Ace Centre is a registered national charity (no. 1089313) dedicated to the support of individuals with complex communication and physical difficulties, and we have always been committed to protecting the privacy and security of the personal data of our service users.
• We take your privacy seriously;
• We are committed to protecting the security of your personal information;
• We comply with data privacy laws when using your personal information;
• We will explain your rights to control your personal information to you, and how to use them.
We provide a range of specialist services to individuals with communication and physical difficulties, their families and the professionals working with them. The effective delivery of these services involves the collection and processing of information that is considered personal information. The exact nature of the personal information collected, the individuals and/or organisations with whom this information will be shared, and the length of time for which these records will be held varies in accordance with the demands of the different services we provide, each of which are itemised below:
1. NHS Specialised AAC Service
Ace Centre have been appointed by NHS England to deliver a specialised Augmentative and Alternative Communication (AAC) service on their behalf in the North West and Thames Valley & Wessex specialised health regions of England.
In accordance with the terms of Contract 13Y_2022-23 CV011 Ace Centre, we collect, process and hold the minimum dataset required to enable us to deliver an impartial, target driven and measured service offering:
• specialised assessment and review of complex communication and physical needs, provision and maintenance of specialised equipment (including hardware and software), and
• training to support set-up and implementation of recommended interventions.
The legal basis for processing information is to pursue the legitimate interests of both NHS England and Ace Centre involved in delivering, monitoring and evaluating the contract services.
In accordance with Health recommendations on minimum data retention periods, Ace Centre retains the personal information gathered on all referrals to this service, regardless of whether or not the referral is ultimately deemed eligible:
- For adults, Ace Centre will retain this information for a period of 8 years following the date of discharge, date of death, or date of non-acceptance for service provision, whichever is earliest.
- For children, Ace Centre will retain this information until the child’s 26th birthday, or for a period of 8 years following the date of discharge, date of death, or date of non-acceptance for service provision, whichever is latest.
Ace Centre use Hugh Steeper Limited to undertake the annual inspection of the Augmentative and Alternative Communication devices we provide. We share a minimum dataset of information with this company to enable them to undertake this role and we have a written contractual agreement with this company to ensure that the necessary and appropriate safeguards are in place for any personal information shared with them in this way.
Additionally, we may share some of your data gathered as part of our ongoing work with you with other service providers supporting you. This data will be shared with your knowledge and on your behalf in all instances, except where we have a statutory requirement to share data, or if there is a safeguarding concern.
As part of our work, we may occasionally use information about those who have used this service for training and/or promotional purposes, for example to participate in the development of case studies. At that time, Ace Centre may also gather additional personal information specifically for these purposes, such as photographs. We will ask for consent from those whose personal information is being processed before collecting, processing, sharing and/or holding information for this purpose.
2. Training
Ace Centre offer a range of training opportunities, both accredited and non-accredited. When you book a training place, we will need to collect, process and hold personal information about those who are booking the event as well as those planning to attend, and any payment required for that booking.
We will use your personal contact information for the purpose of managing and administering training courses. The legal basis for processing information is to pursue the legitimate interests of both Ace Centre and the organisation or individual entering into a contract with Ace Centre for training services, to facilitate the delivery, monitoring and evaluation of same.
The personal data we collect to manage and administer our non-accredited training is not shared with any third party.
Our accredited training, however, is accredited by Manchester Metropolitan University (the University) and is delivered under a Collaborative Partnership Agreement (CPA) with the University. In accordance with terms of that CPA, delegates are required to be registered with the University as external students, and a minimum dataset of information to satisfy the University’s accreditation procedures is shared with the University by Ace Centre. This consists of MMU Student ID number, name, address, date of birth, award studied for, dates of attendance, result, gender, nationality, disability, highest qualification at entry. The CPA ensures that the necessary and appropriate safeguards are in place for any personal information shared with the University in this way.
At the time of booking, and/or during the post-training evaluation process, we may also ask you for consent to send you information that may be of interest or benefit to you or the organisation or group you are representing. Please note that if you don’t provide your consent, we will be unable to send you this information. You may withdraw your consent at any time.
The information that you provide if and when you consent to receiving further information from Ace Centre will be shared with the company that we use to distribute our mailings, and to manage subscriptions on our behalf (a data processor). This is currently ‘Mailchimp’, ‘Access CRM’ and ‘Spotler’. Data Processors may only act on our instructions. Your information is not passed to any other third party.
