1.0 Purpose of our statement1.1. This Privacy Statement outlines how we handle “personal information” as it is defined in the UK GDPR (2020) that is provided when registering and submitting content for the UHL ‘Education Hub’.
1.2. UHL (we, us or our) provides the UHL Education Hub as a repository for educators and learners to share learning resources and information, and developing communities of practice through online discussions.
1.3. We have adopted this Privacy Statement to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:
(a) providing the UHL Education Hub;
(b) the operation of our UHL Education Hub;
1.4. We ensure that we comply with the Data Protection Act (2018) and the UK General Data Protection Regulation (GDPR) (2020) for the handling of Personal Information, to provide appropriate protection and care with respect to the treatment of your personal information in accordance with the UK GDPR (2020)
2.0 Who and what this statement applies to2.1. We collect Personal Information on our own behalf.
2.2. This Privacy Statement applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
2.3. If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.
3.0 The information we collect3.1. When registering for an account, we ask you to provide information about yourself that enables us to create an individual profile. Your individual profile enables us to enhance your interaction with the UHL Education Hub.
Without limitation, the type of information we may collect is:
(a) Personal Information. For registrations, you have an option to provide us with your personal details, we may collect your first name, last name, email address / phone number, grade, specialty, department, UHL assignment number and GMC number.
(b) Contact Information. We may collect information such as an individual’s email address, telephone number, social media accounts, NHS organisation they work / volunteer in.
(c) Statistical Information. We may use some of the information for analytical monitoring to provide performance on:
(i) Hub usability
(ii) Hub interactions
(iii) number of active users
(iv) number of active users per grade, specialty and/or staff group.
3.2. The basis for processing personal data.
(a) We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Statement. We process your personal data, including any special categories of personal data on the basis of your consent, which you give by submitting your registration for an account. You have the right to withdraw your consent if you wish to do so.
(b) In some limited circumstances, we may also process personal data where we have a legal obligation, where it is necessary for the legitimate interests of UHL or someone else of where it is necessary to protect the vital interests of a person.
4.0 How information is collected4.1. Most information will be collected in association with an individual’s use of the UHL Education Hub.
(a) Access. When an individual accesses the UHL Education Hub, we may collect information on types of incidents and monitoring information for analytical purposes.
(b) Sharing/uploading material and resources. When an individual requests for content/resources to be uploaded they will need to provide Personal Information details in order to be contacted and supported, and to allow material to be attributed to them.
4.2. As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
5.0 When Personal Information is used and disclosed5.1. In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected, other than with the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted. We will usually only be shared with relevant and specifically trained staff members. We will usually only disclose the data to others with your consent, or where there are other legitimate reasons for disclosure, for example where it is necessary to protect the safety of a person.
Data will also be shared with Culture Shift, a third party that provides the platform for the YourVoice, Report and Support tool. We have appropriate arrangements in place with Culture Shift to protect personal data and to keep it secure. You can find further information about Culture Shift here.
5.2. We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. We will retain personal information for 2 years for staff reports unless longer is needed for investigation purposes. After 2 years, personal information will be removed from all reports and reports will be used solely for the purpose of monitoring.
We provide assurance that the deletion of Personal Information will adhere to UHL data destruction policy that will securely delete Personal Data.
5.3. We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.
5.4. Information is used to enable us to operate our UHL Education Hub, especially as it relates to an individual. This may include:
(a) communicating with an individual that has created an account
(b) for evaluation purposes of the UHL Education Hub
(c) as required or permitted by any law (including UK GDPR 2020 & the Data Protection Act 2018).
5.5. If we use your Personal Information to request feedback for the purposes of evaluation, we will anonymise your information, meaning no personal confidential information is shared, and you will be unidentified. The purpose of evaluation will be to evaluate the effectiveness of the UHL Education Hub. Any evaluation reporting will be shared internally within UHL.
5.6 There are some circumstances in which we must disclose an individual’s information:
(a) where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of; and
(b) as required by any law (including UK GDPR 2020 & the Data Protection Act 2018). For example, this may include where it is necessary to protect the safety of a person.
6.0 Transfer to other countries6.1. We shall not transfer Personal Data outside of the UK.
7.0 Choosing to opt out or withdrawing consent7.1. An individual may opt to not have us collect their Personal Information. This will prevent us from offering them access to the UHL Education Hub. They will be aware of this when:
(a) Opt In: where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or
(b) Opt Out: where relevant, the individual will have the right to choose to exclude themselves from some or all collection of information and/or receiving information from us.
7.2. If you wish to withdraw your consent, then the investigating organisation will stop processing your personal information from the date of the withdrawal.
8.0 Securing your Personal Information8.1. We may appoint a Privacy Officer to oversee the management of this Privacy Statement and compliance with UK GDPR (2020) & the Data Protection Act (2018). This officer may have other duties within our organisation and also be assisted by internal and external professionals and advisors.
8.2. We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
9.0 How to access and or update information9.1. Subject to UK GDPR (2020) & the Data Protection Act (2018), an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.
9.2. If an individual cannot update their own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.
9.3. It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
10.0 Your right to be forgotten10.1. If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
(a) to comply with a legal obligation;
(b) for the performance of a task carried out in the public interest or in the exercise of official authority;
(c) for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
(d) for the establishment, exercise or defence of legal claims.
10.2. Please note that if you request that we delete your personal data, you will not be able to use the UHL Education Hub until such time as that personal data is provided to us again.
11.0 Complaints and disputes11.1. If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the organisation they are employed by – details below.
11.2. If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
11.3. If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
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13.0 Contacting us13.1. All correspondence with regards to privacy should be addressed to your employing organisation:
University Hospitals of Leicester NHS Trust
Head of Privacy
14.0 Additions to this policy13.1. All correspondence with regards to privacy should be addressed to your employing organisation: University Hospitals of Leicester NHS Trust Saiful Choudhury Head of Privacy UHL IM&T County hall Glenfield LE3 8RA Saiful.Choudhury@uhl-tr.nhs.uk
15.0 Additions to this policy14.1. If we decide to change this Privacy Statement, we will post the changes on our webpage at https://www.uhlclinicaleducation.org. Please refer back to this Privacy Statement to review any amendments.
14.2. We may do things in addition to what is stated in this Privacy Statement to comply with the UK GDPR (2020) & Data Protection Act (2018), and nothing in this Privacy Statement shall deem us to have not complied with UK GDPR (2020) & the Data Protection Act (2018).