Privacy Policy

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At the Difficult Airway Society (DAS), we respect the privacy of our members and visitors to our website. We take our duty to process your personal data very seriously. This policy explains how we collect, manage, use and protect your personal information when you visit our website and/or if you’re a contact, member, supplier, corporate partner or attend a DAS event.

The processing of personal data shall always be in line with the General Data Protection Regulation (GDPR), The Data Protection Act 2018, and Privacy and Electronic Communication Regulations (PECR).

We may change this document from time to time to reflect the latest view of what we do with your information. Please check back frequently; you will be able to see if changes have been made by the date it was last updated.
Refer to the sections below for more details on how and why we use your personal information.

1. Who are we?
The Difficult Airway Society was formed in 1995 to advance the public and the medical profession’s understanding of airway management and was aimed at anaesthetists, critical care personnel and allied professions. Membership is open to anyone medically qualified and registered with the GMC or an equivalent overseas body and also non-medically qualified health professionals, such as Operating Department Practitioners (ODPs), nurses and paramedics.
In this policy, references to ‘DAS’, or to ‘we’ or ‘us’, refer to the Difficult Airway Society, which is registered as a charity in England & Wales no. 1071732 at 21 Portland Place, London W1B 1PY.
We are registered as a data controller under registration number:
ZA055141 Difficult Airway Society

2. What personal data we collect and how we use it
The Difficult Airway Society is a ‘controller’ of the personal data you provide to us. We will usually collect basic data about you like your name, postal address, telephone number, and email address when you apply for membership or to attend an event, and your bank details if you pay your membership subscription by Direct Debit.
Sometimes we will collect other information about you such as your gender and date of birth. We will be very clear with you that we wish to collect such information and our reason for collecting such information, and we would only do so with your specific consent and permission.

Why we need it
We collect information depending on the relationship we have with you but typically this would be:

When you apply for or renew your membership
When you purchase products, services, or attend events either online, over the phone, via fax, post or at a DAS event
When you create a registered user account for our website
When you set up a Direct Debit for membership payments
When you engage with us on social media
When you contact us by any means with queries, complaints etc
When you ask one of our team to email you information about a membership or other products and services we offer
When you register for any kind of course or event with us
When you apply for any grants, bursaries or awards
When you choose to complete any surveys we send to you
Photographs and videos of delegates attending our events
If you attend our offices at 21 Portland Place, London W1B 1PY, your image may be recorded on our CCTV cameras that are operated for the security of both visitors and staff

The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our website. However, if you choose to withhold requested information, we may not be able to provide you with certain services.
The personal data we collect may be used for the following purposes depending on the relationship we have with you:

Processing a membership application and ongoing essential membership related processing
Sending you information about the Difficult Airway Society, our activities, and campaigns and for marketing purposes (including via Facebook and other social media channels)
Processing a purchase that you have made
Responding to correspondence you have sent to us

We are committed to ensuring that the information we collect, and use, is appropriate for this purpose, and does not constitute an invasion of your privacy.
The legal basis we use under the General Data Protection Regulation for the processing of personal data:

Fulfilling our contractual obligations to you
Our legitimate interests as the Difficult Airway Society
Your consent
Any legal requirement we may have

Processing to fulfil the membership contract
When you join as a member of the Difficult Airway Society, we use your personal information to provide the services you have paid for and subscribed to for the lifetime of your membership. We will create an online account for you linked to your email address. Data we hold will be used confidentially, and to help us run our services and keep you informed – for example to collect subscriptions, mail out publications, and let you know about conferences and events; or to fulfil legal or regulatory requirements if necessary.
We will use this account to send essential membership communications to you in regards to core member services you have paid for, including member events, and access to voting and other membership benefits and services. Communications will be relevant, timely and not excessive.
The Difficult Airway Society will never sell, trade, rent, exchange or otherwise share your personal information with any other person, company or organisation unless necessary to fulfil our contractual responsibilities, we have a legal obligation to do so, or without gaining consent to do so.

Data security
The information you provide will be held securely by us and/or our data processors, whether the information is in electronic or physical format. We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

Email marketing
In relation to any email marketing that you may receive from us, either at your request or in any other circumstances, we may monitor whether you open and/or click on any links in such emails and we use various tracking techniques to measure the effectiveness of our email campaigns and tailor our communications to your interests. If you no longer wish to receive these emails, you can unsubscribe directly by following the instructions in the relevant communication.
However, there are some communications that we need to send that are essential to fulfil our promises to you as a member, or a buyer of goods or services from the Difficult Airway Society. Examples are:

Transaction messaging such as Direct Debit schedules, purchase confirmations and event booking confirmations
Membership related mailings such as renewal reminders, DAS quarterly newsletter and notice of any Annual Members’ Meeting
Member benefit emails

Building profiles of members
The Difficult Airway Society may make use of profiling and screening methods to produce relevant communications and provide a better experience for our members. Profiling can help us target our resources more effectively through gaining an insight into the background of our members and helping us to build relationships that are appropriate to their interests.
If you do not wish your data to be used in any of the ways listed above or have questions about this, then please email [email protected] or change your preferences within the membership platform.

Volunteering
When you volunteer for DAS, we will keep you up to date with the work that we are doing and events we are involved with. We will also let you know of any changes that might affect you volunteering with us and which you need to be aware of. We will only use this information in relation to your volunteering with us and while you remain a volunteer with us. By agreeing to volunteer, you are agreeing to us sending you emails about volunteering and your volunteer role.