Ace Centre will retain a minimum dataset, consisting of training attended, dates of attendance, result and basic contact details, for a minimum of 24 months after completion of the training course. The legal basis for holding this information is to pursue the legitimate interests of both Ace Centre and you – enabling us to evaluate the quality of our training provision and its impact on practice, and to accommodate potential requests for replacement certification. Where the training qualification in question is valid for moe than 2 years, the retention period will be extended accordingly.
Ace Centre is legally required to retain information about payment transactions for 6 years from the end of the financial year in which the training course was completed. Ace Centre will securely dispose of information as soon as it is no longer required.
3. Information
Ace Centre provides a range of information services. For each of these information services, Ace Centre will collect, process and hold the minimum personal data needed to enable us to provide an effective service.
3.1. Free telephone helpline
Ace Centre do not record telephone conversations, nor do we retain any data about telephone enquiries, except where the enquiry relates to an existing client. For existing clients, a brief file note will be made summarising the date and nature of the enquiry and the response made/action taken.
3.2. Free website enquiry line
When you use our website enquiry line, we will collect and process your name, role, location and contact details.
The legal basis for processing this information is to pursue the legitimate interests of both Ace Centre and you, by facilitating the delivery, monitoring and evaluation of this service.
Our website is maintained by Fig Agency (a data processor). Data Processors may only act on our instructions. Your information is not passed to any other third party.
At the time of submitting your enquiry, we will also ask you for your consent to send you information that may be of interest or benefit to you. Please note that if you don’t provide your consent, we will be unable to send you this information. You may withdraw your consent at any time.
The information that you provide if and when you consent to receiving further information from Ace Centre will be shared with the company that we use to distribute our mailings, and to manage subscriptions on our behalf (a data processor). This is currently ‘Mailchimp’, ‘Access CRM’ and ‘Spotler’. Data Processors may only act on our instructions. Your information is not passed to any other third party.
3.3. Free information day appointments
When you book an information day appointment, we will need to collect, process and hold your name, role and contact details and, where the purpose of the appointment is to consider the needs of one or more specific individuals, the name, date of birth, diagnosis and summary of the particular needs of those individuals.
During the appointment itself, brief client notes will be made summarising the nature of the discussion.
The legal basis for processing this information is to pursue the legitimate interests of both Ace Centre and the individual(s) using the service, to facilitate the delivery, monitoring and evaluation of same.
Prior to 1/1/19, information day appointment bookings were processed through Eventbrite (a data processor). Since that date, information day appointment bookings are processed through Ace Centre’s website, maintained by Fig Agency (a data processor). Data Processors may only act on our instructions. Your information is not passed to any other third party.
We will also use the minimum personal data gathered in the delivery of our information services to derive quantitative and qualitative management information to enable us to assess our performance and inform business decisions, e.g. allocation of resources. You will not be identifiable from this management information.
At the time of booking, and/or during the post-training evaluation process, we may also ask you for consent to send you information that may be of interest or benefit to you or the organisation or group you are representing. Please note that if you don’t provide your consent, we will be unable to send you this information. You may withdraw your consent at any time.
The information that you provide if and when you consent to receiving further information from Ace Centre will be shared with the company that we use to distribute our mailings, and to manage subscriptions on our behalf (a data processor). This is currently ‘Mailchimp’, ‘Access CRM’ and ‘Spotler’. Data Processors may only act on our instructions. Your information is not passed to any other third party.
For existing clients, the information collected at the time of booking and during the appointment itself will be added to their clinical notes.
For all other clients, the information collected at the time of booking and during the appointment itself will be retained for a period of 24 months after the date of the information day itself.
3.4. Free eNewsletter, AACInfo Monthly
To support and further our Charitable objectives, Ace Centre offers a free eNewsletter, Ace Centre e-Newsletter (formerly AACInfo Monthly), to anyone with an interest in AAC. We collect the name, role, location and contact details of all subscribers. This personal information is collected, processed and held on the basis of your consent, and you may withdraw this consent at any time.
The information that you provide if and when you consent to receiving this free eNewsletter will be shared with the company that we use to distribute our mailings, and to manage subscriptions on our behalf (a data processor). This is currently ‘Mailchimp’, ‘Access CRM’ and ‘Spotler’. Data Processors may only act on our instructions. Your information is not passed to any other third party.
