The Lincolnshire Refugee Doctor Project takes the protection of personal data very seriously. This notice sets out how we manage personal data.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is (from 25 May 2018) governed by the General Data Protection Regulation 2016/679 (the “GDPR”).
Who are we?
The Lincolnshire Refugee Doctor Project (The Association), is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
How do we process your personal data?
The Lincolnshire Refugee Doctor Project complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We do not source personal data from third parties, other than as may be publicly available.
We use your personal data for the following purposes:
to contact you regarding the application process and inform you about your application;
- to administer your membership of the Association and participation in and promotion of its activities;
- to inform you about opportunities to participate in Association events;
- to administer your relationship with the Association;
- to keep records of consents given to process personal data
What is the legal basis for processing your personal data?
The legal basis for processing we have identified is Article 6 of the GDPR. Specifically, we process data under one or more of the following bases set out in that Article:
- consent of the data subject;
- necessary for the performance of a contract with the data subject or to take steps to enter into a contract;
- compliance with legal obligations (for example Companies Act, Charities Act and HMRC requirements) or
- necessary for the legitimate interests of the data controller, except where such interests are overridden by the interests, rights or freedoms of the data subject. In this context our legitimate interests are to promote the objects of the Association –
The Lincolnshire Refugee Doctor Project has three main aims:
- To recruit Refugee Doctors to Lincolnshire, to support them within the community here,
- to provide them with the skills and knowledge required to satisfy examination in Language and Clinical Skills, and to allow them to practice safely as medical practitioners in the UK.
- To give Refugee Doctors a meaningful experience of being valued in the health community of Lincolnshire.
Sharing your personal data
Your personal data will be shared only with the Association’s Directors and/or their designated management team. In all cases personal data is only shared to the extent reasonably necessary for the purposes described above. We will only share your data with third parties with your consent, unless we are required to do so by law.
How long do we keep your personal data?
We keep your personal data for no longer than is reasonably necessary. In deciding how long we should keep your data we take into account the following criteria:
- The nature of your relationship with the Association: e.g. member, past member, supporter or past supporter, supplier or past supplier of services/goods (whether or not under direct contract);
- The legitimate reasons we may have for continuing to contact you deriving from our objects (see above);
- Our legal obligations as a Community Interest Company to retain company, financial and other records (typically for a minimum of 6 years);
- Any specific consents or requests you have made regarding the duration of processing of your personal data;
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which the Association holds about you;
- The right to request that the Association corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for the Association to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing;
- The right to lodge a complaint with the Information Commissioner’s Office.
Changes to how we process personal data
The Association’s processing of personal data is kept under review by the Directors and this Data Privacy Notice may be revised from time to time. Where our processing of your personal data relies on your consent we will provide you with a new notice explaining any new purposes and processing conditions and seek your prior consent prior to commencing such processing.
To exercise all relevant rights, queries or complaints please in the first instance contact:
Dr Andrew Mowat
The Lincolnshire Refugee Doctor Project
Edition Dated: June 2018