Policy Aims
This policy sets out the basis on which personal data is collected and stored by Healthcare Licensing Support Ltd (HLS) and how it is processed and used. Please read this document to understand our responsibilities in relation to the data that we hold.
GDPR
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive and was designed to harmonise data privacy laws across Europe to protect and empower all EU citizens data privacy and reshape the way organisations approach data protection. This new regulation comes into force from 25 May 2018.
This applies to all companies processing and holding personal data of data subjects residing in the EU.
Healthcare Licensing Support Ltd (HLS) are committed to respecting and protecting your privacy at all times and have a duty under the General Data Protection Regulations and privacy laws to protect this. Under the law, we are not obliged to appoint a Data Protection Officer as we do not meet the criteria for “large scale” processing of data, however have appointed a Company Director (Julie Bullock) to oversee that the laws are upheld in relation to personal and sensitive data.
Information we collect and store
HLS request and hold personal data* for the purpose of conducting annual appraisal and also on behalf of the Responsible Officer and Confirmer in order to make judgements in relation to revalidation. The personal data is provided either by the data subject, the designated body, employer (agency, private clinic etc), General Medical Council (GMC) or Nursing & Midwifery Council (NMC).
* Personal data may include, (but is not exhaustive)
Email address (we may contact you via this method)
Skype name
Phone number (Landline and mobile) (we may contact you via this method)
Passport (for ID purposes)
Revalidation data
Appraisal documentation to include the inputs and outputs of appraisal
Any other personal data that is provided by the data subject in relation to the service of appraisal and revalidation.
How long do we keep your information?
The revalidation cycle is 3 years for nurses and 5 years for doctors and therefore a minimum of 3 and 5 years’ worth of appraisal information and supporting data is stored on a secure server.
Information is maintained for the above periods and is required to:
Assist the GMC or NMC should an investigation be commissioned involving a doctor or nurse
To provide information of note to the new Responsible Officer / Medical Officer when the doctor transfers to a new Designated Body (Agency or private clinic)
To allow the Responsible Officer to review previous years’ appraisal information to make a decision in relation to revalidation
To inform a new Responsible Officer
How we store your information
Data subject information is stored on a drive which is part of a secured server service hosted by UK Fast who also provide a managed service to the NHS. Our server is in line with NHS standards of security. Their engineers manage server maintenance to maximise the security framework for our network.
How we use your information
Your personal data will only be used for the purpose of:
Appraisal
Revalidation
Transfer of Information to a new Responsible Officer
To provide you with information such as training opportunities pertaining to ongoing Continuing Professional Development or that may be pertaining to your annual appraisal or revalidation (ie. for ongoing continuing Professional Development)
To provide us with feedback, or to assist us in improving our services
The personal data of data subjects will be shared with us by your designated body or employer for the above purposes by:
HLS Account Manager
HLS Quality assurance staff
HLS lead appraiser
Assigned appraiser
Lead appraiser
Your Responsible Officer (or deputy)
The General Medical Council (GMC) or Nursing and Midwifery Council (NMC) for purposes of assisting with any investigation they may be commissioning in relation to you.
HLS will not share your information with any other 3rd party or access any of your personal data (ie from online portals of other providers of the service) without your written permission.
HLS will securely store data and will release any information we hold about our data subjects, to the data subject at any time, when requested by the data subject.
By submitting data, the data subject accepts the above reasons for processing this data for the above purposes.
Updates and Changes to Privacy Policy
HLS reserve the right to make changes to this privacy policy in line with legislative change.
