RPS Privacy Policy

Version 2.7 (updated March 2023)

Welcome to the Royal Pharmaceutical Society’s Privacy Policy.

RPS respect your privacy and are committed to protecting your personal data. This privacy policy will inform you of how we look after your personal data when you visit our website (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

1. Important Information

Purpose of this privacy notice

This privacy notice aims to give you information on how the Royal Pharmaceutical Society collect and process your personal data through your use of this website including:

• When you browse our website
• When you log in to our members only section of the website
• When you upload content to any of our third-party platforms (please see glossary for specific third party details)
• When you use any of the RPS apps
• When you sign up as an RPS member
• When you interact with any RPS staff or workers
• When you respond to RPS regarding a consultation about pharmacy standards or professional practice
• When you apply for a job at RPS
• When you book an RPS event, call our support line or use any of our products and services
• When you act as a collaborator (e.g. tutor, peer, etc.) for any of our Member services
• When you sign up for an RPS assessment, or sign up as an RPS assessor
• When you book an RPS venue
• When you provide your details for any of our Credentialled individuals lists (e.g. Consultant Pharmacist List)
• When you provide information during consultation response stakeholder, advisory or steering groups for the development of pharmacy standards; or,
• When you request further information about RPS or sign up to our newsletters through our third party social media advertising partners such as (Facebook or Instagram).

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controller

This Website (www.rpharms.com and our associated web pages, including all third-party platforms) is operated by the Royal Pharmaceutical Society of Great Britain incorporated by Royal Charter in England and Wales under company number RC00079 and having its principal business address at 66-68 East Smithfield, London E1W 1AW (‘we’ and ‘our’).

For the purposes of the Data Protection Act 2018 and all relevant data protection legislation (including the UK GDPR), we are the “data controller” (i.e. the company who is responsible for, and controls the processing of, your personal data).

We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy, including any requests to exercise your legal rights. You can contact our data protection officer using the following details:

Calvin Smith
66-68 East Smithfield, London, E1W 1AW
[email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance if you have any questions or feedback.

Changes to this policy

We review this Privacy Policy periodically so there may be minor changes from time to time. We encourage any visitors to frequently check this page for any changes. Any historic changes can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

From time to time, we may introduce new processing activities into our practices. Whenever this takes place, we conduct reviews with relevant staff to ensure that the format of the processing minimises any risks to personal data, and is compliant with all relevant legislation, and we update this privacy policy accordingly.

Third Party Links

This website may include links to third-party websites, plug-ins and applications, applications (including job descriptions and links to recruiters).

Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Collection of Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 

Category	Types of data included	Retention Period
Identity Data	First name, last name, username or similar identifier, and title, and (where appropriate) your RPS membership number. With your consent, we may also process special category data about you (as defined in the UK GDPR) for monitoring purposes and in order to promote diverse representation across different demographics.	For the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent). Where you sign up for an RPS assessment, we may retain this data for up to 40 years as a record of RPS assessment provision.
Contact Data	Billing address, delivery address, email address and telephone numbers.	For the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent). Where you sign up for an RPS assessment, we will retain this data for one year after your assessment.
Financial Data	Bank account and payment card details.	Six years after transaction.
Transaction Data	Details about payments to and from you, and other details of products and services you have purchased from us.	Six years after transaction.
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.	28 days – except for cookies (Cookie expiry periods set out in our Cookie Policy).
Profile Data	Your username and password, CPD entries that you make on our apps /platforms, purchases or orders made by you, your interests, preferences, feedback, and survey responses. You also have the option to upload a profile photograph.	For the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent).
Pharmacist Data	Pharmacist Data includes details about your practice sector and employer, and an RPS Member or Registered User’s registration with the General Pharmaceutical Council, and their renewal date, as well as your credentialed pharmacist status (if applicable).	For the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent). We will retain our credentialed pharmacist lists for the duration of your appointment to that role and update this annually.
Assessment Data	Assessment data includes assessment results, candidate numbers, portfolio assessment materials, and assessment materials.	We will retain most assessment data for a period of one year following the assessment, but we will retain your result and candidate number in our archive for up to 40 years.
Recruitment Data	Recruitment Data includes special category data: gender, age, ethnic origin, and health information connected with disability.	Six months after the closing date of the job you apply for.
Usage Data	Information about how you use our website, products, and services.	Usage data linked to your profile is retained for the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent). Other usage data is deleted after 28 days.
Marketing and Communications Data	Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.	For the duration of your RPS membership, plus four years after your membership lapses / you last log into rpharms.com (whichever is more recent).
Video and audio data	Your image, voice, and likeness.	Two years after your consent is given.

