The Speak Out project is being delivered through a partnership between the Early Intervention Foundation, the Race Equality Foundation and Action for Children. This document reflects the data sharing agreements between all parties involved in the work.

1. Introduction

The Early Intervention Foundation (EIF) is working together with Clear View Research and Action for Children (the ‘collaborators’) to conduct research for a project called Speak Out: You and Your Family’s Experiences of Seeking Family Support (the ‘Project’). The purpose of this privacy notice is to explain what personal data we will collect about you for this project. It is likely you are being made aware of this privacy notice through your voluntary participation in the project or at the point you are deciding to volunteer to participate.

The Collaborators have asked the Race Equality Foundation, Break Comms and Phonic AI to perform a number of tasks on our behalf. All these parties will be processing your personal data to fulfil the project aim of understanding the priorities and experiences of minority ethnic families in relation to family support.

Before you take part in this project, you will be asked to give your permission to participate. You are also able to remove your permission at any time. If you do decide you no longer wish to participate, let us know as soon as you can. We will remove your personal data from any locations we hold your data and make any information you have provided to us anonymous. We will do this as soon as we can. If the analysis of the information has already started, we will not be able to remove your information straightaway but will do so once that phase of the project is complete. We will then inform you once we have done this.

Please read this privacy notice carefully as it provides important information about how we handle your personal information and your rights. If you have any questions about any aspect of this privacy notice you can contact us using the information provided below or by emailing us at datasecurity@eif.org.uk quoting “Speak Out” in the subject or body of the email.

2. Personal data we collect

Personal data is any information that relates to a person (a ‘data subject) which can be identified either directly or indirectly. For this Project, we shall be processing the data from different categories of data subject (people). These are children, and parents, legal guardians, and carers. The types of personal data we will collect from you is listed below:

• Your name
• Your email address
• Your age
• Your gender
• Your ethnicity
• Photographs/videos/audio recordings of you
• Your sexual orientation
• Whether you have a disability
• Whether English is an additional language
• Whether you have experienced any instances of harm
• Any information you disclose within a recorded interview
• Your sentiments/emotional responses
• Your religious or philosophical beliefs (parents, legal guardians, and carers only)
• Information about whether you have children or other dependents (parents, legal guardians, and carers only)

3. How we collect information about you

We will collect your data directly from you. You may provide this information to us or our partners through taking part in one or more of the project activities. These activities include online or telephone interviews, online focus groups and an online survey, which includes options for allowing you to video or voice record your responses.

We may also collect data indirectly from the technology used in the survey platform which uses automated systems to judge if your responses are mostly positive or negative.

4. Purposes for which we use personal data and the legal basis

We may use your personal data for the following purposes and on the following lawful bases.

4.1 Purpose	4.2 Lawful basis for processing
To conduct the Project based on the data you have provided.	Processing is necessary for the performance of a task carried out in the public interest.
For the goal of the Project which is to investigate the wide disparities in child protection rates between ethnic categories and understand the priorities and experiences of minority ethnic children and families in relation to family support.	Processing is necessary for the performance of a task carried out in the public interest.
For the Collaborators to analyse the information in the survey you have voluntarily completed and the information you have provided within an interview or focus group.	Processing is necessary for the performance of a task carried out in the public interest.
For the Collaborators to collect ethical informed consent for participation in the research (you can withdraw this consent at any time and where possible the Collaborators will delete your data).	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
For the Collaborators to contact you to participate in an interview or focus group.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
To transcribe the audio captured from any recorded interviews, focus groups and recordings within the survey platform.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
To translate any of your responses within the survey platform which are in a language other than English.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
To understand your emotional disposition from the recordings within the survey platform where you have recorded an answer (this is known as “sentiment analysis”).	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
To identify your data, which would be deleted where possible, should you no longer agree to have your data processed for the purpose of conducting the research report.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Collaborators”).
For EIF to use your personal data to inform the creation of potential “new” projects that are substantially similar to, and compatible with the original reason for collecting your personal data, although not use your data in any new projects that come as a result of using your personal data without asking for permission to do so from you and receiving a response from you confirming you give your permission for participation.	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“EIF”).
For EIF to contact you to ask if you would like to participate in any new projects as a participant (you can opt out anytime).	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“EIF”).
For Action for Children to conduct further analysis around the geographies/locations of Project participants (you) after the Project has completed and at their discretion. (NOTE: Action for Children will only be provided the personal data of Project participants that were originally contacted by Action for Children for participation and no other participants).	The lawful basis we shall be relying on is the legitimate interest of the Data Controller (“Action for Children”).
For the processing of Special Category personal data in the research as specified by the UK GDPR.	Processing is necessary for archiving, research and statics under UK GDPR Article 9.2(j).

