login sign up

Data Protection Policy

Authored: Rebecca Gill
Role: Marketing Assistant
Date: 11th August 2021

This policy is reviewed by a Lingo Flamingo staff member every 6 months.

Lingo Flamingo is a non-profit language school committed to serving the local community with language based learning opportunities and activities for older adults and those experiencing cognitive decline or living with dementia in care homes and day centres across Scotland.

We are a registered Community Interest Company and our registration number is SC504000.

Lingo Flamingo is based at 155 Deanston Drive, Shawlands, Glasgow, G41 3LP and 128 Sword Street, Glasgow, G31 1SF. Our contact details are info@lingoflamingo.co.uk, tel: 0141 328 4094.

Lingo Flamingo is committed to storing or processing your data correctly and being transparent about our data practices. We care about protecting your privacy.

This policy contains definitions of data. It tells you what kinds of data we may collect when you become involved with Lingo Flamingo and our procedure for handling and storing that data in those circumstances. It explains your rights to your data, as well as our legal bases for processing that data which justify why and how we collect it.

This policy is served by Lingo Flamingo CIC in accordance with the GDPR and DPA and concerns the governance of data and the rights to data privacy of those who interact with the organisation.

Overview

  1. Our Data Values
  2. Definitions
  3. What kinds of data do we collect?
  4. Your rights
  5. Keeping or Using Data
  6. Getting in touch with Lingo Flamingo
  7. Our website
  8. Mailing lists and marketing messages
  9. As a student
  10. As a partner organisation
  11. Our Online Portal
  12. Media and recordings
  13. Recruitment
  14. Volunteers

1. Our Data Values

We care about your privacy. Here at Lingo Flamingo, our data values strive to reflect this. This means we will always process your data lawfully and fairly. Your data will only be processed in service of our legitimate interests, for limited purposes and in accordance with the rights you hold to that data.

The Lingo Flamingo team will always ensure that we are trained in and aware of the correct procedures for protecting your data to the best of our ability. We will treat all information you provide as confidential. We will ensure that staff are well informed about the data they have access to and how to guard its confidentiality. It will always be kept securely and we will never share your data with third parties.

The data we collect or hold about you will always be relevant and not excessive. Your data must be kept accurately, with changes made to keep it up to date and never kept for longer than necessary. When we dispose of data, we will do so in accordance with GDPR guidelines.

2. Definitions

Data is information which is stored:

  • Electronically (Including on phones, computers, tablets, in videos or images)
  • Physically (In hard copy, on paper, in filing systems)

Personal data are things we have recorded about someone which they can be identified from. For example names, birthdates, payroll numbers…

Sensitive personal data is information about race, politics, religion, health, union activity, sex life, or criminal record. Sensitive Personal Data has extra protection because of the harm that could happen to someone if the data was found out by the wrong person.

Processing means anything involving the use of any personal data. It covers collecting, keeping, using and getting rid of the data. It also includes passing the data to other people outside Lingo Flamingo.

3. What kinds of data do we collect?

When you get in contact with us, or sign up for our classes or newsletter, we ask you to provide us with some information about yourself, such as your name, email address, or contact number, which we store or process in pursuit of our legitimate interests, in order to address your inquiry, or provide our services.

In addition to data gathered directly from interactions with the organisation or from becoming one of our students or partner organisations, there are also instances where some data is generated or gathered passively - such as through use of cookies on our website, or automatically through the creation of a student profile on our portal. You can read more about how we collect and use this data in the relevant sections below.

4. Your rights

You have the right to:

  • Request access to the data we hold about you
  • Amend this information when the data is incorrect, incomplete, or needs to be updated.
  • Request copies of the personal data we hold about you
  • Withdraw your consent from any processing of your personal data which requires consent to do so.
  • Object to any of the ways we process your personal data that is based on legitimate interest.
  • Challenge the accuracy or lawful basis of the processing of your data and request a temporary restriction of this processing.
  • Request the deletion of all the personal data that we hold about you and an end to the processing of this data.

