DATA POLICY

This policy sets out how Auditory Verbal UK (AVUK) uses and protects your personal information, including data from your use of our website.

AVUK is the Data Controller for personal data about supporters, event attendees, training participants, service users and newsletter subscribers. For the purpose of this document we will use the group term ‘supporters’ to describe any one of these groups. Our ICO registration number is Z8932751.

We do not trade personal data for commercial purposes and will only disclose it if required by law, if it is necessary to arrange your event attendance or deliver services to you, or if it is with your consent.

This policy was implemented in May 2018 to show that we are adhering to the new General Data Protection Regulation (GDPR), which came into force on 25 May 2018. The policy is updated at regular intervals.

Use the Contact Us form for any data protection queries.

SUBSCRIBERS

If you subscribe to our mailing list, you will be automatically subscribed to receive our quarterly newsletter.  You will also have the opportunity to opt in to receive occasional emails about specific areas of interest, for example fundraising events, training courses or AVUK’s research projects.  You will only receive information that you have opted in to receive and you can change your preferences at any time.

We currently use Campaign Monitor to manage our email marketing who secure, and keep private all data.

We transfer all subscribers’ details to our own database. We are in the process of transferring all subscribers’ details from the eTapestry database to a custom-built version of SalesForce. Our database is kept updated with your marketing preferences.

You can change your email marketing preferences at any time, by clicking ‘unsubscribe’ or ‘manage preferences’ on any of our emails or by contacting: [email protected]

SERVICE USERS

When families contact us to find out more about our programme, whether that is in person, by phone, email or our website, we will take some contact information in order to process their enquiry.  We will also record some basic information about their child’s medical and hearing history so that we can advise whether or not an initial appointment would be appropriate.

At the initial appointment families may be asked to provide further information about their child’s hearing history along with contact details for their local team, ie speech and language therapist, teacher of the deaf and audiologist.

We will keep all of this information in a clinical database built securely and with restricted access in the SalesForce platform.

If the family decides not to join our programme their child’s clinical file will be destroyed 12 months’ after their last contact with us.  At the same time the information on the clinical database will be anonymised and only used for statistical purposes.

When families join our programme we will hold information about them and their child on our databases and on the child’s clinical file.  We will only share information with third parties where we have the parents’/legal guardian’s consent to do so, unless there is a safeguarding issue, in which case our safeguarding policy will take precedence.

Any financial information we collect as part of providing our service to families, for example bank details, payment history, bursary applications and awards, are kept separately from the clinical data, on our accounts systems.

Parents on our programme are automatically subscribed to receive our newsletter and will have the opportunity to opt in to additional mailing lists and our closed Facebook group for families.  Parents can unsubscribe or change their preferences at any time.

TRAINING COURSES

Generally

AVUK runs a variety of different training courses for professionals, from short 90-minute online webinars to inset training and longer, distance-learning programmes.  We maintain an electronic record of participants who have enrolled on our training courses (their name, contact phone/email address, geographic location) and a register of attendees for individual courses in order process their enrolments and deliver their training.  The minimum length of time that we retain these records is three years; for courses that carry CPD we may retain these records for longer.  Any financial information we collect as part of providing our training, for example fees charged, payment history, bursary applications and awards, are kept separately on our accounts systems and are retained in accordance with financial regulations.

AVUK’s Foundation & Advanced training courses

We keep an electronic register of all enquiries specifically relating to our foundation and advanced training courses (name, contact phone/email address, geographic location).  Entries on this training register will be anonymised after 7 years.  We will continue to use anonymised data for statistical purposes, for example how the professional heard about us, geographic spread, conversion of enquiries to enrolments, etc.

For our Foundation and Advanced courses, where participants are routinely required to submit both written and video assignments for assessment, we will use AVUK’s training site in SharePoint to create an individual folder for each course participant.  Access to each of these secure electronic folders will be password protected and restricted to the course participant and AVUK's training team (course tutors and specific members of staff responsible for IT/Operational support).  These folders will be used for the transfer of assignments, video clips and marked assessments back and forth between the course participant and their course tutor except where a participant’s employer has its own system for secure data transfer that it requires us to use.

