5. 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 perform the contract we are about to enter into or have entered into with you, including where you are nominated or agree to act as a Tutor in our Pre-Foundation and Foundation programmes.
- 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.
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. You have the right to withdraw consent to marketing at any time by logging into our preference centre or by contacting us via [email protected]
- PURPOSES OF USE OF PERSONAL DATA
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 ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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Purpose/Activity
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Type of data
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Lawful basis for processing including basis of legitimate interest
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To register you as a new member or registered user
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(a) Identity
(b) Contact
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Performance of a contract with you
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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 Worldpay and GB Group for e-commerce purposes
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(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
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(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
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To carry out our obligations arising from membership of the Royal Pharmaceutical Society 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
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(a) Identity
(b) Contact
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Performance of a contract with you
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To notify NICE of pre-registration members
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(a) Identity
(b) Contact
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(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to promote the education and development of the pharmacy profession)
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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 MyCPD Portfolio
(c) providing you with information for and asking for feedback about an event you registered for on our site
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(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
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(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)
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To enable you to plan, record and enter CPD records on our MyCPD Portfolio, partake in a prize draw, competition or complete a survey
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(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
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(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)
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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
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(a) Identity
(b) Contact
(c) Technical
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(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
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
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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)
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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(a) Technical
(b) Usage
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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)
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To make suggestions and recommendations to you about goods or services that may be of interest to you
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(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
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Necessary for our legitimate interests (to develop our products/services and grow our business)
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To process your application for a job with RPS
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- Identity
- Contact
- Recruitment
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Necessary for our legitimate interests (to grow our business)
Compliance with legal obligations associated with employment
Your specific consent
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To send you information about RPS products and services based on your purchase of membership
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- Identity
- Contact
- Technical
- Usage
- Profile
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Necessary for our legitimate interests (to grow our business)
(see B below)
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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.
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, registered on our website or purchased goods or services from us within the last 24 months and, in each case, you have not opted out of receiving that marketing.
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.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website or MyCPD Portfolio 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.
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 paragraph 4 above.
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.
6. 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 5 above.
This will include sharing data internally with the Pharmaceutical Journal and the Pharmaceutical Press, within the Royal Pharmaceutical Group.
We will also share data with: -
- External Third Parties as set out in the Glossary.
- Worldpay and GB Group assist in the processing of Financial Information for the purposes of delivering e-commerce services as specified in paragraph 5 above.
- 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.
7. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the 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:
- 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.
8. 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 on our instructions and they are subject to a duty of confidentiality.
Where you have access to a secure area of the website, or to the MyCPD Portfolio, 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.
9. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL 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.
We will keep basic information about our members and registered users (including Contact, Identity, Financial and Transaction Data) for two years after they cease being members or logging into this website.
Where you enter CPD records on our MyCPD Portfolio, these will be retained for so 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 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 activity your account and do not respond.
In some circumstances you can ask us to delete your data: see below paragraph 10 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
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.
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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good 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.
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.
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.
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.
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.
11. 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.
EXTERNAL THIRD PARTIES
- Survey Monkey, based in the US, who provide services in connection with surveying members.
- Dotmailer, based in the EU, who provide customer mailing services and who sub-contract services to Microsoft Azure, Google Cloud Platform, Cloudflare, Dynmark International Ltd, Amazon Web Services, GGR Communications, Red SMS, GTT, Interxion, Zayo, Magnetic One, Brooklands Mailing Services.
- Sendgrid, based in the US, in who provide an email delivery service which is used within our website.
- JIRA by Atlassian, based in the US, who store member enquiries to assist with resolution of support issues.
- Oracle, based in the US, and Crowdcompass, based in the UK, who provide data storage services to deliver membership services and benefits.
- Webex, based in the US, who provide webinar services for event attendees.
- Cantarus, based in the EU, who provide website development and hosting services.
- GB Group, based in the EU, who provide identification verification services.
- MandF Health, based in the UK, who provide PR services in connection with membership.
- The National Institute for Health Care and Excellence (NICE), based in the UK, who provide education and training services for pre-registration students.
- Access, based in the EU, who provide online recruitment module services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Mi- Voice, based in the UK, a third party specialist who manage RPS board elections communications.
- Facebook, based in the US, we upload data to Facebook to allow us to target advertising that is relevant to you
- Instagram, based in the US, we upload data to Instagram to allow us to target advertising that is relevant to you
- Hall and Partners, based in the UK, a third party outbound telemarketing agency who assist us with membership renewals and who subcontract hosting services to United Hosting Limited and Fasthosts Internet Limited, both based in the UK.
- WDM, based in the UK, mailing house used for sending out postal communications and membership renewal information.
- Chrysalis, based in the UK, a market research agency
- Reedwords, based in the UK, a copywriting agency