5. Keeping or using data

We may keep a record of your data for a number of reasons, depending on your interaction with us as an organisation. You can find details of these circumstances in the rest of this policy. We will keep your data securely, either digitally or in print. We will not keep your data for longer than necessary.

Holding this data allows us to understand how our services are being used so that we can improve them, in order to better serve our values, our mission and our community. You can ask us to delete this information at any time by getting in touch with us.

We will only make use of your data in certain cases. Lingo Flamingo will only make use of your data with your explicit consent. The only cases where this would not be needed is if you have asked us to get in touch with you in relation to a query you have, or if your data has been anonymised - such as in a feedback report, or survey. We will always follow GDPR guidelines in these cases and will not share your personal data publicly.

6. Getting in touch with Lingo Flamingo

We love to hear from you! If you get in touch with us, we will do our very best to address your query satisfactorily and in a timely manner. To do this, we require your name, your contact details, your organisation (if applicable) and details about the nature of your inquiry.

This personal data may be passed among members of our team depending on who can best address your needs. They will not be shared with anyone outside of the Lingo team, and will not be passed through insecure channels of communication, such as over the phone.

In some instances, we may get in touch with you after your interaction with us, if there is a relevant opportunity or event with Lingo Flamingo that we think you may be interested in. We will only contact you if the opportunity is relevant to your previous interaction with us, and will not contact you if you were in touch with us more than three years ago. You will never be added to our mailing list without having requested it.

7. Our website

Like almost all sites on the web nowadays, ours has some analytics software that tracks visits to the site and page activity. This data is anonymous and collected only for the purpose of monitoring the traffic to our website and learning more about how it is being used. A record of this data is automatically logged by Squarespace (our domain provider). Access to this data is password protected and is not shared with third parties.

8. Mailing lists and marketing messages

As a student, partner organisation or another interested party, you may be asked if you would like to sign up for our mailing list or newsletter. You will only be added to our mailing list if you have given permission, by providing your email address. Contact from Lingo Flamingo through these services will never be excessive, nor will they contain spam or phishing, or any other insidious content that could put your privacy at risk.

We may contact you via our mailing list to ask for feedback on our services. This feedback is important to us so that we can provide you with the best possible language learning experience. It is also necessary for us to collect this information periodically in order to monitor our progress, social impact and development as a non-profit organisation, or to provide feedback to our funders. Data collected through these surveys will be anonymised. You will not be contacted for feedback through this communication channel if you have stopped using our services more than a year prior.

Another way we use our mailing list is to announce new timetables and opportunities for booking classes. We may contact you in this way periodically so that you can book classes as soon as they become available.

Our newsletter is sent out monthly and contains information about the development of the organisation, new classes and other stories of interest relating to our social mission.

You can unsubscribe from these services at any time, by contacting us at info@lingoflamingo.co.uk.

As always, protecting your privacy is a primary concern. This data is kept securely by our Marketing Officer. We will not share your data with any third parties.

9. As a student

When you sign up to join the Lingo Flamingo flock, we ask you for your name and contact details (such as your email) in order to register you as a Lingo student. This data must be collected so that we can process your booking and contact you with necessary information about your courses such as course materials, a zoom link, or start date. These details are kept on file for the duration of your time as a student with us. We keep a record of these details in a secure, password-protected digital drive, monitored by Lingo Flamingo management. We do not share these details with third parties.

Payments for classes that are made online when you book can be done so via PayPal, card or BACS. We retain a record of your details in order to confirm receipt of your payment. We retain these details for the least amount of time necessary to fulfil our legal or regulatory obligations and for our business purposes. If you join the flock via PayPal, your data will be subject to their regulations and policies, which you can read here: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full#2

10. As a partner organisation

If you decide to become our partner through a project, event, or course, we will ask you to provide us with information such as your contact details, information about your organisation (if applicable), website and the nature of your project with us. We process this information so that we can develop the materials and practices that are best suited to the project and your organisation. This information is always kept securely and is not processed for any reason that is not directly related to, or beneficial for your work with us, or in line with our social mission and development as an organisation.

