Privacy Policy
Protecting your privacy
We understand that you care about how information about you and/or the child being assessed is used and we recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information.
This Policy explains how we collect and manage your personal information. In this Policy, “The Austin Assessment”, “we”, “our”, “us” refers to The Austin McDowell Foundation (charity services number CC60616).
What is your personal information?
In general terms, personal information is any information that can be used to identify you and/or the child being assessed. This may include your name, address, telephone number and email address. If any of the information we collect from you identifies you and/or the child being assessed, or is reasonably capable of identifying you and/or the child being assessed, then it will be considered personal information.
What personal information do we collect and hold?
We may collect the following types of personal information from yourself or for the child being assessed:
- Full name
- Email address
- Age
- Relevant health/developmental conditions (i.e. cerebral palsy, autism)
- Data gained through the Austin Assessment (i.e. eye movement data - the app detects eye movement and calculates where we believe the users are looking on the screen. This information is stored as a set of coordinates over time).
- Payment information where we manage your payments. Where your payment is done through Apple or another alternative platform, we do not receive or hold that payment information.
Please note: We are not collecting any biometrics or face data. The app detects eye movement and we are interpreting this data and storing the results.
How we collect personal information
We collect personal information through the use of the Austin Assessment Apps.
- For the personal app, this information is provided by yourself or by a parent/caregiver for their child.
- For the professional app, this information is obtained from the child being assessed by the person administering the assessment. Please note: Consent must be obtained from a parent/caregiver to conduct an assessment on a child beforehand. This consent process (third party consent) needs to be completed outside of the app in line with your organisation's guidelines and processes.
Cookies
Our website uses Google Analytics to collect anonymous user data. This helps us understand how visitors engage with our website. This allows us to:
- Improve our website (for example, identify and promote popular pages); and
- Provide you with more targeted information (where appropriate).
You can opt out of Google Analytics without affecting how you visit our site. Optionally, your browser can delete or block third party cookies.
What happens if we can't collect your personal information?
Whether or not you provide personal information to us is entirely up to you. If you do not provide us with the personal information described above, the results of the Austin Assessment may not be accurate. For instance;
- If the age of the child being assessed is not inputted into the app, the app will not be able to determine whether the child’s performance on the Austin Assessment met a threshold in their age group for further assessment.
- If a name of the child being assessed (or distinct identification code) is not provided for each individual assessment, it will be difficult to distinguish between each assessment and connect them with a specific child.
For what purposes do we collect, hold and use your and/or the child's personal information?
We collect, hold and use personal information for the following primary purposes:
- We collect eye movement data and use this information to determine if a child meets the threshold for a potential cerebral visual impairment (CVI).
- For the ongoing development of the Austin Assessment app
- To regularly review the normative ranges and thresholds for the assessment variables to ensure they are accurate
- To understand the impact of specific health or developmental conditions on assessment results
- Ongoing research into CVI (CVI screening and assessment, supporting children with CVI). Where the information we have collected is being used for further research purposes, it will not be published in a form that will identify you or the child.
How do we store the information?
Your and/or the child’s personal information will be stored with Google Cloud platform, which is located in the US across three different locations. This is a cloud based service and Google will not have access to or be able to use the data that is stored on its systems for its own purposes.
We will remain responsible for all personal information that we store on the Google Cloud platform.
Who has access to your and/or the child’s personal information and who may we disclose it to?
Access
Employees of the Austin McDowell Foundation will have access to your and/or the child’s personal information whether you use the personal or professional app.
For the professional app, your and/or the child’s personal information will be accessed by those approved within the organisation that administered the test; however, they will only have access to test data conducted within that organisation (i.e. other organisations who also use the Austin Assessment will not be able to access your and/or the child’s personal information). If you have any concerns about who may be able to access information within the organisation that administered the app, you will need to contact them directly.
Who may we disclose it to?
It may be necessary for your personal information to be shown to our professional advisors, auditors and insurers from time to time to ensure that we meet our legal and ethical obligations.
We may also disclose personal information to a third party where your and/or the child’s personal information is not identifiable.
We will take all reasonable steps to ensure that the information is protected against loss, access, use, modification, disclosure or any other misuse.
How long do we store the information for?
One of the Austin McDowell Foundation’s aims is to support children with CVI and we are committed to ongoing research to enable us to do this.
In light of this, we will keep personal information, in particular:
- Age (month and year of birth but not actual date of birth)
- Relevant health/developmental conditions (i.e. cerebral palsy, autism)
- Data gained through the Austin Assessment (i.e. eye tracking data),
in perpetuity for data collection and trend over time.
How can you access and correct your and/or the child’s personal information?
We require accurate personal information about you and/or the child being assessed to ensure the results of the Austin Assessment are as accurate as possible. You may request access to any personal information we hold about you at any time by contacting us (see the details below).
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, if it would result in a breach of confidentiality, where the information is not readily retrievable or where the request is frivolous, vexatious or the information requested is trivial. If that happens, we will give you written reasons for any refusal within 20 days of you making the request.
If we are able to provide you with the information requested and you believe that your and/or the child’s personal information is not correct, you may request in writing that we correct the information (see the details below).
We store your personal information securely
We take reasonable steps to ensure we protect any personal information that we hold from misuse, loss and unauthorised access, modification and disclosure.
How to stop the further collection of information
You may withdraw your consent for the collection of this information at any time, by deleting your account using the feature provided in the app.
How to remove personal information
When you delete your account, any personally identifying information that we hold about you is removed.
Privacy Officers
If you are concerned about any possible interference with your and/or the child’s privacy, or would like to request access to personal information, please contact our Privacy Officer:
Dr Nicola McDowell
Founder and CEO Austin McDowell Foundation
privacy@austinassessment.org
Protection of information where a request for access is made
In the event that a request is made to access any personal information that we hold about you, efforts will be made to copy or preserve the information until the request has been dealt with and disposed of and, in particular, we will endeavour to retain information for at least three (3) months after we respond to your request to allow anyone who has requested disclosure to review our decision with the Privacy Commissioner.
How to make a complaint
If you feel we have failed to deal with your complaint in a satisfactory way you can make a complaint about the handling of your personal information to the Office of the Privacy Commissioner. More information can be found at www.privacy.org.nz.
Changes to this privacy policy
We may occasionally update this policy without notice to you to ensure that it remains current with New Zealand’s applicable laws. We encourage you to check this policy regularly so that you are aware of any changes.