Privacy Policy

In this policy the following terms have the following meanings:

Account

An account required to access and/or use certain areas and features of Our Site.

Cookie

A small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the cookies used by Our Site are set out in section 12 below.

Our Site

This website, definingdyslexia.org.

UK and EU Cookie Law

The relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015.

We / Us / Our

Defining Dyslexia and any associates.

Our Site, definingdyslexia.org, is operated by Mark Wilson.

We are a member of PATOSS, found at www.patoss-dyslexia.org.

I am an independent specialist dyslexia teacher who advertises services as Defining Dyslexia. I offer diagnostic assessments, tuition and services for pupils, parents and schools.

Defining Dyslexia understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

Defining Dyslexia is registered with the Information Commissioner’s Office (ICO).

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of cookies); other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5. Depending on your use of Our Site, We may collect some or all of the following data:

• Name
• Business/company name (where you contact Us in a professional capacity)
• Job title
• Profession
• Contact information such as email addresses and telephone numbers
• Demographic information such as postcode, preferences and interests
• IP address (automatically collected)
• Web browser type and version (automatically collected)
• Operating system (automatically collected)
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

We do not hold any financial information such as credit or debit card numbers.

All personal data is stored securely in accordance with the UK and EU General Data Protection Regulation (GDPR). For more details on security, see section 6 below.

We use your data to provide the best possible services to you. This includes:

• Providing and managing your access to Our Site
• Personalising and tailoring your experience on Our Site
• Supplying Our services to you
• Personalising and tailoring Our services for you
• Responding to communications from you
• Supplying you with email, for example newsletters and alerts, that you have subscribed to. You may unsubscribe or opt out at any time by emailing definingdyslexia@outlook.com
• Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience

In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.

With your permission and/or where permitted by law, We may also use your data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

Our lawful bases for processing

Under GDPR we will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

• You have given consent to the processing of your personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is necessary to protect the vital interests of you or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Signing up to be a member or a partner is considered a legitimate interest.

We only keep your data for as long as We need to in order to use it as described in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. We retain your data:

• For two years, if you contacted us for support;
• Indefinitely, if you subscribed for email and marketing. If you unsubscribe we keep your data to ensure you remain unsubscribed. You can request to have all your data deleted completely at any time by emailing definingdyslexia@outlook.com;
• Up to two years after the partnership ends, if you contacted us for legitimate interest or you are a partner.

Website, enquiry and practice-management data is stored within the United Kingdom or the European Economic Area (the EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein), other than the limited exceptions described below.

There are two situations in which information may be processed outside the UK and the EEA. The first is payment processing, where a payment provider may process information internationally under its own stated safeguards (see section 8). The second is the online scoring of one particular standardised test (see section 9). Where UK personal information is transferred internationally, an appropriate transfer mechanism and contractual safeguard must apply.

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. Steps We take to secure and protect your data include:

• Limiting who can access your data by using passwords for the platforms and software where your data is stored;
• Using password protected computers.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to Us via the internet.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required by any legally binding request that is made of Us.

If our business changes hands

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

Assessment and service fees can be paid by bank transfer, by GoCardless, or by PayPal. Payment providers receive payment information only. They do not receive assessment reports, test protocols, detailed assessment scores or background histories.

PayPal

PayPal is offered as an optional payment method. Where you choose it, PayPal processes payment and transaction information. This may include the payer’s name, contact information, billing information, the payment amount, transaction details, device information and information needed for fraud prevention or regulatory compliance.

We do not receive or store your complete PayPal password or your full card credentials. We may retain the payment amount, the payment status, the transaction reference, payer details and the associated invoice or accounting record.

PayPal operates under its own privacy notice and legal obligations. PayPal and Defining Dyslexia may each act as an independent data controller for the information each processes for its respective payment, accounting, fraud-prevention and regulatory purposes. PayPal may process information internationally, and states that it uses recognised transfer safeguards, which may include Binding Corporate Rules, adequacy arrangements, Standard Contractual Clauses, the UK International Data Transfer Agreement or the UK Addendum, as applicable. See the PayPal UK Privacy Statement.