We also collect, use, and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, however, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We collect this data for the purpose of equal opportunities monitoring and reporting, to promote diverse representation across different demographics, and to allow us to provide for any reasonable adjustments to accommodate any disability you may disclose under the Equality Act 2010. Where we collect this data, we rely on your explicit consent to do so.

We do not collect any information about criminal convictions and offences, except where this is provided to us by the GPhC or through our Membership Committee for the purposes of any hearing of a complaint about an RPS member.

If you enter your personal data through our Access Recruitment Module, we collect special categories of personal data (gender, age, ethnic origin, and health information connected with disability) as set out in the Privacy Statement for our Access Recruitment Module

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Provision of special category data is always optional, but you should be aware that if you do not provide information about any disability, RPS will not be able to consider whether we need to provide appropriate adjustments for any assessments you sit with us.

3. How we collect your personal data

We use different methods to collect data from and about you, including through:

Category of Data	Collection Method
Identity, Contact, Profile, and Pharmacist Data	You can enter this information on your membership application and on your online user profiles.
Identity, Contact, Profile, Pharmacist, Recruitment, Transaction and Financial Data	Direct interactions such as registering a profile, filling in forms, entering a contractual relationship, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: Purchase RPS membership; Register for and create an account on our website, apps, or other third-party platforms (please see glossary for specific third party details) Subscribe to our newsletter or job alerts Sign up as a mentor or mentee Submit applications for jobs through our Recruitment Module; Email us with a query Book an event with us or one of our affiliates Engage with interactive features of our website (e.g. groups and networks) Provide a response to a consultation about pharmacy standards and professional practice Communicate with our venue hire agents or staff Enter a promotion / competition, or complete a survey; Become a speaker at an event, or an outworker Report a problem with our site Share information (e.g. a direct message through a social media platform) or, Give us feedback or contact us.
Identity Data	Internal authentication from your existing RPS membership account is used to verify whether you are an RPS member.
Identity & Contact Data, Pharmacist Data	If you are nominated as a collaborator on our RPS E-portfolio by a Member or Registered User, or if you are nominated as a Peer in a Revalidation Peer Review Entry on a MyPortfolio entry by a Member or Registered User, your Identity and Contact data (your email address) will be provided by the applicable Trainee or Foundation Pharmacist or Member or Registered User and you may be invited to sign up as a Registered User. If you reject this request, we will delete that data.
Identity, Pharmacist Data	Authentication with General Pharmaceutical Society is used to check your GPhC registration number.
Contact, Financial and Transaction Data	Third party providers of technical, payment, and delivery services (please see glossary for specific third party details).
Technical, Usage Data	Automated technologies or interactions with our website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details. This data may also be accessed by third parties, such as: Analytics providers (please see glossary for specific third party details) Search information providers (please see glossary for specific third party details) Website troubleshooting services (please see glossary for specific third party details).
Marketing and Communications Data	Direct interactions when you tick boxes to opt in or opt out of marketing through your account and communications from us, or unsubscribe to any of our communications.
Identity, Contact, Pharmacist, and Marketing and Communications Data	Direct interactions when you respond to lead advertising on our social media partner platforms (e.g. Facebook, Instagram).
Special Category Data (including video and audio data)	Direct interactions when you: Complete a survey offered by us or our third party partners; Register for one of our assessments Confirm you are happy to be recorded as part of an online meeting or event or, Submit an application for a job with us through our Recruitment Module.

4. Using your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to process the data to perform a contract we are about to enter into, or have entered into with you. For example if you are an RPS member, you book an event or venue with us, or you sign up as a registered user to access RPS products or services.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given us consent.

