RCPI Privacy Statement
There are many different ways you can use our products and digital services (“Services”) –booking onto a course, applying for an examination or training programme, consuming educational materials and participating in discussions on The Physician Network, maintaining your record of Professional Competence using ePortfolio. As you use our Services, we at the Royal College of Physicians of Ireland (“RCPI”, “we”, “our”) respect your right to privacy and our obligation to
comply to the Data Protection Acts 1988 and 2003.
Our Privacy Statement explains:
- What information we collect and why we collect it.
- Where information is stored.
- How we use that information.
- The choices we offer, including how to access and update information.
Your privacy matters to RCPI so whether you are new to RCPI or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us at firstname.lastname@example.org
Information we collect
We collect information to provide better Services to all of our users. We collect information in two ways:
1. Information you give us
For example, many of our digital services require you to sign up for an RCPI Account. When you do, we’ll ask for personal information. This is data that identifies you or can be used to identify or contact you such as your name, date of birth, gender, email address, and telephone number. You can amend your information at any time through your Digital Hub (accessed when you log in to our website) or via our Helpdesk, and in the case you wish to terminate your account you can contact us to do so.
2. Information we get from your use of our services
We may collect non-personal information about the Services that you use and how you use them. This is information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our services. This information includes:
We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information).
When you use our services or view content provided by RCPI, we may automatically collect and store certain information in server logs. This may include:
- Details of how you used our service, such as your search queries.
- Internet protocol address (IP address)
- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- Cookies that may uniquely identify your browser or your RCPI Online Services account.
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
We use various technologies to collect and store information when you visit our services which may include sending one or more cookies to your device.
Where your data is stored
Your Personal Data is held on our (or our service providers’) or our partners’ secure servers. In line with our obligations under the Data Protection Acts 1988 and 2003, we have implemented contractual measures to ensure that our partners and contractors comply with their data protection obligations while processing your Personal Data. The following include but are not limited to our partner services:
- Portfolio is hosted by the NHS Education for Scotland (“NES”) and the data for the system is stored by them. RCPI also retains a copy of this database on RCPI servers.
- Our booking/purchasing service is hosted by Tata Consultancy Services (TCS) and the data for the system is stored by them in a central database.
- The Physician Network is hosted by Tata Consultancy Services (TCS) and the data for the system is stored by them in a central database.
- Moodle is hosted by Enovation and the data for the system is stored by them in a central database. RCPI also retains a copy of this database on RCPI servers.
- Our online applications are hosted by Ellucian Ireland and the data for the system is stored by them in a central database. RCPI also retains a copy of this database on RCPI servers.
- Your credit or debit card details are held by the Realex Payments Gateway, which is governed by the Irish Payments Services Organisation.
How we use information we collect
As the Data Controller, RCPI may use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect RCPI and our users. We also use this information to offer you tailored content – like giving you more relevant search results.
The Personal Data that we collect may be provided voluntarily by you to us pursuant to a number of the different functions of RCPI, including but not limited to, in our role as a Medical Council-recognised postgraduate training body, training and education opportunities to physicians, continuing medical education, training programmes, study days, Masterclasses, examinations, Professional Competence and academic meetings. We may use your anonymised data to facilitate research and/or statistical or other into the improvement of education, training and quality programmes.
In the case of your RCPI Account, Personal Data held by RCPI may be used to create a user profile and give you access to services including but not limited to Moodle, ePortfolio, RCPI Committees, our booking/purchasing service and The Physician Network.
Your Personal Data may be used by RCPI to communicate with you about upcoming events and initiatives within RCPI. Your data will not be used for unsolicited direct marketing communications unless you have provided the requisite level of consent required by law.
When you contact RCPI, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our Services, such as letting you know about upcoming changes or improvements.
The purpose for which we collect Personal Data is usually stated on the webpage where the information is requested and should be self-explanatory. However, if you have any specific queries about the purpose for which your information is to be used, you should contact us before submitting the information.
We use information collected from cookies and other technologies to improve your user experience and the overall quality of our Services.
As Data Processors our partners may use the information you supply to help us provide you with a better service, and in particular for the following reasons:
- To increase performance of their service and improve user navigation.
- To facilitate internal record keeping and to improve efficiency or costs.
