data Protection Officer as set out in section 12.

As quickly as possible and in any event within 30 days of receiving 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).

The withdrawal of your consent will not affect the lawfulness of our processing based on your consent before you withdrew your consent.

6. DATA SHARING

We will not sell or rent your information to third parties.

We may have to share your data with third parties, as described below. If we do, you can expect a similar degree of protection in respect of your personal information to that provided by us. We require third parties to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal details and health information may be given to other people who need to know relevant information about your health. For example, an individual or organisation involved with the continuation of care as part of your treatment such as ambulance personnel, another healthcare professional such as a nurse or doctor, or a carer, a home help, or a social worker.

We may pass your personal information to our third-party service providers, including contractors and designated agents, and other associated organisations for the purposes of completing tasks on our behalf (for example to process donations and payments, to fundraise, send you St John communications, to supply you with goods and services, to resolve product queries or issues and to assist us with marketing analysis). However, when we use third party service providers, we disclose only the personal information that is reasonably necessary to deliver the service.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a legal duty to disclose or share your personal data in order to comply with or enforce any legal obligation or rights or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will aim to protect your privacy.

We may share your personal information with our parent charity, The Priory Of England And The Islands Of The Most Venerable Order Of The Hospital Of St. John Of Jerusalem whose registered office is St John’s Gate, St John’s Lane, London EC1M 4DA (charity number 1077265) as well as St John Ambulance in the UK, a company limited by guarantee (company number 3866129) whose registered office is at 27 St John’s Lane, London, EC1M 4BU (registered UK charity number 1077265-1) where reasonably necessary.

Data transfers to Non-Equivalent Countries

There may be some instances where your personal information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

St John operates in the Bailiwick of Jersey and in the Isle of Man, each of which are outside of the EU. Personal information provided to St John may be given to our local offices in those territories and stored in data retrieval systems in the territory, but only when you request information or services relating to our operation in those territories. There is an adequacy decision by the European Commission for these countries, which means that they are deemed to provide an adequate level of protection for your personal information.

7. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

We will only retain your personal information for as long as necessary for the purposes we collected it for, as set out in our Data Retention Schedule, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and 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.

For further information about the retention period in a particular case, please contact our Data Protection Officer as per the appropriate contact details set out in section 12.

8. HOW WE KEEP YOUR DATA SAFE

St John would like to reassure you that we use appropriate security measures to protect your personal information against unauthorised or unlawful processing and against accidental loss, destruction or damage. These measures may include, but are not limited to, a range of organisational safeguards such as staff training, and duties of confidentiality and the following technical safeguards listed below. We have put in place 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.

Encryption

Encryption is the process of converting data to an unrecognizable or “encrypted” form. This means that only the sender and intended recipient can view it in a meaningful way. If the encrypted data is stolen, it should not be possible to change it back to readable data.

Pseudonymisation

Pseudonymisation changes data that can be used to identify a person into data that can’t be used to identify a person. This is done by replacing the data that can be used to identify someone with other data, for example, changing someone’s date of birth to 01/01/1700.

Certification from third parties

We engage security experts to test or confirm that our systems meet relevant security standards.

Secure log on/authentication

As well as requiring staff to enter usernames and passwords, our systems also check that a particular computer or program is authorised to access and manipulate data before allowing it to do so.

Access controls and role based access controls

Staff are prevented from accessing our systems unless they enter their user name and password. In addition, we restrict whose personal data each user can access depending on their role at St John and individual data files are password protected. We also limit access to your personal information to those agents, contractors and other third parties who have a business need to know. Everyone with access to your personal information are subject to a duty of confidentiality and will only process your personal information on our instructions.

Data back-up and restoration

We regularly back-up our systems and data which means that we can restore or recover the system and data from a back-up file. We regularly review our procedures both internally and with our external I.T. support contractors and suppliers. As such we may update oursecurity measures and as such this policy
as well to inform you of these changes and the steps we take to keep your data secure.

9. CHANGES TO YOUR PERSONAL INFORMATION

Please let us know if your contact information changes so that we can ensure that our records are accurate and up to date. You can request that we change your contact details by contacting our Data Protection Officer by using the contact details in section 12

10. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

By law you have the right to:

  • Request access to your personal information. 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 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 does not apply to medical records). This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing 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 process 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 send a written request to our Data Protection Officer using the contact details listed in section 12.

We will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request (including any identification documents requested).

11. USE OF COOKIES

To make full use of the online shopping and personalised features on the St John website, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.

Our cookies don’t store sensitive information such as your name, address or payment details: they simply hold the ‘key’ that, once you’re signed in, is associated with this information.

You can restrict, block or delete cookies from St John at any time through your browser. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

More information about cookies and how to control how they are set can be found at www.allaboutcookies.org

12. ORGANISATION CONTACT

If your question concerns the activity of The Commandery, St John Guernsey, St John Commercial Services (including either of their respective trading entities St John Training Services or St John Healthcare Equipment Centre) or St John Property LBG or if you have any questions about this Policy or how we handle your personal information, please contact our Data Protection Officer using the contact details listed below.

If your query is related to the St John Ambulance and Rescue Service or its trading entity the St John Emergency Ambulance Service then they have appointed their own Data Protection officer whose details are also listed in the table below.

If you are unsure as to which entity to contact then please call 727129 during normal office hours to ensure your enquiry is routed through to the correct Data Protection Officer.

  • The Commandery
  • St John Guernsey
  • St John Commercial Services
    • St John Training Services
    • St John Healthcare and Equipment Centre

By Post:

Data Protection Officer St John Guernsey
St John Headquarters,
The Rohais,
St Peter Port,
Guernsey, GY1 1YN

By Email:

DataProtectionOfficer@stjohn.gg

By Telephone:

+44 (0) 1481 727129 (normal office hours
only)

  • St John Ambulance and Rescue Service
    • St John Emergency Ambulance Service

By Post:

Ambulance Data Protection Officer
St John Emergency Ambulance Service
Rohais
St Peter Port
Guernsey, GY1 1YN

By Email:

AmbulanceDPO@stjohn.gg

By Telephone:

+44 (0) 1481 723866

13. RIGHT TO MAKE A COMPLAINT

You have the right to make a complaint at any time to the Office of the Data Protection Commissioner, the Guernsey supervisory authority for data protection issues. The contact details for the Office of the Data Protection Commissioner, the data protection regulator in Guernsey, are below:

By Post:

Office of the Data Protection Commissioner
St Martin’s House
Le Bordage
St Peter Port
Guernsey
GY1 1BR

By Telephone:

+44 (0)1481 742074

By Email:

enquiries@odpc.gg