Privacy Policy

RCPI Privacy Statement

Last modified: August 2018

The Royal College of Physicians of Ireland (“RCPI”, “we”, “our”) offers many products and digital services (“Services”) which can be accessed when you log-in to the RCPI website or through the RCPI App.

Examples of such services are:

  • Booking a place at a course or event
  • Applying to a training programme
  • Consuming educational materials
  • Participating in discussions on The Physician Network (RCPI’s professional social network)
  • Maintaining your training record using ePortfolio
  • Maintaining your record of Professional Competence using ePortfolio
  • Accessing Medical Journals
  • Paying subscriptions

We respect your right to privacy and our obligation to comply with the General Data Protection Regulation (2016/679).

This policy explains how we collect, use, store and share your personal data.

By using our Services, you are agreeing to these terms.

Please read this policy in conjunction with our Terms of Use.

 

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Information you give us

If you wish to use our digital services, you need to register for an RCPI Account. During registration you will be asked to provide personal information such as your name, date of birth, gender and email address.

Information we get from your use of our services

  • Device Information: We may collect device-specific information such as your hardware model, operating system version, mobile network information
  • Log Information: We may collect server log information certain (like your search queries and how you used our services), system activity (like the time and date of your requests), events (like crashes), hardware settings, browsers type, browser language and your IP address.
  • Local Storage: To facilitate the off-line provisions of our Services, we collect and store information (including personal information) from your device using mechanisms such as browser web storage (including HTML 5), application data caches and cookies.
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How we use information you give us

We may use your anonymised data to facilitate research for the improvement of education, training and quality programmes. The anonymised data may include Personal data provided voluntarily by you to us, pursuant to a number of the different roles of RCPI including as a:

  • Medical Council accredited post-graduate training body
  • Training body recognised to operate Professional Competence Schemes on behalf of the Medical Council
  • Provider of continuing medical education for physicians
  • Host of academic meetings

How we use information we collect

We 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 give you more relevant search results and to offer you tailored content.

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 appropriate to your profile.

Our partners, as Data Processors, may use the information you supply to help to provide you with a better service, and in particular to:

  • Increase performance of their service and improve user navigation
  • Facilitate internal record keeping and to improve efficiency or costs
  • Provide information to RCPI in support of legitimate operational and regulatory requirements

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 dataprotectionofficer@rcpi.ie

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.

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Your personal data is held on our secure servers, our partners’ secure servers or our service providers’ secure servers. In line with our obligations under the General Data Protection Regulation (2016/679), 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:

  • Our website and Digital Hub is hosted by SunGuard Ireland and the data for the system is stored by them in a central database
  • ePortfolio for Professional Competence is hosted by the NHS Education for Scotland (“NES”) and the data for the system is stored by them
  • ePortfolio for Training is hosted by FryIT and NHS Education for Scotland (“NES”) with the data for the system is stored by them
  • Our booking/purchasing service is hosted by Tata Consultancy Services (TCS) and the data for the system is stored by them
  • The Physician Network is hosted by Tata Consultancy Services (TCS) and the data for the system is stored by them.
  • Moodle is hosted by Enovation and the data for the system is stored by them.
  • Our user authentication application is hosted by Ellucian Ireland and the data for the system is stored by them.
  • Data is transferred between different systems using applications that are hosted by Amazon Web Services and data is cached within this service.
  • Our Computer Based Testing is hosted by Tata Consultancy Services (TCS) and the data for the system is processed by them.
  • Realex Payments Gateway, which is governed by the Irish Payments Services Organisation, is a service which allows you to process your payments. We do not store your credit card details.
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We will not share your personal information with third parties except where we have received your explicit and informed consent to do so, or where one of the following circumstances apply:

For data processing

We provide personal information to our service partners to process it for us. This processing must be based on our instructions, in compliance with our Privacy Statement and any other appropriate confidentiality and security measures.

