Privacy Policy
This policy was last reviewed in September 2024
Affina Organisation Development Ltd (with company number 04644495 in England and with data controller number Z9213489) (“AOD”) is committed to protecting your privacy and security. AOD is part of the Skills for Care Group and the registered address of both is West Gate, 6 Grace Street, Leeds, LS1 2RP. For the purposes of data protection law, AOD will be the controller of its own data.
This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information. We will comply with the United Kingdom General Data Protection Regulation (“GDPR”) in respect of the personal data you pass to us and the Data Protection Act 2018 (“DPA”) and any successor legislation to the GDPR and the DPA.
Your personal data (i.e., any information which identifies you, or which can be identified as relating to you personally) will be collected and used by AOD which is the data controller (as defined in GDPR) of your personal data.
Questions?
Any questions you have in relation to this policy, or how we use your personal data, should be sent to compliance@skillsforcare.org.uk or addressed to The Data Protection Officer, Affina Organisation Development Ltd, West Gate, 6 Grace Street, Leeds LS1 2RP or telephoning 07866 802990.
Contents
- What information we collect
- How we use information
- Disclosing and sharing data
- Marketing communications
- How we protect data
- Data storage
- Cookies and links to other sites
- Your rights
- Changes to this privacy policy
1. WHAT INFORMATION WE COLLECT
Personal data you provide
AOD does not capture and store personal information except where you have given us permission or it forms part of a contract with your employer / or an organisation with which you are working or from publicly available sources. , for example:
- Cookies and analytics on our website
- Registering on our website when using our training course booking forms, using the contact us forms, ordering AOD Connect credits or registering for our newsletter (via Mailchimp)
- name
- email address
- organisation details
- billing address
- contact telephone number
- billing address – for course bookings or credit purchases
- Registering on our AOD Connect web platform and use of our on-line assessment and development tools.
- name
- email address
- organisation details
- assessment responses and team journey activities
- Providing delegate details directly or through your organisation for participation on our training courses
- Name
- Email address
- Organisation details
- Postal address
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff then we will keep a record of this to comply with our statutory duties under the Health and Safety Act, but we will of course keep this data strictly confidential and will not disclose to any third parties unless the law tells us to do so (which may include personal data and sensitive personal data).
2. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter into, or perform, a contract with you, your employer or affiliated organisation;
- comply with a legal duty;
- protect your vital interests;
- for our own (or a third party’s) lawful interests, provided your rights do not override these.
In any event, we will only use your information for the purpose or purposes it was collected for (or else for closely related purposes).
Marketing
We use personal data to communicate with you and to promote AOD offers. This includes keeping you up to date with our news, updates, campaigns, events. For further information on this please see Section 4 (Marketing).
Training programmes and on-line tools
Personal data provided for course registration or to enable use of the Affina Team Journey, Affina Team Performance Inventory or Affina Real Team Profile Plus will be used solely for the undertaking of the specific activity.
For these purposes information will be limited to identity and contact data:
- full name
- title
- team name
- email address
- phone number
- organisation name and address
In the undertaking of our Culture Assessment Tool, Partnership Assessment or other bespoke organisation/system-wide surveys, participants may also be asked to respond to questions relating to ‘special category’ personal data. Questions may include:
- age
- gender
- ethnicity
- religion
- sexual orientation
- physical / mental disability
- caring responsibilities
- occupational group
Responses to all questions relating to special category data will be non-mandatory. This data will only ever be requested from the data subject themselves. Such demographic data is collated to enable statistical comparison between groups and, as with all other response data, will only be accessible in an anonymised, aggregated format.
3. DISCLOSING AND SHARING DATA
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, or third-party products and services, but these communications will always come from AOD and are usually incorporated into our own marketing materials (e.g., in newsletters).
We may share personal data with subcontractors or suppliers who provide us with services. For example, our AOD Connect platform hosts, or delivery companies for training materials. However, these activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.
We may also share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may also need to disclose your personal information where we:
- sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller.
- are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
- need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.
4. MARKETING COMMUNICATIONS
AOD adheres to the “opt-in” principles for our marketing communications. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about AOD products and services as well as relevant information on team-based working).
This means you will have the choice as to whether you want to receive these email messages.
You can decide not to receive communications or change how we contact you at any time. You can unsubscribe to our marketing communications or update your details by following the unsubscribe/update links at the bottom of our emails. Alternatively, please contact our marketing team by emailing info@affinaod.com, writing to Affina Organisation Development Ltd 156B Rectory Road, Old Bakery Mews, Farnborough GU14 8AL or telephoning 01252 727270.
5. HOW WE PROTECT DATA
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.
Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training, and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
6. DATA STORAGE
Where we store information
AOD operations are based in the UK and all our data is stored in the UK. Some organisations which provide services to us may transfer personal data outside of the UK, but we will only allow them to do so if your data is adequately protected and the relevant contract clauses are in place.
How long we store information
We will only use and store information for as long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question, and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing your email address for marketing purposes (though we will keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required.
General retention times
- Affina Team Journey (2-year licence) – data is retained for just over 24 months as Team Journeys are expired at the end of each quarter. At the start of the following quarter data is permanently deleted.
- Team Leader and Team Coach contact data is retained for as long as the individual has an active Affina Team Journey. When all Affina Team Journeys have expired, all associated Team Leader and Team Coach data will be deleted.
- Affina Team Assessment Tools – standalone assessment data is retained for 36 months to enable re-assessment; at the end of this time all assessment data is deleted. Questionnaire recipient data (name and email address) is not required for the re-assessment and is retained for 6 months from production of the final report.
- Affina Team Assessment Tools – practitioner contact data is retained while the practitioner remains active and accredited. Inactive users will be deleted 48 months after the last assessment registration date or user set up.
- Culture Assessment and Partnership Assessment Tool data – personal data is retained for 6 months from production of the final report.
At the end of the retention period, your personal data will be securely deleted or anonymised.
You can find more about our data retention periods by requesting a copy of our Data Retention Policy.
7. COOKIES AND LINKS TO OTHER SITES
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. Please refer to our detailed cookie policy.
For further information visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Links to other sites
Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the ‘Contact us’ link at the top of the page).
If an external website requests personal information from you (e.g., in connection with an order for goods or services), the information you provide will not be covered by the AOD Privacy Policy. We suggest you read the privacy policy of any website before providing any personal information.
When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with AOD.
8. YOUR RIGHTS
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website. These rights apply for the period in which we process your data. Your rights are:
- right to be informed
- access to your personal data (‘subject access request’)
- rectification of your personal data
- right of erasure
- right to restrict processing
- data portability
- right to object to us processing your personal data
- right to object to automated decision making (note that we do not carry out any automated decision making using your personal data)
- right to withdraw consent
- right to lodge a complaint
If you have any concerns about the way your data is being used, please contact our Data Protection Officer on email compliance@skillsforcare.org.uk.
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can also report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website.
AOD has appointed Data Protection Representative Limited (trading as DataRep) as our representative in the European Union for the purposes of Article 27 of the General Data Protection Regulation ( GDPR, regulation EU 2016/679 in the EU and EEA)
Any data protection subject requests outside of the UK should be made directly to our representative and not to AOD. Enquiries should be made by email to datarequest@datarep.com (quoting <Affina Organisation Development> in the subject line), online at www.datarep.com/datarequest or directly in your home country, using the addresses listed in the Representative Contact Summary.
9. CHANGES TO THIS PRIVACY POLICY
We will amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.