We may retain details about your organisation or the work we have done together for the purposes of funding applications or reports, but all personal information will be anonymised in these instances. We may also retain and process this data for promotional purposes - on our blog, newsletter or social media. We will only share this with your explicit consent and will do so in accordance with GDPR guidelines. This means that personal data will only be shared with consent and within reason (such as first names or photos). Information that is not available through public records (for instance, the name of the organisation or details about the project) will not be shared.

11. The E-Flock: Our Online Portal

When you sign up for the e-flock on our online portal, you will be asked to provide your name, email address and password. This is so we can create a unique student profile for you, with which you will be able to sign up for online courses, contact other students or your tutors and keep track of your progress. These details are stored securely with the data for the site, and will not be shared with third parties. By creating an account on the portal, you consent to the possibility of being contacted by other students on your course either through any group message boards that you join or via the message option on your profile. You also have the option to add a profile photo or ‘about’ section which will be visible to other students on the portal. Adding this information is entirely optional.

As per our values and community guidelines, all interactions through the portal should be respectful and appropriate. Lingo Flamingo has a zero-tolerance policy for offensive, abusive, discriminatory or threatening language or behaviour. If you feel that your right to respect on the platform has been violated, please contact us either directly (info@lingoflamingo.co.uk) or through the 'Help' tab on the portal so that we can resolve the issue.

12. Media and recordings

Lingo Flamingo may make use of media and recordings for various reasons. Media includes photos, videos, or sound recordings.

The platform we use for our online classroom is called Zoom. During online classes, you may wish to turn on your microphone or camera in order to participate in the class. Online classes are recorded using the record function of the Zoom platform for educational purposes only. This is so students can access the lesson if they have missed it, or wish to revise the content. Using the platform means that you consent to and understand the terms and conditions of use. It also means that any data gathered through the use of the platform is subject to Zoom’s privacy policy, which you can find here: https://zoom.us/privacy

Recordings can only be accessed via a secure link, with permission from your tutor. The recordings are deleted by the end of the course duration, in order to protect the privacy of students and tutors.

Lingo Flamingo may take photographs or videos at our events, in line with our core values, social mission and community guidelines, for the purpose of showcasing our services on our social media platforms or website. These photographs or videos will only be used with written consent from those featured in them and will be deleted if this permission is not given. We comply with GDPR guidelines regarding media and its circulation, ensuring the protection of your data and right to privacy. Lingo Flamingo exercises this policy in accordance with our other safeguarding policies, which all staff are required to abide by and receive training in when taking up their role with the organisation.

13. Recruitment

If you apply for a job with Lingo Flamingo, we may ask for your name, contact details, work experience, a covering letter and references. If you are unsuccessful in your application, your details will be kept on file for a period of six months after applying.

If you are successful in your application, this information will be kept in your personnel file for the duration of your employment with the organisation, and for a year afterwards in line with GDPR guidelines. It will be kept and disposed of securely, with the utmost care. If you are successful, we will ask you to complete an Equal Opportunities Monitoring form. This information is anonymous and is used purely to make sure that we are honouring our diversity and inclusion values.

You will also be asked to provide your bank details so that we can add you to payroll. This information will be kept securely by Lingo Flamingo management and we will not share your personal data with any third parties.

14. Volunteers

When signing up as a volunteer for Lingo Flamingo, you will be asked to provide us with your name, contact details and previous experience. As a volunteer, you may be working with our beneficiaries in care homes or day centres. In this case, you will be asked to submit a background check. This serves to protect the people we work with, who may be children, young people or vulnerable adults.

Your data will be kept confidential and will not be shared with any third parties. We will do our best to protect your personal information and will ensure that your privacy is protected at all times.

We will only process your data in order to monitor your time volunteering with us, or in the case of an emergency.

We will retain a copy of your information for up to a year after you have stopped volunteering with us and will dispose of it securely in accordance with GDPR guidelines at this time.

Thank you for taking the time to read our Data Protection Policy! If you have any questions or feedback, please do not hesitate to get in touch.