To fulfil our obligations as RCPI

In order to fulfil our obligations as a Medical Council-recognised postgraduate training body and as a recognised operator of Medical Council Professional Competence Schemes, access is granted to records in ePortfolio as follows:

  • RCPI Trainee ePortfolio records are accessible by RCPI Trainers, RCPI Reviewers, National Specialty Directors and RCPI administrative staff. This is for the review, approval and monitoring of trainees throughout their training programme.
  • RCPI Trainer ePortfolio records are accessible by RCPI Reviewers and RCPI administrative staff.
  • RCPI Exam responses and results are accessible by RCPI Examiners and RCPI administrative staff.
  • PCS Participant ePortfolio records are accessible by RCPI administrative staff. During the Annual Verification Process records are also accessible by RCPI Reviewers, the RCPI Dean of Professional Competence and the Responsible Medical Officer.
  • RCPI periodically provides reports to the Medical Council or the HSE on information stored in ePortfolio.

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 as well as 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.

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We work hard to protect RCPI and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information we hold.

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.

We hold your personal data on our servers or our service providers’ servers which are all secure servers. However, no data transmission over the Internet can be guaranteed to be 100% secure and, as such we cannot guarantee the security of any information you transmit to us via the Internet. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.

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We transfer examination candidates’ personal data, collected during the registration process, to Tata Consultancy Services (TCS) for the configuration of candidates’ preferred examination centres. TCS are based in India.

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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.

Security

We use multiple security cookies to authenticate users through RCPI Digital Services. For example, we use cookies called "SimpleSAMLAuthToken" and "_shibsession_xxx". These cookies are set by our authentication system and contain digitally signed and encrypted records of your username and browsing session information. The combination of these cookies allows you to pass easily through RCPI Digital Services without having to log in again.

These Cookies are removed when you close your browser.

Processes

Process cookies help make RCPI Digital Services work and deliver the experience that you expect, like navigating around web pages or accessing secure areas of RCPI Digital Services. Without these cookies, RCPI Digital Services cannot function properly. For example, we use a cookie called "RCPIurl" which makes it possible for RCPI Digital Services to know where you started from, so it can return you to that place when you complete a course booking. By blocking this cookie RCPI Digital Services won't know where to return you to which will infringe on your navigation experience.

Session State

Websites often collect information about how users interact with a website. This may include the pages users visit most often, and whether users get error messages from certain pages. RCPI Digital Services use these so-called 'session state cookies' to help us improve our services, in order to improve our users' browsing experience. Examples include "PHPSESSID" and "rcpi_sess". Blocking or deleting these cookies will not render the website unusable.

Session Management

A number of our services also create cookies to improve your user experience by making it easier and faster to navigate through the services. For example, ePortfolio creates a cookie called "NESEportfolioAuth10". These Cookies are removed when you close your browser.

Analytics

Google Analytics is an analytics tool that mainly helps us to understand how you engage with RCPI Digital Services. We use Google analytics including universal analytics which set cookies on the domain of the site you are visiting. It uses a set of cookies with names like '__utma', '__utmz' and '__cid' to collect information anonymously and report website trends without identifying individual visitors. If you don’t want Analytics to be used in your browser, you can install the Google analytics opt out browser add-on.

Learn more about Google analytics and privacy

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You can amend your information at any time through your Digital Hub, this is the portal you are directed to when you log-in to the RCPI website. Alternatively, you can contact the RCPI Helpdesk on +353 1 8639721.

If you wish to terminate your account, you please contact us to do so.

Updates to this policy

RCPI reserves the right to change this Policy as we may deem necessary (for example to reflect changes to our information practices) or as may be required by law.

If we make any changes to this Policy that materially impacts previously collected information about you, we will obtain your prior express consent.

Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.

How to contact us

If you have any questions about this policy or information we have collected about you, please contact dataprotectionofficer@rcpi.ie
or

Data Protection Officer,
RCPI,
19 Frederick Street South,
Dublin 2
Phone: 01 8639 700