Privacy Policy

Background

Your Voice is an NHS-wide opportunity for an open conversation for all maternity and neonatal staff to help shape real and sustainable change in services. It builds on feedback from more than 9,000 staff members who contributed their views to the Independent National Maternity and Neonatal Investigation, focusing on turning recommendations into action.

This privacy policy explains how personal data is collected, stored and used when you register your interest in Your Voice at yourvoice.clevertogether.com and when you participate in the online conversation.

Who is responsible for your data?

NHS England is the data controller for Your Voice. As data controller, NHS England determines the purpose and means of processing your personal data and is registered with the Information Commissioner's Office (ICO).

Clever Together Lab Limited acts as data processor on behalf of NHS England, providing the technology platform and analytical services that power the Your Voice registration and online conversation.

Clever Together will not use your data for any purpose other than the delivery of this initiative and will act only on instructions from NHS England.

What data do we collect?

When you register your interest via this website, we collect the following information:

• Your organisation — the NHS Trust or body you currently work for
• Your role type — whether your role is primarily clinical or primarily administrative, clinical support or management/leadership
• Your job title
• Your region — the NHS England region in which you work
• Your responses to four baseline statements rated on a 0–5 scale, relating to:
  • Agency — your sense of ability to influence positive change in maternity services
  • Trust — your confidence that people like you will be listened to
  • Hope — your belief that maternity services can improve significantly
  • Pride — your sense of pride in being part of maternity and neonatal services
• Your email address
• Your consent to receive updates about Your Voice
• When first entering the conversation, we will also ask you some demographic questions about your ethnicity, gender, disability status. We use this data to understand how representative the conversation is, and to ensure that the unique views of minority groups are noticed and represented. You do not have to provide this information to take part, and will have the option of ‘Prefer not to say’.

We do not collect medical records, financial information, or any data unrelated to your participation in this initiative.

How do we use your data?

Your data is used for the following purposes:

1. Communication. To send you updates about Your Voice, invitations to participate in the national online conversation, and information about how the process will work, where you consent for us to contact you.
2. Analysis. To understand the baseline conditions for change across the maternity and neonatal workforce — including how experiences of agency, trust, hope and pride vary across roles, organisations and regions — before and after the national conversation takes place.
3. Authentication. To ensure that participation in the national online conversation is limited to registered participants.
4. Support. To assist you with any difficulties in accessing or participating in the conversation.

Aggregated, anonymised findings from the baseline questions will be published as part of Your Voice reporting. No individual responses will ever be attributed to a named person in any published findings.

During the conversation, comments will appear anonymously in the conversation feed. However, comments are linked to your registered account so that Clever Together can provide technical support, moderate the conversation, analyse contributions appropriately, and apply the safeguards described in this policy.

When reporting findings to NHS England and provider trusts, Clever Together will share aggregated and anonymised insights only. This may include themes, trends and summaries by organisation, region or role type, but not personal data that identifies who made a contribution. Comments will not be shared with NHS England or provider trusts with identifying details attached, and reporting will not be produced for any group smaller than 11 people. The only exceptions are contributions where a serious crime has been committed, where there are serious risks to individuals, the public or staff, or where disclosure is necessary to protect children or vulnerable adults.

As part of Your Voice, no automated decisions will be taken about any individual based on data we hold or process.

Who do we share your data with?

Your personal data is shared with Clever Together Lab Limited, acting as data processor on behalf of NHS England. Clever Together processes your data solely to deliver Your Voice and does not process or share it with any other third parties for commercial or other purposes.

Your data will not be sold, rented or disclosed to any other organisation, except where required by law.

Further information about what is shared with NHS England and provider trusts is set out earlier in this policy under “How do we use your data?”.

What is the lawful basis for processing your data?

NHS England processes your data under the following lawful bases as set out in the UK General Data Protection Regulation (UK GDPR):

• Public task (Article 6(1)(e)) — the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, specifically the national effort to support improvement in maternity and neonatal services across England and inform the National Maternity and Neonatal Taskforce’s action plan.
• Consent (Article 6(1)(a)) — your explicit consent is obtained before you are added to the Your Voice mailing list. You may withdraw this consent at any time.

To withdraw your consent or unsubscribe from communications at any time, simply email privacy@clevertogether.com with the subject line YOUR VOICE UNSUBSCRIBE or click on the unsubscribe link in any of the emails you receive.

How is your data stored and protected?

Your data is securely stored using industry standard security measures and policies. These include technical measures like encryption and organisational policies such as role based data access. Clever Together's application servers are hosted in Ireland on Amazon Web Services infrastructure, which operates in compliance with UK GDPR requirements. Personal data will also be processed by authorised personnel located in France for the purposes of delivering and supporting the Your Voice service, in adherence with UK GDPR requirements.

All systems are regularly updated to ensure they meet and exceed industry standards for data security. Access to personal data is strictly limited to authorised personnel involved in delivering Your Voice.

How long do we keep your data?

Your personal data will be retained for the duration of Your Voice and for no longer than 3 months after the conclusion of the national conversation. Your data will then be securely and permanently deleted.

Anonymised, aggregated data — which cannot identify you individually — may be retained beyond this period for research, reporting and improvement purposes. Clever Together will not retain any personal data, or anonymised outputs, for any longer than 12 months after the closure of Your Voice.

Cookies

The Your Voice website uses only essential functional cookies required for basic site operation — for example, to maintain your session. We do not use tracking cookies, advertising cookies, or any cookies that monitor your behaviour on other websites.

You can set your browser to refuse cookies, though this may affect the functionality of some parts of the site. For more information about cookies, visit allaboutcookies.org.

Your rights as a data subject

While NHS England holds or processes your personal data, you have the following rights under UK GDPR:

• Right of access — you may request a copy of the personal data we hold about you.
• Right of rectification — you may request that inaccurate or incomplete data is corrected.
• Right to erasure — in certain circumstances you may request that your personal data is deleted from our records.
• Right to restriction of processing — you may request that we limit how your data is used.
• Right to data portability — in certain circumstances you may request that your data is transferred to another organisation.
• Right to object — you may object to certain types of processing, including direct marketing.
• Right to object to automated processing — you have the right not to be subject to decisions based solely on automated processing that significantly affect you.

To exercise any of these rights, please contact Clever Together or NHS England using the details below.

Changes to this policy

This privacy policy will be reviewed and updated as Your Voice develops. The date of the most recent update is shown at the top of this page. Any significant changes to this policy will be notified via email to people who have registered in the process.

How to make a complaint

If you feel that your personal data has not been handled appropriately, or you wish to make a formal complaint, you can contact our DPO using the details above. If our DPO is not able to resolve your data protection complaint, you have the right to contact the UK's Information Commissioner's Office (ICO):

• Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• Website: ico.org.uk
• Telephone: 0303 123 1113