Generally we do not rely on consent as a legal basis for processing your personal data other than

• In relation to sending third party direct marketing communications to you via email or text message.
• In relation to the collection of Special Category data that you submit when completing a job application, apply for an assessment, when completing a survey, or when providing details for your online profile.

You have the right to withdraw consent to marketing at any time by logging into our preference centre or by contacting us at [email protected].

The RPS Recruitment site allows you to submit your CV in order to apply for specific jobs. We do not use the personal data in your CV for any other purposes. Please contact [email protected] if you wish use to withdraw consent at any time.

Purposes of use of personal data

Below, we have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate). Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Act	Type of data	Lawful basis for processing (including basis of legitimate interest)
To register you as a new member or registered user	(a) Identity (b) Contact	(a) Performance of a contract with you.
To process and deliver your orders on this website, for events and products, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Direct Debit credit reference checking This information will be processed by Braintree, Stripe, and Worldpay for e-commerce purposes.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us).
To carry out our obligations arising from a contractual relationship between you and the us, including notifying you of membership services, elections, entering you into our members database, notifying you about changes to your membership and other purposes connected with your membership.	(a) Identity (b) Contact (c) Financial	(a) Performance of a contract with you.
To notify Third-party organisations (e.g. NICE, HEE, NES, etc.) of pre-registration members.	(a) Identity (b) Contact	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to promote the education and development of the pharmacy profession).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Asking you to leave a review or take a survey including sending an email asking you to rate your experience of using our third-party platforms. (c) Providing you with information for and asking for feedback about an event you registered for on our site.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to plan, record and enter CPD records on our MyCPD Portfolio, partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Special Category	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business and to monitor equal opportunities).
To enable RPS to manage and administer assessments that you have applied to take or which you are an assessor for.	(a) Identity (b) Contact (c) Assessment (d) Special Category	(a) Performance of a contract with you (delivery of assessment). (b) Necessary for our legitimate interests (to conduct and manage fair and high quality assessments to promote a reputable pharmacy profession). (c) Consent. (d) To comply with legal obligations.
To allow RPS to collate and analyse responses to professional standards consultations or policies and to follow up with you on case studies where those may be beneficial to pharmacy standards or advocacy work.	(a) Identity (b) Contact (c) Pharmacist	(a) Necessary for our legitimate interests (to ensure that pharmacy standards and policies represent the profession and promote excellence in pharmacy practice). (b) Consent.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to ensure that content from our site is presented in the most effective manner on your computer.	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you) Identity.	(a) Contact (b) Profile (c) Usage (d) Marketing and Communications (e) Technical	(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	(a) Technical (b) Usage	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business).
To process your application for a job with RPS.	(a) Identity (b) Contact (c) Recruitment	(a) Necessary for our legitimate interests (to grow our business). (b) Compliance with legal obligations associated with employment. (c) Your specific consent.
To administer our Consultant Pharmacist List.	(a) Identity (b) Contact (c) Pharmacist	(a) Necessary for our legitimate interests (to allow identification of the best qualified pharmacists and maintain the integrity of the pharmacy profession).
To send you information about RPS products and services based on your purchase of membership.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to grow our business). (see B below)
To enable you to participate in a recorded meeting or event.	(a) Video data (b) Special category	(a) Consent (where you are a participant). (b) Performance of a contract with you (where you are a performer).
To publish videos to RPS members of recorded governance meetings.	(a) Video data (b) Special category	(a) Consent (where you are a participant). (b) Performance of a contract with you (where you are a performer).

B. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference centre where you can view and make certain decisions about your personal data use: www.rpharms.com/my-rps/my-communication-preferences.

You can also subscribe to receive newsletters, which will keep you informed, by e-mail, of the latest issues in pharmacy and provide you with other career and industry information. We have established a preference centre where you can change your email preferences: www.rpharms.com/my-rps/my-communication-preferences

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and (in each case) you have not opted out of receiving that marketing.

You may also be presented with RPS marketing communications through third party platforms that we work with such as Facebook and Instagram. You can change your advertising preferences on those platforms through your user account with those platforms.

Recruitment

We offer you the opportunity to apply for jobs at RPS.

Your job application and/or CV will not be shared with any recruiters or third parties.