3.5. Charged for printed publications and training materials
When you order a charged for printed publication and/or training materials, we will need to collect, process and hold your name, role, contact and payment details.
The legal basis for processing this information is to pursue the legitimate interests of both Ace Centre and the individual or organisation placing the order, to facilitate the prompt administration and supply of the required items.
Purchases are processed through Ace Centre’s website, maintained by Fig Agency (a data processor). Data Processors may only act on our instructions. Your information is not passed to any other third party.
At the time of placing your order, we may also ask you for consent to send you information that may be of interest or benefit to you or the organisation or group you are representing. Please note that if you don’t provide your consent, we will be unable to send you this information. You may withdraw your consent at any time.
The information that you provide if and when you consent to receiving further information from Ace Centre will be shared with the company that we use to distribute our mailings, and to manage subscriptions on our behalf (a data processor). This is currently ‘Mailchimp’, ‘Access CRM’ and ‘Spotler’. Data Processors may only act on our instructions. Your information is not passed to any other third party.
Ace Centre is legally required to retain information about payment transactions for 6 years from the end of the financial year in which the training course was completed. Ace Centre will securely dispose of information as soon as it is no longer required.
4. Consultancy/Partnership Agreements
To support and further our Charitable objectives, Ace Centre undertake a number of paid for activities under contract with individuals and organisations that may involve collecting, processing and holding your personal information.
The personal information collected, the individuals and/or organisations with whom this information will be shared, and the length of time for which these records will be held, will vary in accordance with the specific terms of each individual contract.
The legal basis for processing information for this purpose is to pursue the legitimate interests of Ace Centre and the individual and/or organisation entering into a contract for delivery of the stated services.
The data will remain the property of the contracting individual and/or organisation.
5. Research
To support and further our Charitable objectives, Ace Centre undertake a number of research activities which may involve gathering, analysing, storing and other processing of your personal information.
The personal information collected, the individuals and/or organisations with whom this information will be shared, and the length of time for which these records will be held will vary in accordance with the specific parameters of individual research projects, and you will always be able to decide whether or not to provide us with the information we are requesting.
Research undertaken by Ace Centre is always for the purpose of furthering our charitable objectives of improving services for children, young people and adults with complex communication and/or physical difficulties. The way in which your information will be used will vary, although results of research are always reported in an anonymous, aggregated form. We collect personal information based on your consent and you may withdraw this consent at any time.
Research information will be processed by the appropriate team within Ace Centre, and we do sometimes share results of their research with third parties. Usually, this will be in an anonymous, aggregated form although occasionally we will share original datasets.
Personal information will only be shared if the third party wishes to process the personal information for the same or compatible purposes.
When information is shared in this way, Ace Centre will always use an information sharing agreement with the third party to ensure the necessary and appropriate safeguards are in place for any personal information.
Research data does not have any set retention periods although the information is regularly reviewed to ensure it remains relevant to furthering Ace Centre’s objectives. As part of this review, we also consider whether the data can be pseudonymised or anonymised. We securely dispose of research data as soon as it is deemed to be no longer required.
6. Fundraising
Ace Centre are a national registered charity, and raise funds from individuals, groups and organisations to further our charitable objectives.
Ace Centre is legally required to retain information about payment transactions for 6 years from the end of the financial year in which the transaction was completed. Ace Centre will securely dispose of information as soon as it is no longer required.
We will retain direct debit mandates indefinitely in line with the Direct Debit Guarantee scheme
7. Recruitment
All recruitment at Ace Centre follows a formal recruitment process prior to entering into a contract of employment.
As part of the recruitment process, each candidate will be required to complete and submit a covering letter and CV or application form.
All information provided during the recruitment process will be used to decide whether a person is suitable for a particular role. Following your application, the legal basis for this processing is in order to take steps prior to entering into a contract.
Information that you provide will be passed to those in Ace Centre who are part of the recruitment panel. Ace Centre may also pass certain information to the Disclosure and Barring Service (a data processor), if the role for which you are applying is subject to disclosure checks. Data Processors may only act on our instructions. Your information is not passed to any other third party.
Information relating to any recruitment process is not transferred internationally.
Ace Centre retain information relating to unsuccessful applications for twelve months from the date of appointment of the successful candidate. Information relating to the successful candidate usually forms part of an employment contract and will be retained for 6 years from the date employment is terminated for any reason.