Anything else?
All the personal data we process is processed by our staff in the UK and for the purposes of IT hosting and maintenance is normally situated within the European Economic Area (EEA). On occasions where it is necessary for this to be situated outside of the EEA it will be done in accordance with guidance issued by the Information Commissioner’s Office.
If you would like to change the way you hear from us or no longer wish to receive direct marketing communications then email [email protected] or click the unsubscribe link on the email communication.

3. Legitimate interests
We have a number of lawful reasons that mean we can use (or ‘process’) your personal information. One lawful reason is something called your ‘legitimate interests’. Broadly speaking legitimate interests means we can process your personal information if:

We have a genuine and legitimate reason and
We are not harming any of your rights and interests

When you provide your personal details to us we use your information for our legitimate business interests to carry out our work to promote the advancement of public education in the science and practice of airway management, as well as promote research and the development of new techniques. By doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Direct marketing is generally seen as an important tool, but we want to respect the wishes of recipients of our marketing. For this reason we have undertaken a balancing test to compare our legitimate interests versus your interests and fundamental rights and freedoms, which require the protection of your personal data. We believe that the recipients of our marketing have a reasonable expectation that DAS will store and process their personal data in this manner.
We will also hold information about you so that we can respect your preferences for being contacted by us.

4. Processing using consent
There are certain circumstances, particularly in regard to electronic marketing communications where we may need consent from you, in order to process your data. If this is the case we will ensure that the consent you provide is by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the processing of personal data relating to you.
The Difficult Airway Society is monitoring future developments in EU electronic marketing regulation presently being debated and subject to change.

5. Sharing your information
We only disclose information to third parties or individuals when obliged to by law, for purposes of national security, taxation, criminal investigations, professional regulatory body investigations and the following:

When we use other companies to provide services on our behalf e.g. mailing or delivering orders, sending mail and emails, providing access to apps, customer analysis, assessment and profiling, when using auditors/advisors or processing credit/debit card payments
If we receive a complaint about any content you have posted or transmitted to or from one of our sites, to enforce or apply our terms and conditions or if we believe that we need to do so to protect and defend the rights, property or personal safety of the Difficult Airway Society, our websites or our visitors or for other lawful purposes
We may disclose aggregate statistics about our site visitors, members, customers and sales to describe our services and operations to prospective partners and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information
If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register

We will never sell or rent your personal information to other organisations.
The Difficult Airway Society will share your personal data with third parties only for the purposes of essential sub-contracted processing. We will seek assurances that these contractors/processors have in place appropriate technical and organisational measures to safeguard the security of your data.

6. Retaining your information
We hold your information only as long as necessary for each purpose we use it. This section will be updated with some examples of retention periods shortly.

7. Your details on the web: our cookie policy
We use web analytics tools provided by service partners such as Google Analytics to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our services. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.
Our cookies help us:

Make our website work as you’d expect
Remember your settings during and between visits
Improve the speed/security of the site
Continuously improve our website for you
Granting us permission to use cookies

Each cookie cannot be used by anyone other than the service provider (eg: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies.

8. Your privacy rights explained
At any point while we are in possession of or processing your personal data, you, the data subject have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you free of charge
Right of rectification – you have the right to correct data that we hold about you that is inaccurate or incomplete
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing
Right of portability – you have the right to have the data we hold about you transferred to another organisation
Right to object – you have the right to object to certain types of processing such as direct marketing
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling

9. Other websites
On occasion our website will contain links to other websites. This privacy policy only applies to the Difficult Airway Society’s website. When you link to other websites you should read their own privacy policies.

10. DAS Airway Alert Card
DAS maintains a database of adult patients with difficult airways and issues airway alert cards to these patients upon their explicit consent to participate in the project. To provide this service we collect your personal and medical data, which is provided to us by your anaesthetist who obtained consent from you.

What personal data we collect and how we use it
The Difficult Airway Society is a ‘controller’ of the personal data for the DAS Airway Alert Card project. We usually collect basic data about you like your name, postal address, telephone number, email address and demographic details like age, sex, height and weight, along with background medical data (like your comorbidities) and medical data pertaining to the airway incident.

Why we need it
The information is either needed to fulfil your request or to enable us to:

Provide you with an airway alert card
Have your record in the difficult airway database
Respond to correspondence you have sent to us

Fulfilling our contractual obligations to you
Our legitimate interests as the Difficult Airway Society
Your consent
Any legal requirement we may have

What information is available and who can access it
The Difficult Airway Database will be available 24/7 from our website in order for it to be useful during medical emergencies.

None of the information will be available publicly
Only health professionals who have registered with the website can access the database
No patient identifiable information (PII) like your name, address of other contact details are available on the database
Health professionals will only be able to look for patients using the ‘Unique Access Code’ or the patient’s NHS number

Who can access the person identifiable information and where is it held?

PII is not stored on the database
PII is stored separately on an offline computer and is accessible only to DAS administrators/officials involved in the DAS Airway Alert Card project
DAS does not share this information with other organisations

11. Changes to our privacy policy
We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 2nd October 2024.

12. How to contact us in regards to your rights, or to make a complaint
In the event that you wish to make a complaint in regards to how your personal data is being processed by the Difficult Airway Society, please contact our data protection representative. If you are unhappy with how your complaint has been handled you have the right to lodge a complaint directly with the ICO.
Data Protection Representative
DAS Secretariat, 21 Portland Place London W1B 1PY
Email: [email protected]
Telephone: +44 (0)20 7631 8899

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