5. Sharing your data

Your personal data will be processed in the United Kingdom (UK), the European Economic Area (EEA) and for the survey only, in the United States of America. We have entered into the relevant legal mechanism for cross-border transfers outside the UK and EEA. In this case we have entered into an International Data Transfer Agreement (IDTA) with our survey provider.

Any data shared with the below categories of recipients is the minimum necessary for the task they have been instructed to carry out:

1. Research partners (“Collaborators”)
2. Pre-approved transcription vendors
3. Pre-approved online survey platform providers
4. Pre-approved translation vendors

There may be times where we have a legal obligation to disclose or share your personal data. This could include sharing your data with law enforcement agencies, regulatory bodies, or public authorities to prevent or detect crime or report a safeguarding concern. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.

6. How long we keep your data

We will take steps to ensure we only keep the minimum amount of data possible throughout the Project. Where we need to retain your personal data for the purposes of subsequent Project reviews or analysis, we shall keep your information for 2 years after the completion of the final output from this project (this may be a report or other method of presenting the findings). This is scheduled for March 2022.

Any subsequent use of Project data by EIF for the development of similar projects will also have all data deleted 2 years after the final outputs of the original Project for which it was collected (March 2022).

Any subsequent use of Project data by Action for Children will only be Project data developed from the personal data of any data subjects Action for Children already owns and who volunteered to participate. This data will be deleted at Action for Children’s discretion in line with the reason for Action for Children’s original collection of the participant’s data which can be found on Action for Children’s website.

All processors working on behalf of the Collaborators will delete their data in line with or before the dates outlined above.

7. How we protect your data

There are appropriate technical and organisational measures in place to protect data that we process from unauthorised disclosure, use, alteration, or destruction. We conduct data protection assessments for each research project we conduct.

Your information is securely stored on dedicated secure access drives by all Collaborators, and access is controlled by Data Protection Policies, Information Security Policies and Access Control Policies or similar, by each Collaborator for the duration of the research study period.

Collaborators will always keep these under review to make sure that the measures they have implemented remain appropriate.

If you make video recordings within the survey, this will be automatically analysed to decide how positive or negative you are about the information you provide. This is done by analysing your facial muscle movements in real-time.

8. Your rights and options

You have the following rights in respect of your personal data:

• You have the right of access to your personal data and can request copies of it and information about our processing of it.
• If the personal data we hold about you is incorrect or incomplete, you can ask us to rectify or add to it.
• Where we are using your personal data with your consent, you can withdraw your consent at any time.
• Where we are using your personal information because it is in our legitimate interests to do so, you can object to us using it this way. You can ask us to restrict the use of your personal data if:
  • It is not accurate,
  • It has been used unlawfully but you do not want us to delete it, or
  • If you have already asked us to stop using your data but you are waiting to receive confirmation from us as to whether we can comply with your request.

You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, please contact us at datasecurity@eif.org.uk

9. How to complain

You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://ico.org.uk/concerns/

10. Contact us

If you have any questions, or wish to exercise any of your rights, then you can contact:

Project: Speak Out
Organisation: Early Intervention Foundation
Address: The Evidence Quarter, Albany House, Westminster, London, SW1H 9EA

Alternatively, you can email us at datasecurity@eif.org.uk

11. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify you of the changes where required by applicable law to do so.

Last modified 12 January 2022