Privacy policy

Introduction

The Royal College of Speech and Language Therapists (“the RCSLT”) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use your personal information about you, in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (together, “the Regulations”). This privacy notice applies to RCSLT members and non-members who access RCSLT services or who engage with the RCSLT as interested stakeholders, as indicated.

The RCSLT is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Under the Regulations you have a right to be informed about why we collect and how we use the data we hold about you.

This notice does not form part of any contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with the Regulations. This says that the personal information we hold about you must be:

• Fairly and lawfully processed in a transparent way
• Collected and processed for specified, explicit and legitimate purposes and not in any other way which would be incompatible with those purposes
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
• Accurate and kept up to date
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed
• Processed in a manner that ensures appropriate security of personal data
• In addition the RCSLT will ensure that personal data
  • will be processed in line with your rights as a data subject
  • will not be transferred to a country which does not have adequate data protection laws.

How your personal information is collected

RCSLT MEMBERS

Your personal data is held on a customer relationship management (CRM) system which is linked to the RCSLT website. We are using tried and tested proprietary software for this, which is GDPR compliant. You are able to access and change your data through the website. We also hold some of your personal data (e.g. email addresses) in our Outlook address lists and emails, and also in spreadsheets on our secure internal systems.

How we will use information about you (legal basis)

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where it is necessary to perform the membership contract we have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

You are able to add, amend or delete your personal information through your member profile via the RCSLT website or by contacting us by phone (0207 378 1200) or contact us. The default setting of your member profile will be “private”, but you will be able to easily change it to “visible” if you wish. We are encouraging all members to do this as part of our desire to enable members to better engage with the RCSLT and each other. You may also subscribe to the member directory, which will show only your name and area of clinical interest. This will default to a “private” setting, but again, we are encouraging members to make themselves “public” for networking purposes.

NON-MEMBERS

Your personal data is held in the CRM database, our Outlook address list and emails, and also in spreadsheets on our secure internal systems. You are able to add, amend or delete your personal information by contacting us by phone (0207 378 1200) or contact us.

How we will use information about you (legal basis)

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to comply with a legal or regulatory obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

For everyone:

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your vital interests (or someone else’s vital interests).
2. Where it is needed in the public interest or for official purposes.

We will never sell your personal data to a third party.

Situations in which we will use your personal information

For RCSLT members, we need all the categories of information detailed in the list above primarily to allow us to perform our membership contract with you, to further the RCSLT’s operations and influencing and to enable us to comply with legal and regulatory obligations. For non-members, we will use your information to further the RCSLT’s operations and influencing.

In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. In those cases we will apply and document a legitimate interests test before using your information. This is a simple, standard test approved by the ICO to assist in determining whether we should use your personal information for the purpose we envisage.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to provide the full functionality of membership services that we would like to provide to you, or our ability to influence and fulfil our charitable purposes may be restricted.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your consent and in rare cases without your knowledge, in compliance with the above rules, where this is required or permitted by law.

Do we need your consent?

RCSLT members

If you are an RCSLT member we do not need your consent to process your personal data in order to fulfil the contract between the RCSLT and yourself to provide membership services.

Non-RCSLT members

If you are not an RCSLT member but you are a stakeholder with whom we would like to engage in order to promote the RCSLT or generally to enhance the provision of Speech and Language Therapy services in accordance with our objects and for the public benefit, we will ask your consent for us to process your personal data, which will generally be limited to your name, email address and telephone number. We will do this by an email request, and it will be made clear at the time what information we are asking for and how we are going to use it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us or phone us on 0207 378 1200.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to.

Data sharing

We may have to share your data with third parties, including third-party service providers, for example, in order to conduct membership surveys and to operate our IT systems. If we do share your data with third parties we will use GDPR compliant contracts. In the unlikely event that your personal information has to be transferred outside the EU we will ensure that we will use contracts that give your personal data an agreed similar degree of protection as under GDPR (e.g. EU/US Privacy Shield).

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, or where it is necessary to administer our working relationship with you or where our legitimate interest in doing so is not over-ridden by your rights and freedoms.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following are illustrative, but not exhaustive, of the kinds of activities that are carried out by third-party service providers: direct debit services, IT services, webinar providers, which are carried out under strict standards set out by the RCSLT in GDPR compliant contracts.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have been bound by contract to fulfil their obligations under Article 28 of GDPR.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach. A suspected data breach will always be investigated internally first. We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy and are available upon request. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a member of the RCSLT, we will retain and securely destroy your personal information in accordance with our data retention policy or current applicable laws and regulations.

Rights of access, correction, erasure and restriction

Keeping your data up to date

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes whilst you are a member of the RCSLT. You can do this by amending your member profile online. For non-members, please contact us so that we may update your details.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the CRM manager at the RCSLT by contacting us.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, in very rare circumstances, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to complain

You have the right to make a complaint using the RCSLT’s member complaints procedure.

Or you may complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Data Protection Officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information; you may contact the DPO.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will inform you when we make any substantial updates and signpost you to the new version. We may also notify you in other ways from time to time about the processing of your personal information.

October 2018