- To provide information as appropriate to RCPI in support of legitimate operational and regulatory requirements.
Personal information will not be retained for longer than it is required and once the initial purposes for gathering the information have become irrelevant the information will not be retained.
We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Statement.
Information we share
We do not share personal information with third parties unless one of the following circumstances apply:
With your consent
We will share personal information with third parties when we have your consent to do so.
To fulfil our obligations as RCPI
We will share personal information with third parties where it is required to fulfil your request to us and/or our obligations to fulfil the functions of RCPI.
It should be noted that to fulfil our obligations as a Medical Council-recognised postgraduate training body and Medical Council accredited Professional Competence Scheme provider access is granted to records in ePortfolio as follows:
- RCPI trainee ePortfolio records are accessible to individuals with the role of RCPI Trainer, RCPI Reviewer and Administration. This is to review, approve and monitor progress through their training programme.
- RCPI Trainer ePortfolio records are accessible to individuals with the role RCPI Reviewer and Administration.
- PCS Participant ePortfolio records are accessible to individuals with the role of Administration. As part of the Annual Verification Process individuals with the role of Dean/Responsible Medical Officer/Reviewer/Administrator assigned responsibility for a group of participants in a particular Scheme have access to view the ePortfolio of these participants.
- RCPI from time to time provide reports to the Medical Council or the HSE on information stored in ePortfolio.
- Access is limited to those individuals having a legitimate need to access the data for the purposes explained in this Privacy Statement.
For data processing
We provide personal information to our service partners to process it for us, based on our instructions and in compliance with our Privacy Statement and any other appropriate confidentiality and security measures.
For legal reasons
We will share personal information with third parties if we believe in good faith that we are required to disclose it in order to:
- comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement. Where Personal Data is sought from us in the context of any statutory or non-statutory investigation or enquiry (e.g. by the Medical Council, a Hospital or by the HSE in the context of a malpractice or disciplinary investigation) we will assess the request on its merits having regard to the legitimate interests of RCPI, the public interest and the interests of the data subjects concerned.
- Enforce applicable Terms of Service, including investigation of potential violations.
- Detect, prevent, or otherwise address fraud, security or technical issues.
We may share aggregated anonymised information publicly and with our partners. For example, we may share information publicly to show trends about the general use of our Services.
We reserve the right to transfer information (including your Personal Data) to a third party in the event of a re-organisation of RCPI or a transfer of all or substantially all of the assets of RCPI (whether by dividing, merging or transferring its business between two or more bodies, or subcontracting or outsourcing same or otherwise) provided that any relevant third party agrees to adhere to the terms of this, or a similar, Privacy Statement and provided that the third party only uses your Personal Data for the purposes that you provided it to us.
Accessing and updating your personal information
Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly – unless we have to keep that information for legitimate business or legal purposes.
You can update your personal information on your RCPI Digital Hub (accessed when you log in to our website) or if you want to have your Personal Data updated, amended or removed from our database, please email your request to us at email@example.com When updating your personal information, we may ask you to verify your identity before we can act on your request.
Pursuant to the Data Protection Acts 1988 and 2003, you have certain rights to obtain a copy of the data held about you, for a fee.
Any such data subject requests must be made in writing to the Data Protection Officer on firstname.lastname@example.org or at the postal address set out below and may be subject to the prescribed fee. RCPI may fulfil its obligations of disclosure by making your Personal Data available to you electronically.
For further details on your data privacy rights, please refer to www.dataprotection.ie
We work hard to protect RCPI and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information we hold. In particular:
Your Personal Data is held on our (or our service providers’) secure servers. However, the nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
We restrict access to personal information to RCPI administrators, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Our Privacy Statement applies to all of the services offered by RCPI but excludes services that have separate privacy statements that do not incorporate this Privacy Statement.
Our Privacy Statement does not apply to services offered by other companies or individuals, including services or websites that may be displayed to you including but not limited to @physicians email, ExOrdo, The Physician Network, our booking/purchasing service, ePortfolio and medical journals, which are linked to our website.
Our Privacy Statement may change from time to time. We will post any privacy statement changes on this page so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy statement changes).
Any queries or concerns you may have about the processing of personal information should be addressed to:
Data Protection Officer
Royal College of Physicians of Ireland
19 South Frederick Street
Phone: +353 1 863 9721