As part of their training, course participants are required to submit a variety of short 5-minute clips for discussion with their cohort during webinars, and longer full-session videos of them delivering therapy for formal assessment.  The purpose of this is to enable course tutors to provide feedback and help participants reflect on their practice and embed their training into their therapy.  Alongside each video, the course participant may need to share limited personal information, eg first names of child and adults participating in the session, age of child, hearing history of child (eg level of hearing loss, type of hearing technology etc) and any other medical conditions that may have an effect on the child’s learning and/or behaviour, eg SI indicators, Oro-Motor difficulties, etc.  Foundation and Advanced course participants are notified of these requirements prior to being enrolled on their course and are responsible for obtaining the necessary consents from their employer and service users.

Ahead of each webinar a member of AVUK's training team uploads the video clips from that cohort's individual SharePoint folders into a PowerPoint presentation so that they can be played to the group during the webinar.  The webinars take place using Skype for Business, Teams or Zoom.  Access to the webinars is via a secure link, by invitation only and is restricted to that cohort's participants, the course tutor and, if required, a member of the IT/Operational support.  Participants are held in a virtual lobby prior to the webinar starting and are required to be “on camera” during all webinars so we can see as well as hear everyone.  The webinars are not recorded.  At the end of each webinar the PowerPoint presentation, including the participants' video clips, is deleted and participants are advised to delete their clips from their SharePoint folder. 

The full session videos that course participants are required to submit for formal assessment are not played in webinars.  Once they have been downloaded from SharePoint to AVUK’s server they are watched by the course tutor and moderator in order to complete the assessment and are then deleted.  Once marked, the assessment is returned to the participant via SharePoint and the participant is advised to remove the video from their SharePoint folder.

We do not keep any participants' videos on our own servers or for longer than necessary.

Copies of the marked assessment forms will be retained in secure folders on AVUK’s server and will be destroyed no later than 5 years after the training course has been completed.  An electronic log of course participants and results is maintained.  Our course accreditation requires us to share this information with the AG Bell Academy.  In order to manage participants’ training and keep them informed of appropriate training in the future, information on this log will be updated but will not be deleted unless we receive a request for erasure.

EVENTS

Each year AVUK organises a variety of fundraising, awareness raising, training and outreach events.  When you accept an invitation or register to attend an event we will need your name and email address.  In some cases, particularly for training and outreach events we may need additional information, for example your job role and payment details.  We will use this information solely for the purpose of administering the event, this may involve sharing your details with third parties who are involved in the organisation or hosting of events in conjunction with or on AVUK’s behalf.

For some events we use Eventbrite to manage event registrations.  They may contact you about other events that may be of interest to you, but only if you opt in when you register with them.  Read Eventbrite's privacy policy.

For most events we will not keep your information for more than 12 months but for some training we will need to keep your information for up to five years and we are required to keep details of financial transactions for seven years.

Event attendees will be given the opportunity to subscribe to our mailing list if they wish but it is not a pre-requisite of participating in any AVUK event.

If you are a speaker at an AVUK event, we will publically promote your involvement via Facebook, Twitter, LinkedIn and emails to our supporters.  This data may continue to be processed by those platform providers after the event has ended.

FUNDRAISING

As we get to know you, we will collect the following types of information:

  • Name, title/s and postal address
  • Bank, credit card and payment details – we will only use these for the purpose of processing your donation and will destroy them afterwards
  • Contact details such as email addresses, social media links and telephone numbers
  • Your date of birth
  • Information relating to events you may organise or participate in such as the event date, the donation collection method, records of the money raised
  • If you support our Loud Shirt Day Campaign
  • Contact notes relating to your involvement with AVUK or are considering having with our cause, including
    • How you heard about us
    • What kind of connection you have with our charity
    • Your motivations

How much of this information we collect depends on the type of relationship you have and the information we build in the course of your relationship with us.

