Privacy Notice Concerning the Processing of Personal Data

Introduction

This is the Cleveland Clinic Philanthropy (UK) Ltd Privacy Notice.  

Cleveland Clinic Philanthropy (UK) Ltd (“Cleveland Clinic Philanthropy” or “we”) is a charity with the mission of advancement of health, medical education, and research.  

It describes the types of personal data that we collect, how we collect and process that information, who we share such information with, and your options in connection with your information. For details about how we collect, process, and share personal information related to our website, please visit Cleveland Clinic Philanthropy’s Website Privacy Notice. 

1. Important information and who we are

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Cleveland Clinic Philanthropy collects and processes your personal data. 

We do not knowingly collect data relating to children who are under 13 years of age.  

We may receive your personal data if you consent to an organisation providing it to us or you otherwise share your information with us directly.  

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  

This Privacy Notice supplements the other notices and is not intended to override them. 

Controller 

Cleveland Clinic Philanthropy is the controller and responsible for your personal data (also referred to as “we”, “us” or “our” in this Privacy Notice). If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below. 

Contact Details

Please direct any questions, comments, or complaints regarding this Privacy Notice to us using the contact information below. 

Full name of legal entity: Cleveland Clinic Philanthropy (UK) Ltd
Email address: ccp-privacy@ccf.org 
Postal address: 40 Grosvenor Place London, SW1X 7AW 

Further guidance on your rights is available from the Information Commissioner’s Office (https://.ico.org.uk/). You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office, at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.  

The Cleveland Clinic Philanthropy (UK) Ltd registration number is ZB318964. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

This Privacy Notice does not override any applicable national data privacy laws and regulations applicable to Cleveland Clinic Philanthropy. 

Changes to the Privacy Notice 

We reserve the right to update this Privacy Notice because of changes in the law or our business operations. We will post any changes to this Privacy Notice on our website (the “Site”) and, where appropriate, will notify you of changes by email. Please check the Site periodically for changes to the Privacy Notice. 

Changes to Your Information 

We can most effectively communicate with you when we have information that is accurate and current. Please contact us to update your contact information as it changes. 

2. The data we collect about you

We may collect or receive the following categories of personal data about individuals. 

• Identity Data: first name, last name, username or similar identifier, organisation, title, phone number, email address, date of birth, and medical record number*. 
• Health Data: Any limited health-related information that you share with us. 
• Economic Data: Publicly available information about your financial resources that may affect your ability or interest in making donations. 
• Marketing Data: Data about newsletter requests and individual participation in conferences and seminars and attending webinars. 

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose that are anonymous. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. 

*Cleveland Clinic Philanthropy does not have access to your medical records and will never use a medical record number to access medical information. Medical record number will be used for attribution of communication preferences to the correct individual.

3. How is your personal data collected?

We use different methods to collect data from and about you including through: 

Direct interactions. You may give us your Identity Data by filling in forms or by corresponding with us by phone, email or otherwise.  

Cleveland Clinic London Ltd: Cleveland Clinic London Ltd, a separate entity from Cleveland Clinic Philanthropy, shares Identity Data of patients for Cleveland Clinic Philanthropy to possibly (a) ask whether an individual would like more information about certain philanthropic opportunities, and (b) in some instances review publicly available information to assess interest and capacity to make charitable donations.  

Organisations that collect publicly available information. Cleveland Clinic Philanthropy may receive personal data from organisations that compile publicly available information. 

Publicly available sources. We may receive Identity Data or Economic Data from publicly availably sources.  

4. How we use your personal data

Below we describe the purposes for us using personal data and our lawful bases for using such data. 

• To communicate with you about charitable giving opportunities that may be relevant to you we use Identity Data and Registration Data. We may use health information to identify charitable opportunities particularly relevant to you. 
• To assess individuals’ interest and capacity to make a charitable donation we receive and assess Economic Data. It is in our legitimate interest to understand individuals’ interest and capacity to make a charitable donation. 
• To engage with our vendors we use Identity Data. It is in our legitimate interest to be able to communicate and otherwise conduct business with our vendors.  

Marketing Choices 

You have control regarding our use of personal data for direct marketing. You can elect not to receive particular marketing communications at any time by clicking on the unsubscribe link of those marketing emails. You may also contact us at ccp-privacy@ccf.org with the information set forth below specifying what marketing communications you no longer wish to receive. 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in in Section 4 above. 

• Affiliates: Cleveland Clinic Philanthropy (UK) Ltd is a subsidiary of The Cleveland Clinic Foundation (“Cleveland Clinic Foundation”), which has other subsidiaries throughout the world. We may share personal data with Cleveland Clinic Foundation or any one or more of its direct or indirect affiliates for the purposes set forth in this Privacy Notice. In certain circumstances, we may act as joint controllers with The Cleveland Clinic Foundation, including to respond to some requests by data subjects to exercise their rights under data protection laws, as set out in Section 10 below.
• Service Providers: We engage third parties to perform tasks on our behalf that include the use and processing of personal data, including information technology providers, contractors performing work on our behalf, marketing consultants and providers, credit card processors, lawyers, consultants, accountants, and financial institutions that process or manage payments. 
• Recipients Through Legal Proceedings: We will share personal data to the extent required by any applicable court order, or legal process or to comply with a request from a regulator or other government entity and as otherwise legally required. We will also share your applicable personal data with recipients as part of, and to the extent consistent with, any proceeding in which we need to engage in or assert and defend our legal rights. 

6. International transfers: Intra-Group and Third-Party Vendors

a) Intra-Group

We transfer personal data to Cleveland Clinic Foundation located in the US. Cleveland Clinic Foundation acts as a joint controller in relation to certain of our functions. The international transfer of personal data from us to Cleveland Clinic Foundation is governed by approved Standard Contractual Clauses for controllers, taking into account appropriate technical and security safeguards. You may request a copy of the relevant sections of these agreements by contacting us in one of the ways set out in Section 10. Cleveland Clinic London provides certain administrative and information technology support for the operations of Cleveland Clinic Philanthropy. 

b) Third Party Suppliers

If and when transferring your personal data outside the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented.  Where a third-party supplier is based outside of the UK and EEA, we will usually achieve this by using one of the following safeguards: 

• the transfer is to a non-EEA country outside the UK that has been the subject of an adequacy decision;  

• the transfer is governed by the ICO or EU Commission-approved Standard Contractual Clauses; or 
• the transfer is otherwise in accordance with applicable data protection laws.  

You may request further information, including a copy of the relevant sections of the relevant transfer documentation, by contacting us in one of the ways set out in Section 10. 

7. Data security

We have put in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, 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 those purposes through other means, and the applicable legal requirements. 

In some circumstances you can ask us to delete your data: see your legal rights below for further information. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you. 

9. Automated decision making and automated profiling

Your personal data will not be used for automated decision-making or automated profiling. Although not automated, we do maintain profiles of individuals who have expressed an interest in making a donation or who may reasonably be interested in making such a donation. 

10. 10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

• Access: Subject to certain exceptions, you have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Correction: You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Deletion: You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Objection: You have the right to object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Restriction: You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
• Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• Withdraw Consent: You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain communications to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.