Action on Hearing Loss is a registered charity (registered as The Royal National Institute for Deaf People) in England, Wales (number 207720) and Scotland (number SC038926). Contact information for our Data Protection Officer is set out in this policy below in section 11.
Personal information means any information which could be used to identify an individual. It can include your name, date of birth or email address.
We update this policy from time to time as we make improvements or when laws change. If we make significant changes to this policy or the ways we use personal information, we will notify you where reasonably possible for us to do so.
Further information is provided below on:
- Collecting your personal information
- Special category data
- Our purposes for processing your personal information
- Lawful bases
- Who we share your personal information with
- International data transfers
- Securing your personal information
- How long we keep your personal information
- Your rights
- Changing how we communicate with you
- Contacting our Data Protection Officer
1. Collecting your personal information
When we collect personal information, we will always explain clearly what information we are collecting, why we are collecting it and how we’ll use it. There are a number of ways we could receive your personal information.
If you give us your information directly for any reason. For example, when you make a donation or contact us for support.
If you give your information to a third-party to pass onto us. For example, by using fundraising sites like JustGiving. We also work on marketing initiatives with third parties under which they may share your personal information with us where you have indicated that you are happy to be contacted by us.
Occasionally we obtain personal information from public sources to better understand our supporters. For example, we might collect information from Companies House or charity or corporate annual reviews.
We also collect certain technical information from you when you interact with our website. For example, the amount of time you spend on pages you visit. For more information about this, please see our Cookies Policy.
Special category data
Certain types of personal information are sensitive and need more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, and health information. There are also special rules about the use of criminal information (information about criminal convictions or allegations about criminal convictions).
We may collect these types of information – particularly information about the health of our beneficiaries. We only collect these types of information where we have a valid reason for doing so (for example, where we require it in order to provide support to a beneficiary) and only if the law allows us to do so. For example, the law allows us to collect health information where we are doing so in order to provide support for individuals with a particular disability or medical condition, or where we have your explicit consent.
3. Our purposes for processing your personal information
We process your personal information for the following purposes:
- To provide you with information about us (where you have requested it) and to communicate with you in general
- To send you updates about Action on Hearing Loss and our activities, services and products
- To administer and promote lotteries
- To invite you to and to run events, including focus groups
- To support our beneficiaries, including assessing individual support needs, preparing and delivering support plans, liaising with carers and healthcare professionals and managing referrals, and to visit beneficiaries and their families at home
- To collect your story about dealing with hearing loss and to use your story in our publications
- Reporting to third parties, such as local authorities, where we are contracted to provide a service on their behalf
- To analyse and demonstrate our impact
- To recruit staff and volunteers
- For staff training and monitoring purposes
- To handle the administration of any donation or other payment you make to us
- To promote our charitable aims (including the use of case studies for this purpose)
- To process Gift Aid
- To provide you with the products or services you have requested
- To analyse, evaluate and improve our operations (including our overall strategy) and our website
- To prepare our accounts and for audits
- To satisfy legal obligations which are binding on us (for example, reporting to the Charity Commission)
- To administer and process legacies (including establishing entitlement and processing legacy payments)
- To establish, defend or enforce legal claims
- To create an evidence base to support our work and to influence policy.
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 purposes. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
4. Lawful bases
Data protection law says that we must have a ‘lawful basis’ to process your personal information. There are five lawful bases that we can rely on depending on why we are processing your information.
If you’ve given your consent to the processing of your personal information for one or more specific purposes. Taking an action to agree you’re happy with us to process your information could include clicking a button or replying to an email. We might use this basis to contact you via email to market our services or to fundraise.
2. Legitimate interests
If we process your personal information for this reason, we believe we have a legitimate reason and that this reason is not overridden by your interests, rights and freedoms. For example, if you have placed an order for a product, we may send you a future edition of our product catalogue in the post. If we rely on our legitimate interest you have the right to object.
If the processing of your personal information is necessary for entering into a contract or a contract we already have with you. This includes sending an order from our shop.
4. Legal obligation
If the processing of your personal information is necessary for us to comply with a legal obligation.
5. Vital interests
If the processing of your personal information is necessary to protect your life.
For more information about lawful basis for processing, visit the ICO website.
Profiling and automated decision making
Profiling is a form of automated processing of personal information to build up a picture of a person. In particular, to analyse or predict aspects about that person’s economic situation or personal preferences. We may use the information we hold about you based on your interactions with us to help us build our relationship with you and personalise what we offer.
This includes building a profile, which may include information from public sources such as Companies House and can contain employment information, estimated capacity to give, information about assets and history of charitable giving. We will only ever access third party or public sources which we consider to be credible and accurate. You have the right to object to this.
We also screen our mailing lists against a register of deaths, and ‘gone away’ changes of address. This ensures that our lists do not contain information which is out of date because the supporter is deceased or has moved away.