We do not store sensitive personal information that you share with us unless there is a clear and valid reason for doing so.  We will store your information on our SalesForce database.

We will use your information to:

  • Provide you with the services, products or information you asked for
  • Administer your contact details and give you the opportunity to change your preferences as well as amend errors and update your data
  • Manage donations (including processing Gift Aid)
  • Support your fundraising activities
  • Help with your activities online.
  • Keep a record of your relationship with us
  • Ensure we know how you prefer to be contacted
  • Flag your data record– for example if you request to be removed from certain mailing lists, opt out of any specific data processing, or if you have special requirements

We need to keep the details of financial transactions for 7 years after the financial year of a donor’s last gift, in the event of a tax or banking enquiry.

We will only contact you to thank you.

If you say that you would like to hear from us, you will be added to our email subscriber list and will receive our quarterly newsletter.  You will also have the opportunity to opt in to receive occasional emails about specific areas of interest, for example specific fundraising events, training courses or AVUK’s research projects.  You will only receive information that you have opted in to receive and you can change your preferences at any time.

WEBSITE VISITORS  

We use Google Analytics (GA) to track site user interaction.  We have GA code installed on our site which creates one or more text files on your computer (called a “cookie”). The cookies contain an ID number which is used to uniquely identify your browser and track each site you visit that has GA enabled.

We use this data to determine the number of people using our site and to better understand how they find and use our web pages.  With this information we can continually improve the information that we provide on our site and the processes for actions such as contacting us and donating. We can also use it to increase the number of new people finding our site.

Google analytics stores the following data:

  • Time of visit, pages visited, and time spent on each page of the webpages
  • Interactions with site-specific widgets
  • Referring site details (such as the URL a user came through to arrive at this site)
  • Type of web browser
  • Type of operating system (OS)
  • Flash version, JavaScript support, screen resolution, and screen colour processing ability
  • Network location and IP address
  • Document downloads
  • Clicks on links leading to external websites
  • Errors when users fill out forms
  • Clicks on videos
  • Scroll depth

Google also collects information about you from its Doubleclick tracking and profiling service, from ad-supported apps on your Android or iOS device, from your YouTube and Gmail activity and from your Google account.  This data is put together and used to make inferences about your age, gender, interests, hobbies, shopping habits and living circumstances. 

Your rights

If you already have GA cookies, they will be updated with the latest information about your visit to the site.

As we cannot access any personal data about you ourselves, we are not the Data Controller for your Google Analytics or Doubleclick profile data.  You would need to contact Google directly for this information.

You have the right to object to this tracking and to stop it happening.

If you would like more details about the methods used however, please get in touch at [email protected]

How do I prevent being tracked by Google Analytics?

If you are uncomfortable with this tracking, you can take the following actions:

  • Use a tracking-blocker, such as Privacy Badger
  • Clear cookies after every browsing session
  • Install the Google Analytics opt-out extension

Third party websites

This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them.  If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data.

We operate a number of social media pages ([including Facebook, Twitter, You Tube and Instagram]). Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information.  Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

EMPLOYEES AND JOB APPLICANTS

If you apply to work at AVUK we will only use the information you give us to process your application.  If we want to disclose information to someone outside AVUK, for example if we need a reference, or need to get a DBS disclosure, we will make sure we tell you beforehand, unless we are required to disclose this information by law.

If you are unsuccessful in your job application, we will hold your personal information for 6 months after we’ve finished recruiting the post you applied for.  After this date we will destroy or delete your information.

If you begin employment with us, we will put together a file about your employment.  We keep the information in this file secure, and will only use it for matters that apply directly to your employment.

Once you stop working for us, we will keep this file according to our record retention guidelines.  You can contact us to find out more about this.

YOUR RIGHTS

As an individual whose personal data is processed by AVUK you have the following rights:

If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you can complain to the ICO.