GoCardless

GoCardless is used for relevant payment arrangements. Where that payment method is selected, GoCardless processes payment information. This may include the payer’s name, contact details, bank-account information, payment mandates, the payment amount, transaction status, device information and information required for fraud prevention, verification or regulatory compliance.

We do not need to store your complete bank credentials. We may retain mandate status, payment status, transaction references, invoices and accounting records.

GoCardless operates under its own privacy notice and financial-services obligations, and may act as an independent controller for some payment-processing activities. GoCardless states that its main processing for European payments takes place on servers in the European Economic Area, and that it also uses selected suppliers that may process limited information outside the EEA subject to appropriate safeguards. See the GoCardless privacy notice and its GDPR information.

Bank transfer

Where you choose bank transfer, your bank and our bank process the transaction. Bank statements may show the payer’s name, account reference, amount and transaction information. Relevant payment and accounting records are retained as required for business, tax and legal purposes. Complete assessment reports are not supplied to a bank as part of the payment process.

Keeping payment information separate from assessment information

Payment providers receive only the information needed to create or process the payment, to identify the relevant client or invoice, to confirm payment status, to prevent fraud and to meet their own regulatory obligations. Diagnostic reports, test protocols, detailed assessment scores and unnecessary information about a person’s disability are not sent to a payment provider. Neutral invoice and payment descriptions are used where practical, and unnecessary diagnostic information is not placed in a payment reference.

Payment options are set out on the payment page.

Most assessment activities are administered and scored manually by Mark. One test is different. The Tests of Dyslexia, or TOD, uses the online system provided by its publisher, Western Psychological Services (WPS), for authorised scoring and report generation. That system is referred to as WPS Hub or the WPS Online Evaluation System, and it is unrelated to the office-software product of a similar name.

Use of the WPS platform is limited to the testing and scoring functions required for the TOD. WPS may process identifiable information and testing data entered into its platform. Depending on how the assessment record is created, that may include a client identifier, name, date of birth, age, demographic information, administration information, test responses, scores and generated results.

WPS does not receive every document held by Defining Dyslexia simply because its scoring system is used. Full background forms, unrelated reports, payment information and complete practice-management records are not uploaded to WPS unless genuinely required for the TOD and permitted by the relevant agreement. Defining Dyslexia remains responsible for deciding why your information is submitted for scoring.

WPS generally acts as a data processor or assessment-service provider for the assessor, although its privacy policy describes limited situations in which it may act as a controller for its own purposes.

Information processed in the United States

When the Tests of Dyslexia is used, limited client and testing information is entered into the WPS online scoring system. Western Psychological Services is based in the United States and states that information may be transferred to and processed there. We use the platform only for the authorised administration, scoring and reporting functions required for that assessment. Where UK personal information is transferred internationally, an appropriate transfer mechanism and contractual safeguard must apply.

WPS states that UK and EU data arrangements may include contracts, Data Processing Addenda and Standard Contractual Clauses where appropriate, and that it does not use automated decision-making in processing personal information. See the WPS platform privacy policy and the WPS privacy policy.

Scoring is not diagnosis

Some standardised assessment scores are calculated using authorised publisher software. These calculated results form only part of the evidence considered. No software system makes the final diagnostic decision. The assessment findings and any diagnostic conclusion are determined by the qualified assessor using professional judgement and the complete assessment information.

Before TOD information is entered into the system, the client, or the appropriate parent or responsible adult, is told that publisher software is used for scoring this test, that limited identifiable and assessment information may be processed in the United States, that the software calculates standardised results but does not make the diagnostic decision, that the final professional interpretation is completed by Mark, and that they can ask for more information about the system and the relevant safeguards.

The providers below support the running of the practice. Each receives only the information it needs for its own purpose. A provider is listed here only where it is genuinely in use.

