deafPLUS is the trading name of Breakthrough Deaf-Hearing Integration (charity number 1073468, Registered Company number 3680467).   Registered Address:  Trinity Centre, Key Close, London E1 4HG.

This policy was last updated: 23rd May 2018

How we will use your personal details

deafPLUS takes your privacy very seriously and we want you to understand clearly how we use the Personal Information we collect about you. We are a “data controller”. This means that we are responsible for deciding how we hold and use Personal Information about you, and for explaining this clearly to you. When you share information with us, we will always tell you how we will use it depending on how and why we are collecting the information.

We always act on your instructions and we aim to put you in control of your relationship with us. Our aim is to communicate and work with you in a way that makes you want to stay involved with us for as long as possible, as you see the value and impact of your relationship with us.

We will not share your data for others’ marketing purposes

Please be assured that you will not receive offers from other companies or organisations as a result of giving your details to us. We will not sell, rent or lease any Personal Information we collect to any third parties.

How to stop or change how we communicate with you

If at any time you wish to stop or change how we communicate with you, or update the information we hold, please do get in touch. We will provide you with contact details or you can use the details at the bottom of this policy. 

Our full privacy policy

Introduction

deafPLUS takes your privacy very seriously and we want you to understand clearly how we use the Personal Information we collect about you. When you share information with us, we will always tell you how we will use it depending on how and why we are collecting the information.

This Privacy Policy applies to any Personal Information collected and used by deafPLUS. For the purpose of this Policy, ‘Personal Information’ means information which can identify a living individual.

What we collect, why we collect it and how we use it

The type of Personal Information we collect will depend on why you are providing it and how we are using it – for example if you are making a donation, purchasing a product or service (eg training), asking about volunteering opportunities or receiving support from us.

As an organisation we collect and use Personal Information for a variety of reasons and in a variety of ways, depending on the activity you are taking part in when you share the information.

When we collect Personal Information, we will always explain clearly what information we are collecting, why we are collecting it and how we will use it.

If you do not provide us with your Personal Information, we may not be able to provide you with any of our services.

We will always make sure we have a lawful basis for processing your Personal Information. For more information on the lawful bases to process your Personal Information click here.

Legitimate Interests

If you receive a communication from us that mentions our “Legitimate Interest”, then please be assured you are still in control of how we use your Personal Information. “Legitimate Interest” is one of the lawful bases we can rely on to process your Personal Information, and when we use this basis we have to consider your privacy rights and whether these outweigh our legitimate interests. You can easily stop or change how we use your Personal Information, and we will explain how you can contact us to do so. Click here to find out more about what we mean by Legitimate Interests.

How we collect personal information

We may obtain your information in the following ways:

Directly from you

If you give us your information directly for any reason – such as making a donation, becoming a member or volunteer, purchasing a product or requesting support from us, we will ensure you are given all the important information about how we will use and look after your information at the time.

Indirectly

If we receive your information from another source and not directly from you (for example by fundraising sites like Just Giving, or if we receive referral information about your support from other agencies or your care manager) we will also ensure you are given all the important information about how we will use and look after your information as soon as possible and within one month of receiving your information (unless it is impossible to do so or would involve disproportionate effort). If it is disproportionate for us to contact you with this information, you can always find a copy of this privacy policy on our website.

When you visit our website

We use cookies on our website to collect information about your visit to our website, including the pages you view, the links that you click on and other actions taken within our website. We also collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring Web site addresses. This data about your site visit is not linked to any information you enter into any forms on our website (such as signing up for newsletters, or purchasing in our online shop), or to any other information we hold about you.

When you access deafPLUS’s Social Media

We might also obtain your Personal Information through your use of social media such as Facebook, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.

Facebook
Twitter
LinkedIn

When the information is publicly available

We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like deafPLUS. In this scenario, we may seek to find out more about these individuals, their interests and motivations for giving through publicly available information. This information may include newspaper (eg Sunday Times Rich List) or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House. This is a form of profiling (see below) to build up a picture of donors. We will not retain publicly available data relating to major donors without informing them, which will be done at the earliest practical opportunity.

Profiling and Automated Decision making

Profiling is any form of automated processing of personal data to build up a picture of a person, in particular to analyse or predict aspects about that person’s economic situation, personal preferences or interests. We may use the information we hold about you based on your interactions with us in order to build our relationship with you, offer you the right help or information and personalise things we offer to you.

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We will always inform you if we are processing your information in this way.

Who we share your information with

We do not sell, rent or lease the Personal Information we collect to any third parties.

Depending on why you provided us with your Personal Information and how we are using it, we may need to share your information with other organisations or individuals, such as those that provide services on our behalf (e.g. printing and delivery of mailings, delivery of products, information on your support or communication needs to a hospital if you are admitted).

We will only provide these organisations and individuals with the Personal Information necessary to fulfil the purpose for which it was provided.

We have systems and processes in place to ensure your Personal Information is maintained confidentially and securely and that it is used only for purposes for which it was provided.

Depending on why you provided us with your Personal Information and how we are using it, we may need to transfer your information outside the EEA, (for example some of systems we use to hold Personal Information may be provided by an organisation that stores the data on computer systems held outside the EEA). Although the country may not be subject to the same data protection laws as companies based in the UK, we will endeavour to make sure they provide an adequate level of protection in accordance with UK data protection law, or ensure that safeguards are put in place to protect your personal information. If you wish to know more about any transfer outside the EEA or the safeguards in place please contact us using the contact details provided or at the bottom of this policy.

