Privacy and Data Protection Notice –
Practice Based Small Group Learning (PBSGL) Membership
About NHS Education for Scotland
NHS Education for Scotland (NES) is a public-sector body as set out in 2002 No. 103 National Health Service – the NHS Education for Scotland Order 2002. It is one of the organisations which form part of NHS Scotland (NHSS).
NES is an education and training body and a special health board within NHS Scotland, with responsibility of developing and delivering education and training for the healthcare workforce in Scotland.
What types of personal information is collected
NES holds and manages personal data for the administration and evaluation of training and education of health and social care professionals, for the employment of staff, for research and for related activities in support of our core purposes.
We process several categories of personal data, including:
- Training management data: including contact details for trainees, educational history, placements and records of progress
- Educational data: contact details, records of attainment, records of attendance
- Employee data: contact details employment and educational history, leave records, management information, performance and appraisal information
- Contact details for: contractors and suppliers, stakeholders, volunteers, organisational leads or contacts for specific activities
- Equality and diversity data (where provided by individuals): race or ethnicity, religion, sexual orientation, disability
For Practice Based Small Group Learning membership (PBSGL) we process the following categories of personal data:
- Name and contact details
- Professional Registration number
- Health Board area of workplace
What is the purpose of processing data
- To enable individuals to voluntarily join PBSGL
- To manage their access to educational modules via our online site
- To manage their account and ensure that they are invoiced correctly on an annual basis
- To provide anonymised reports on the demographics of the membership for the purpose of developing the service
- To send you information relevant to your PBSGL membership and other CPD Connect educational resources.
What is the legal basis for using personal information
NES as a data controller and a data processor, is required to have a legal basis when using personal information. NES considers that performance of our tasks and functions are in the public interest. When using personal information, our legal basis usually that its use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us.
For PBSGL NES considers our legal basis for processing is:
- Article 6(1)(e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Sharing the information
We will share personal data where appropriate and necessary with third parties such as employing NHS Board and other employers, educational institutions and regulatory and professional bodies. We will also share persona data where required to do so by law.
For PBSGL we will share your data with:
- Tactuum Ltd – the company who maintain our website.
- Your PBSGL Facilitator to enable them to correspond with you about group activities.
Transferring personal information abroad
PBSGL will not transfer any of your personal data outside of the UK.
Retention periods of the information we hold
We only keep your information for as long as it is necessary to fulfil the purposes for which the personal information was collected. This includes for meeting any legal, accounting or other reporting requirements or obligations. The NHS Scotland retention policy sets out the minimum retention timescales.
For PBSGL we will retain your personal data for 6 years after your membership ceases.
Security of your Information
We take our duty to protect your personal information and confidentiality very seriously and we are committed to taking reasonable measures to ensure the confidentiality and security of personal data for which we are responsible for.
All NES staff are required to undertake annual information governance training and to be familiar with information governance policies and procedures.
Your rights regarding your personal data
You have the following rights in regard to your personal data:
- The right to informed of why we are collecting/holding data about you and how that data will be used;
- The right to access the data we hold about you;
- The right to have the data we hold about you rectified if it is inaccurate or incomplete;
- The right to have your personal data erased and to prevent processing in specific conditions;
- The right to restrict the processing of your data;
- The right to obtain and reuse your personal data for your own purpose across different services;
- The right to object to the processing of your data based on legitimate interests of NES, direct marketing or for the purposes of scientific/historical research and statistics;
- The right not to be subject to a decision based on automated processing.
How to access your personal data?
You have the right to access the information which NES holds about you, and why, subject to any exemptions using a Subject Access Request. Requests must be made in writing and you will need to provide:
- Adequate information [for example full name, address, date of birth, staff number etc] so that your identity can be verified, and your personal data located.
- An indication of what information you are requesting to enable us to locate this in an efficient manner.
You should send your request to the Information Governance Team. Contact details can be found below.
We will aim to comply with requests for access to personal data as quickly as possible. We will ensure that we deal with requests within 30 days of receipt unless there is a reason for delay that is justifiable.
Complaints about how we process your personal data
In the first instance, you should contact the Information Governance Team – contact details can be found below.
Data Protection Notification
NES is a ‘data controller’ under the Data Protection Act. We have notified the Information Commissioner that we process personal data and our registration number is: Z7921413
The details are publicly available from the: -
Information Commissioner’s Officer
Wilmslow SK9 5AF
How to contact us
Data Protection Officer
Edinburgh EH3 9DN