We do not undertake automated decision making, which would involve making significant decisions affecting you solely by automated means.
5. Who we share your personal information with
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. This may include those that provide services on our behalf, such as printing of letters or delivery of products. We have systems and processes in place to ensure your personal information is stored securely and is used only for the purposes it was provided.
We may share personal information with our social care regulators where required as part of their regulatory activity. You can access the privacy notices for each as follows: the Care Quality Commission (CQC), the Regulation and Quality Improvement Authority (RQIA) and the Care Inspectorate Wales (CIW).
We may also share your personal information with third parties where necessary to protect or defend our legal rights or the rights of another party.
Public and governmental authorities
We may have to share your personal information with another organisation to comply with the law. For example, if you provide us with VAT exemption information, we may have to share your completed VAT exemption form with HMRC if requested.
We may share your personal information (such as email address and phone number) with social media sites (such as Facebook, Instagram and Twitter and LinkedIn) to show you Action on Hearing Loss content while you use these services.
This information may also be used by the social media site on our behalf to identify other users with similar interests who may be interested in our content. These social media services may also receive some personal information about you when you visit our website, or view our videos, and engage with us that way (in other words, we identify individuals who might be interested in our work and our aims, and then ask social media platforms to check whether those individuals have accounts with them and, if so, provide those individuals with our advertising and campaigning material).
You have the right to object to this. If you do not want us to share your email address or telephone number with social media sites (even in encrypted form), then you can ask us not to by contacting our Data Protection Officer using the details below. You can also control what ads you see via your ad settings within social media sites such as Facebook; we have no control over this.
Third parties in corporate transactions
In connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our organisation, we may share you personal information as part of the transferring assets.
We may share your personal information with our accountants, auditors, lawyers, insurers, bankers or other professional advisors.
6. International Data Transfers
We may need to transfer your personal information outside of the EU and the UK. For example, some of the systems we use to hold personal information are provided by an organisation that stores the data on systems held outside of the EU and the UK. This includes our eNewsletter and live chat providers.
Although these countries may not be subject to the same data protection laws as companies based in the UK, we make sure they provide an adequate level of protection in accordance with UK data protection law or that safeguards (such as standard contractual clauses) are put in place to protect your personal information. Should you have any questions about these safeguards, please contact us using the details below.
7. Securing your personal information
We will take steps to ensure that all personal information we hold about you is kept safe using a variety of security technologies and organisational procedures. These protect your personal information from unauthorised access, use or disclosure.
When we use external companies to collect, process or store data on our behalf, we carry out comprehensive checks and put in place contracts to control how they manage the data they have access to.
8. 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. This includes if it’s needed for any legal, accounting or reporting purposes. For example:
If you submit an online enquiry form, we will store your personal information for up to two years after you submit it.
If you receive eNewsletters from us, we will store your personal information for up to two years after you last open an email from us.
If you make a donation to Action on Hearing Loss, we will store your personal information for up to 10 years from your last donation. This will be longer for those who have committed to leaving us a gift in their Will to ensure we honour this commitment appropriately.
If you volunteer with us and stop volunteering, we will store your personal information for up to six years from when you stopped. If you apply to become a volunteer and are unsuccessful, we will store your personal information for up to six months from your application.
9. Your rights
You have the right to:
- be kept informed about what we are doing with your personal information
- request access to your personal information – this enables you to receive a copy of the personal information we hold about you unless we can rely on an exemption.
Depending on why we are processing your personal information, you may also have the following rights:
- to object to the processing of your personal information, where we are relying on the legitimate interest lawful basis, using your personal information for direct marketing, or for research purposes
- to request us to update or delete the personal information we hold about you
- to withdraw consent for processing your personal information if that is the lawful basis that we are relying on
- to ask us to restrict how we use your personal information for a period of time
- to request us to send personal information that you have provided to us to you or to another organisation in a commonly used electronic format
- to object to the use of automated decision-making and profiling.
Please note that these are legal rights which may not apply in all cases, and which may be subject to legal exceptions. We may also request that you provide us with information to confirm your identity, before we provide any personal information to you.
You have a right to complain to the Information Commissioner about how we use your personal information.
For further information on your rights, visit the ICO website.
10. Change how we communicate with you
If at any time you wish to stop or change how we communicate with you for direct marketing or fundraising purposes, or update the personal information we hold, please contact us. We may continue to send you communications which are purely administrative.
You can also unsubscribe from our eNewsletters at any time. Simply click on the “unsubscribe” link in any of our email news updates.
If you are unhappy with how we handle your personal information or any requests you make, please contact our Data Protection Officer using the details below.
11. Contact our Data Protection Officer
- 020 7359 4442
- Data Protection Officer, Action on Hearing Loss, Brightfield Business Hub, Bakewell Road, Orton Southgate, Peterborough, PE2 6XU
Last updated 23 September 2020 and will come into effect 26 October 2020.