We may also need to disclose your Personal Information to another organisation if we are required to do so to meet a legal obligation.

How we keep your Personal Information secure

All Personal Information we hold about you will be kept securely, using a variety of security technologies and organisational procedures to help protect your Personal Information from unauthorised access, use or disclosure.

How long we keep your Personal Information

We will only keep your Personal information for as long as it is required for the purpose we collected it, including if it is needed for any legal, accounting or reporting purposes. We will let you know how long we keep your Personal Information.

Your rights and controlling your Personal Information

You have the right to:

  • Be informed about what we are doing with your Personal Information;
  • Object to the processing of your Personal Information;
  • Request access to your Personal Information (commonly known as a “data subject access request”);
  • Request us to update the Personal Information we hold about you or delete the information we hold about you (although we will not be able to provide our services to you if you make this request);
  • Ask us to stop processing Personal Information about you where we are relying on a legitimate interest;
  • Ask us to restrict how we use your Personal Information for a period of time;
  • Request us to send another organisation information that you have provided to us in a computer-readable format;
  • Understand and input into a decision made by solely automated means if it has a legal or similarly significant effect on you;
  • Withdraw consent if that is the basis that we are relying on. We will inform you how to do this.

For further information on your rights – click here

If you are unhappy with how we handle your Personal Information, or how we handle any requests you make, please contact our Data Protection Officer using the details below.

If our Data Protection Officer cannot address your concern, you can complain to the Information Commissioner’s Office: or call 0303 123 1113.

Changes to this Policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Information.

Contact our Data Protection Officer

Our Data Protection Officer is responsible for making sure that we comply with our Privacy Policy and with all data protection regulations and law.

Our Data Protection Officer can be contacted by calling 020 7 790 6147 or writing to Data Protection Officer, deafPLUS, Trinity Centre, Key Close, London  E1 4HG.

Lawful Bases

Data Protection law says that we must have a ‘lawful basis’ to use your Personal Information. There are 5 lawful bases that we might rely on depending on why and how we are using your information, which are described below.

Lawful Basis Description When this is likely to apply
Consent You have given your Consent to the processing of your Personal Information for one or more specific purposes If you take an action to agree or confirm you are happy with our use of your data – this may be clicking a button, replying to an email, or by providing us with your information.
Legitimate Interests If deafPLUS has a genuine and legitimate purpose to process the Personal Information, unless this is outweighed by harm to your individual’s rights, interests and freedoms.

Click here to find out more about what we mean by Legitimate Interests.

If we feel we have a “Legitimate Interest” in using your information, as long as this does not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is and you have the right to object.
Contractual Processing of Personal Data is necessary for the performance of a contract with you or to take steps that you request before entering into a contract (e.g. to supply goods or services you have requested). If we need your Personal Information to provide a service to you, or to provide or deliver a product to you, or for any other contract we may have with you.
Legal Obligation Processing of Personal Data is necessary for deafPLUS to comply with a legal obligation. If we have to use your Personal Information in a certain way, or share it with another organisation, to comply with the law.
Vital Interests Processing of Personal Data is necessary to protect your vital interests. If we need to use your Personal Information to protect your life.

Legitimate interest

“Legitimate Interests” means the interests of our organisation in achieving our aims. For example, we have an interest in communicating with our supporters to provide information on our work helping those confronting deafness, tinnitus and hearing loss and how to support our life-changing work, including fundraising, campaigning and volunteering.

When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law)

If you have any concerns about the processing of your Personal Information based on our legitimate interests, you have the right to object. For more information on your rights, please click here.

You have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. (Access)
  • Request that we update the personal information we hold about you (Rectification)

Depending on why we have and use your Personal Information you may also have the following rights:

  • To be informed about what we are doing with your personal data.
  • To object to the processing of your personal data (Object).
  • To ask that we delete your Personal Information (Erasure). If you ask us to delete your Personal Information we will not be able to provide our services to you.
  • To ask us to stop processing your Personal Information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
  • To limit our use of your Personal Information (Restriction).
  • To request an electronic copy of your Personal Information in a commonly used form e.g. CSV file (Data Portability).
  • To understand and input into a decision made by solely automated means if it has a legal or similarly significant effect on you (Automated Decision Making including profiling).

Your rights explained

Find out below when you have each of the following rights.

Erasure

To ask that we delete your Personal Information

    • If we no longer need your information for the reason we collected it
    • If you gave your consent to how we use your information but now wish to withdraw that consent
    • If you want to object to our use of your information and we have no overriding legitimate interest to continue
    • If we are using your information unlawfully
    • If there is a legal requirement to delete the information
    • If the information is processed in relation to the offer of online services to a child.

Object

To object to our use of your Personal Information

    • If we are using your information based on our legitimate interests
    • If we are using your information to contact you for direct marketing reasons (e.g. fundraising)

Restrict processing

To limit our use of your Personal Information

    • If you think the information we hold about you is inaccurate or incomplete – whilst we check the accuracy and/or update it
    • If you object to the processing of your information based on our legitimate interests, while we investigate if we have an overriding legitimate interest
    • If we are using your information unlawfully
    • If we no longer use the information, but you require us to keep it for any legal claim

Data Portability

To request an electronic copy of your Personal Information in a commonly used form e.g. CSV file

If you provided us with your information directly for contractual reasons or consented to how we use it, and the processing is carried out by automated means.

Automated decision making including profiling

To obtain human involvement, obtain an explanation, input to and challenge the decision

If we are using your information to make a decision which has a legal or similarly significant effect on you and if it is made by solely automated means (including profiling)