• WriteUpp

  Purpose

  Practice management and client records

  Information

  Contact details, appointments, forms, communications, assessment records, reports and administration

  Location

  Published hosting for UK and European accounts is Dublin and Amsterdam

  Role

  Processor for client information entered by Defining Dyslexia

• Microsoft 365 / Outlook

  Purpose

  Email, calendar, documents and business communication

  Information

  Contact details, correspondence, appointments and documents sent through Microsoft services

  Location

  As set out in the configured service and the applicable Microsoft terms

  Role

  Processor for business communication and documents

• Cal.com

  Purpose

  Optional telephone-call booking (Cal)

  Information

  Name, contact details, booking time, time zone and limited booking notes

  Location

  As set out in the current account configuration and provider terms

  Role

  Processor for booking information submitted through the booking page

• PayPal

  Purpose

  Optional payment processing

  Information

  Payer, transaction, billing and fraud-prevention information

  Location

  International processing may occur under PayPal's stated safeguards

  Role

  PayPal and the merchant may each act as independent controllers for their respective purposes

• GoCardless

  Purpose

  Payment mandates and payment processing

  Information

  Payer, bank, mandate, transaction, verification and fraud-prevention information

  Location

  Main European payment processing in the EEA, with possible international supplier processing under safeguards

  Role

  May act as an independent controller for relevant payment activities

• Western Psychological Services (WPS Hub / Online Evaluation System)

  Purpose

  Authorised Tests of Dyslexia administration, scoring and output

  Information

  Limited client identifiers, demographic information, test administration data, responses, scores and results

  Location

  Information may be transferred to and processed in the United States

  Role

  Generally a processor or assessment-service provider, with the limited separate controller activities described in the WPS policy

• Website hosting and enquiry-form provider

  Purpose

  Website hosting, security and delivery of enquiries

  Information

  Technical connection data and information submitted through the enquiry form

  Location

  As set out in the provider terms for the live implementation

  Role

  Processor for enquiry messages sent to us through this website

When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data, including the ability to opt out of receiving emails from Us, which you may do by unsubscribing using the links provided in Our emails and by stating your contact preferences at the point of providing your details.

You may also wish to sign up to one or more of the preference services operating in the UK: the Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

Withholding information, and withdrawing it after you have given it

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict your internet browser’s use of cookies, see section 12.

You may withdraw your consent for Us to use your personal data as set out in section 5 at any time by contacting Us using the details in section 15, and We will delete your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.

Accessing your data

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact us at definingdyslexia@outlook.com or using the contact details in section 15.

Our Site may place and access certain first-party cookies on your computer or device. First-party cookies are those placed directly by Us and are used only by Us. We use cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using Our Site you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services and/or parties other than Us. These cookies are not integral to the functioning of Our Site.

All cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.

Before cookies are placed on your computer or device, you will be shown a message requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of Our Site may not function fully or as intended.

Certain features of Our Site depend on cookies to function. UK and EU Cookie Law deems these cookies to be “strictly necessary”. Your consent will not be sought to place these cookies. You may still block them by changing your internet browser’s settings, but please be aware that Our Site may not work as intended if you do so.

You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies but this can be changed. You can also choose to delete cookies at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently. It is recommended that you keep your internet browser and operating system up to date and that you consult the guidance provided by the developer of your browser if you are unsure about adjusting your privacy settings.

Under the GDPR, you have:

• The right to request access to, deletion of, or correction of your personal data held by Us;
• The right to complain to a supervisory authority;
• The right to be informed of what data processing is taking place;
• The right to restrict processing;
• The right to data portability;
• The right to object to the processing of your personal data;
• Rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights, or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details in section 15 below. You also have the right to complain to the Information Commissioner’s Office.

In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant) effect on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from Us.

That right does not apply in the following circumstances:

• The decision is necessary for the entry into, or performance of, a contract between you and Us;
• The decision is authorised by law, or you have given your explicit consent.

Where We use your personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;
• Appropriate mathematical or statistical procedures will be used;
• Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

We currently profile your personal data only if you are a volunteer who has sent us your CV to volunteer with us.

Computer-assisted scoring is not automated decision-making

Some standardised assessment scores are calculated using authorised publisher software, as described in section 9. These calculated results form only part of the evidence considered. No software system makes the final diagnostic decision. The assessment findings and any diagnostic conclusion are determined by the qualified assessor using professional judgement and the complete assessment information.

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at definingdyslexia@outlook.com. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

Assessment and service enquiries are usually answered fastest at mark@definingdyslexia.org, or through the contact page.

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.