This page explains our privacy policy and how we will use and protect any information about you that you provide when registering with our Learning Management System.

This privacy notice is intended to provide transparency regarding what personal data Invicta Health CIC may hold about you, how it will be processed and stored, how long it will be retained and who may have access to your data.

Personal data is any information relating to an identified or identifiable living person (the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number or factors specific to the physical, genetic or mental identity of that person, for example.

What this privacy statement covers

This privacy statement only covers the processing of personal data by Invicta Health CIC that Invicta Health CIC has obtained from data subjects accessing the Invicta Health Learning Management System and from its provision of services and exercise of functions. It does not cover the processing of data by any sites that can be linked via the LMS so you should always be aware when you are moving to another site and read the privacy statement on that website.

When providing Invicta Health CIC with any of your personal data for the first time, for example, when you register for the Invicta Health Learning Management System, you will be asked to confirm that you have read and accepted our terms and conditions and this privacy statement. A copy of your acknowledgement will be retained for reference.

If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing the page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

Why Invicta Health CIC collects your personal data

Your personal data is collected and processed for the purposes of and in connection with the functions that Invicta Health CIC performs with regard to workforce education and planning. The collection and processing of such data is necessary for the purposes of those functions.

In connection with training, Invicta Health CIC collects and uses your personal information for the following purposes:

1. To manage your training and programme
2. To quality check the training programme and provide assurance that standards are maintained
3. To identify workforce planning targets
4. To contact you about training opportunities, events, surveys and information that may be of interest to you

We also collect and use personal information from you so that we can provide education and training to you, to promote our services, to monitor our own accounts and records, to monitor our work, to report on progress made, and to let us fulfil our contractual obligations with the Kent LMC.

Collection and use of data from website users

When you access the Invicta Health Learning Management System, small amounts of information are sometimes placed on your device, including small files known as cookies. These pieces of information are used to improve services for you. For example, we use a series of cookies to monitor website speed and usage, as well as to ensure that any preferences you have selected previously are the same when you return to our website.

On a number of pages we use ‘plug ins’ or embedded media. For example, we might embed YouTube videos in pages. The suppliers of these services may also set cookies on your device when you visit the pages where we have used this type of content. These are known as ‘third-party’ cookies. To opt-out of third-parties collecting any data regarding your interaction on our website, please refer to their websites for further information.

We will not use cookies to collect personal data about you. However, if you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies. Please be aware that restricting cookies may impact on the functionality of our website.

Invicta Health CIC as data controller

Invicta Health CIC is the data controller in respect of any personal data it holds.

Lawful basis for processing

The GDPR requires that data controllers and organisations that process personal data demonstrate compliance with its provisions. This involves publishing our basis for lawful processing and that law we have a valid lawful basis to process personal data. The GDPR requires us to be accountable and transparent about our lawful basis for processing.

As personal data is processed for the purposes of IHL’s contractual functions, IHL’s lawful bases for the processing of personal data as listed in Article 6 of the GDPR are as follows:

– 6(1)(a) – Consent of the data subject
– 6(1)(b) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
– 6(1)(c) – Processing is necessary for compliance with a legal obligation

Where IHL processes special categories of personal data, its additional legal bases for processing such data as listed in Article 9 of the GDPR are as follows:

– 9(2)(a) – Explicit consent of the data subject

Please note that not all of the above legal bases will apply for each type of processing activity that IHL may undertake. However, when processing any personal data for any particular purpose, one or more of the above legal bases will apply.

We may seek your consent for some processing activities, for example for sending out invitations to you to training events. If you do not give consent for us to use your data for these purposes, we will not use your data for these purposes, but your data may still be retained by us and used by us for other processing activities based on the above lawful conditions for processing.

How we protect your personal data

The personal data we hold will be held as an electronic record on the Invicta Health Learning Management System. These records are only accessed, seen and used as required and/or permitted by law by staff who need access to personal data, so they can do their jobs and other partner organisations under data sharing agreements.

The security of the data is assured through the implementation of Invicta Health CIC’s policies on Information Governance management.

We make every effort to keep your personal information accurate and up to date, but in some cases, we are reliant on you as the data subject to notify us of any necessary changes to your personal data. If you tell us of any changes in your circumstances, we can update the records with personal data you choose to share with us.

We will not keep personal data for any longer than necessary, in line with our terms and conditions.

Sharing personal data

So that we can provide the right services at the right level, we may share your personal data with other third-party organisations such as our training providers, the Kent Local Medical Committee, the Clinical Commissioning Groups and other organisations where necessary to provide the best possible training and education. This will be on a legitimate need to know basis only.

We may also share information, where necessary, to prevent, detect or assist in the investigation of fraud or criminal activity, to assist in the administration of justice, for the purposes of seeking legal advice or exercising or defending legal rights or as otherwise required by the law.

Your rights

Right to rectification and erasure

The GDPR extends and strengthens your rights as a data subject. Under the GDPR you have the right to rectification of inaccurate personal data and the right to request the erasure of your personal data.

Right to object

You have the right in certain circumstances to ask IHL to stop processing your personal data in relation to any IHL service. As set out above, you can decide that you do not wish to receive information from IHL about matters of policy affecting education, training and workforce. However, the right to object is not an absolute right and it may be that it is necessary in certain circumstances for IHL to continue to process your personal data for a number of lawful and legitimate reasons.

If you object to the way in which IHL is processing your personal information or if you wish to ask IHL to stop processing your personal data, please contact the Invicta Health CIC office. However, if we do stop processing personal data about you, this may prevent IHL from providing the best possible service to you.

Subject Access

You can access a copy of the information Invicta Health CIC holds about you by writing to our Data Protection Officer via Invicta Heath CIC, Innovation House, Ramsgate Road Sandwich CT13 9FF. This information is generally available to you free of charge subject to the receipt of appropriate identification.

If you want to complain about how we have used your personal data or to know more about how your information will be used, please contact Invicta Health CIC, Innovation House, Ramsgate Road Sandwich CT13 9FF.

Alternatively, you can also contact the Information Commissioner if you have a complaint about our processing of your personal data:

The Office of the Information Commissioner

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Your responsibilities

It is important that you work with us to ensure that the information we hold about you is accurate and up to date so please inform Invicta Health CIC if any of your personal data needs to be updated or corrected.

All communications from Invicta Health CIC will normally be sent by email. It is therefore essential for you to maintain an effective and secure email address or you may not receive information or other important news and information about your training.

 

Version 1, 15.06.2018