Body Donation Programme Privacy Notice

The School of Medicine, Dentistry and Biomedical Sciences and Queen’s University Belfast (“we”, “us” and “our”) are committed to protecting your personal data. The notice is addressed to individuals who have registered an interest “Prospective Donors” and/or consented “Donors” to donate their body after death to Queen’s University Belfast for the purposes of anatomical examination, education or training related to human health, research in connection with disorders or the function of the human body.  This Privacy Notice tells you why we need to collect personal information about you, what we will do with it, and how we will look after it. It also tells you about your legal rights in relation to your Personal  Data. If you have any questions about this privacy notice, please contact us. Contact details are provided below.

WHO WE ARE

• We are Queen’s University Belfast, a university with a reputation for excellence in education and research and a member of the Russell Group. Founded in 1845 as Queen's College Belfast, we became an independent university in 1908. 
• Since its establishment, Queen’s University Belfast has accepted human bodies for use in education and research. Within Northern Ireland, Queen’s University School of Medicine, Dentistry and Biomedical Sciences is the sole recipient of body donations.
• The decision by an individual to donate their body to medical science is important, not only in helping student understanding but also in advancing anatomical knowledge.
• The present Body Donation Programme operates in accordance with the provisions of the Human Tissue Act (2004) and all aspects of the Body Donation Programme and the practice of Anatomy are regulated by the Human Tissue Authority (HTA) http://www.hta.gov.uk/
• The HTA issues licences for the premises in which anatomical work is performed and delegates authority to trained Designated Individuals to ensure that suitable practices are used in undertaking the licensed activity, that the other persons who work under the licence are suitable and that the conditions of the licence are complied with.  The licensed premises can be visited by the HTA at any time in order to inspect the human bodies, anatomical specimens, premises, equipment and records.

HOW YOUR PERSONAL DATA IS COLLECTED

• Queen’s University Belfast takes the protection and confidentiality of personal data very seriously. During the course of our duties and when providing services, we will be required to store and process your personal information. We will only process personal information necessary to fulfil the requirements of the Body Donation Programme. 
• We will keep your information secure, accurate and for no longer than is necessary in accordance with data protection laws; and we will not share your personal information with any third parties, without your prior knowledge or consent, unless required to do so by law.
• We will process this data to administer your donation request as part of our responsibility to provide teaching, learning and research facilities, and as part of our Anatomy Licence from the Human Tissue Authority.
• Prospective Donors: We will record and process your data if you contact us to register an interest in donating your body.  Personal data may include, but is not limited to, your name and contact details in order to provide you with information on the Body Donation Programme at your request.
• Donors: We will record and process relevant personal data provided by you on the Donor Consent Form, and where this is collected in the case of periodic updates to records (by you and/or at our request). Personal data, may include but is not limited to:

• Name(s), address, telephone number(s), email address
• Date of birth
• Name and contact details of Witness/ Next of Kin/Executor/Doctor as appropriate
• Consent declaration and/or withdrawal of consent
• Data relating to arrangements for the release of remains and/or burial or cremation

The University may process some information about you that is considered to be “sensitive”, this is called “special category” personal data.  These types of information have additional protections. Sensitive data may include, but is not limited to: 

• Religion/Faith Group (if applicable)
• Relevant medical history
• Data relating to a decision regarding the acceptance or otherwise of a body following death

You will be informed of any changes to the types of information we collect about you in the Body Donation Information Booklet. 

HOW WE USE YOUR PERSONAL DATA

We use your Personal Data for the purposes of administration of the Body Donation Programme.  This may include but is not limited to the following:

• Providing you with information on the Body Donation Programme at your request.
• Maintaining/updating your record (Body Donation Database and Donor hard copy file).
• Communicating with you, and as appropriate, with your Witness, your Next of Kin, your Doctor, your Executor, the University’s Funeral undertakers and Belfast City Council or other relevant third party (with regard to cremation or burial arrangements).
• Maintaining records that enable traceability to ensure a robust audit trail and in order to comply with Human Tissue Authority requirements.
• Producing statistics for reporting purposes and to comply with Freedom of Information/Data Subject requests.

LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL DATA

We will only use your Personal Data if we have valid reasons for doing so. These reasons are known as our “legal basis for processing”. In certain circumstances we may ask for your consent to process your information, for example, in your provision of consent regarding the donation of your body. At other times we may be required to process your information to enable us to fulfil our responsibilities in administration of the Body Donation Programme. There are circumstances where we have a legitimate interest to process your personal data, for example to provide you with a service which you have requested, for example, in discharging your wishes regarding the retention of your body and arrangements for your remains.   The legal bases for processing your Personal Data are:

• Our obligations to you, owing to your consent to participate in the Body Donation Programme;
• Legal obligations, where we are required to process it under law and to comply with the requirements  of the Human Tissue Authority (HTA);
• Legitimate interests of the data controller, where we are required to process data for business related tasks and;
• To protect your vital interest where there is a threat to life.

When processing your ‘sensitive data’, we will do so in line with Article 9 of the GDPR and will use the appropriate exemption for each instance of sharing and/or processing, which are:

• Processing is necessary to protect the vital interests of the data subject;
• Processing is carried out in the course of the legitimate activities with appropriate safeguards;
• For the purposes of public interest in the area of public health, such as cross-border threats and ensuring high standards of quality and health and safety;
• Processing is necessary for archiving purposes in the public interest, scientific or historical research or statistical purposes.

WHO WE SHARE YOUR DATA WITH

In line with our Data Protection Policy and Procedures we can share your information, including Personal Data for the purposes set out previously (see How We Use Your Personal Data).

DATA PROCESSING OUTSIDE EUROPE

In the unlikely event that we are required to transfer your Personal Data outside of Europe, these services will only be used outside of the EEA when there is an Adequacy Decision in place and/or appropriate safeguards to protect any personal or sensitive data.

HOW LONG YOUR INFORMATION WILL BE KEPT

• We will keep your Personal Data and Sensitive Personal Data in line with our legal and regulatory obligations regarding the retention and destruction of data. All information that is gathered by us as part of our daily operations, will only be retained as long as it still serves the purpose for which it was gathered. We will only keep your information if we need it for one of the reasons described above. We place great importance on the security of the Personal Data that we hold, including the use of physical, technological and organisational measures to ensure your information is protected from unauthorised access and against unlawful processing, accidental loss, alteration, disclosure, destruction and damage.
• Note: Donor bodies are normally held within the School for a period of 1-3 years.  After this time the Next of Kin/Executor will be contacted by the School regarding the release of the remains.

YOUR RIGHTS

The Data Protection Act 2018 provides you with a number of legal rights in relation to your Personal Data, including your right:

• to request access to your Personal Data;
• to request correction of your Personal Data that is wrong or incomplete;
• to request erasure or the restriction of processing of your Personal Data;
• to request the transfer of your Personal Data in a structured; commonly used machine-readable format;
• not to be subject to automated decision making; and
• to withdraw your consent.
  
  If you wish to exercise any of the rights set out above, or require further information about any of the rights, please contact us (details below).
  
  Where we need to collect your Personal Data, whether for the purposes of providing a service you have requested or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the service or perform the contract. We may, therefore, have to cancel the contract or the service we provide to you but we will notify you if this is the case at the time.
  
  There may also be times where we cannot stop using your Personal Data when you ask us to, but we will tell you about this if you make a request.

 CONTACTING US   

If you have any questions or comments about this privacy notice, the University’s Data Protection Officer can be contacted at:

Data Protection Officer

Information Compliance Unit
Lanyon South
Queen’s University Belfast
University Road
BT7 1NN
info.compliance@qub.ac.uk        

COMPLAINTS

You have the right to complain about how we treat your Personal Data and Sensitive Personal Data to the Information Commissioner’s Office (ICO). The ICO can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

CHANGES TO THIS NOTICE

We may update this Privacy Notice from time to time. We will notify you of the changes where we are required by law to do so.