We will delete your job application six months after the deadline for that job unless you are appointed to the role, in which case, we will process your job application in line with our Employee Data Protection Policy and Privacy Notice.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the Royal Pharmaceutical Society group of companies for marketing purposes.

Social Media Platforms

We may work with other data controllers such as Facebook and Instagram to provide you with targeted advertising about RPS whilst on those platforms. You can change your advertising preferences on these platforms through your account settings.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website or app and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. Please note that setting changes can take up to seven days to be fully processed.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase including registration for our applications, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Interactive Services

There are parts of our website which permit registered users to post user generated content. All content posted in such areas must comply with our Acceptable Use Policy. We ask you not to enter content which contains personal information.

If you engage with our mentoring platform, your mentoring profile will be shared with others on the mentoring platform for the purposes of allowing mentors and mentees to connect and conduct the mentoring relationship. You can change your mentoring profile information by logging into your account.

If you engage with the RPS e-Portfolio, your profile and portfolio information may be shared with collaborators on the platform for the purposes of providing feedback on your practice and guiding your development through the associated learning programme. In some cases, we may share your account details with your training provider or the educational commissioning body that administers your learning programme. You can change your portfolio profile information by logging into your account.

If you engage with RPS Learn, your profile may be shared with other users on the platform for the purposes of course administration and developmental interaction. You can change your mentoring profile information by logging into your account.

If you choose to engage with one of our professional networks (including social media groups, RPS Connect, and/or any other digital forum we may introduce), your details will be shared with other individuals engaging with that group in accordance with the settings for the third party platform provider (e.g. for WhatsApp groups your WhatsApp profile including your number will be accessible by other group members as this is how WhatsApp works). For each professional network, all members are required to agree to our privacy policy, and specific terms of reference which are designed to govern behaviour within the group when they join – however it is up to members to read the privacy terms applied by the third party provider. We discourage all members of professional networks from any unlawful processing of any personal data of any other member of the network, and RPS accepts no responsibility for any such processing.

5. Disclosure of your personal data

When you contribute content to public or shared areas of our website you will be credited as the contributor using your username. This accreditation will appear on the service and will therefore be visible to other users. The default setting for the user ID is your first name and surname. You can change these fields is by logging in to your profile.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Sharing data between the Royal Pharmaceutical Society and the Pharmaceutical Press.
• Braintree, Stripe, and Worldpay assist in the processing of Financial Information for the purposes of delivering e-commerce services.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We share your personal data within the External Third Parties listed in the Glossary (Paragraph 11). This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only directly transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries

• Where we use certain service providers not based in the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection that it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Security Measures

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data following our instructions, and they are subject to a duty of confidentiality.

Where you have access to a secure area of the website, or any external platform linked to the site, you are responsible for keeping your login details and password(s) confidential and protected. We ask you not to share your password with anyone. You can change your password at any time by logging in. We accept no responsibility or liability if a third party obtains and uses your ID or password. You must tell us immediately if you believe someone may have access to or use of this information.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As a general rule, we keep personal information about subscribers for a period of four years following the lapse of their subscription or RPS membership.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Where you enter CPD records on our MyCPD app, these will be deleted 28 days after your subscription expires. It is your responsibility to make copies of these if you want to retain the data.

Where you enter details into any of our third-party platforms, these will be retained for as long as you continue to be a member or registered user of RPS. It is your responsibility to make copies of these if you want to retain the data. These will be deleted 24 months after you cease to be a member or stop logging into this website as a registered user.

Where you are nominated as a Tutor in our Pre-Foundation, or Foundation, or Transition, or Advanced or Consultant programme and do not accept appointment by signing up as a registered user and creating your own account, we may delete your data associated with the Tutor nomination any time within 30 days after you receive an email from us asking you to activate your account and you do not respond.

Any job applications to RPS will be deleted six months after the closing date for the job you apply for.

We will update and maintain our lists of credentialed individuals (e.g. Consultant Pharmacists) annually.

In some circumstances you can ask us to delete your data: see below paragraph 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We will retain video recordings for up to 2 years for administrative purposes. Recordings made for the purpose of publication will be retained for the length of time as outlined in the relevant rights transfer agreement.

 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legal reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our data protection officer at [email protected] or using the contact details set out at the beginning of this policy.

No fee usually required

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.