Privacy Notice

Last updated 10 December 2018

Introduction

GP Update Limited (trading as Red Whale) takes your privacy very seriously.  We ask you to read this Privacy Policy carefully as it contains important information about what to expect when we collect information about you and how we will use your personal data.


Why do we need your information?

We use personal data to do three things:

1. Perform our contractual duty towards you or fulfil a request you have made to us, ie. Ship a handbook order, get you booked on one of our courses, track your CPD credits, provide you a quote for a private course etc.

2. Keep you informed about clinical or operational matters applicable to General Practice and the products we offer.

3. Perform our legal obligations as a company eg. Pay HMRC.


Whose data do we collect?

We hold data on anyone who has attended a course or bought or commissioned a product or service from us (including subscribing to our online content).
We also hold data of those who we think might be interested in our products and services.


How we obtain your data

The majority of the information we hold about you has been provided directly to us by you:

(i) on forms on our websites,
(ii) in response to marketing or other communications,
(iii) through social media,
(iv) by signing up for a course, product or service,
(v) through participation in an offer, program or promotion,
(vi) in connection with an actual or potential business or employment relationship with us.

In some cases we may collect data from someone else.
For example, you may have instructed a colleague to book you on a course or you may have chosen to consent to third parties disclosing information about you to us that those third parties have collected.
We may collect data from publicly available sources. Examples include information gathered from a news article or on-line media, including social media like LinkedIn or Twitter. We may also use publicly available directories and similar information such as Companies’ House.


What we do with your data and why
If you are a delegate, customer or business contact

The core purpose of our data processing is to ensure you receive the products and services you expect from us.
In order to fulfil this, we will use the data we collect about you to perform our obligations to you under the contract we have signed, or to provide you with the information you have requested.
This includes letting you know about the date and location of the course you are booked on and any after course email to explain how to use the online access you have received.
We will also use this information to send you communications about clinical updates and product information we publish via e-mail or post.
We may use data obtained other than from you to ensure that your contact details are up to date.
We collect the following classes of information:

• Contact information (Title, Name and address, email)
• Business contact information (such as job title, department and name and address of organisation/surgery, professional registration numbers eg. GMC, NMC etc.)
• Mobile number – only used to let you know about a last-minute change to your booking
• Information about our relationship with you, correspondence, meeting notes, booking and attendance at courses, details of your subscription to our products etc.
• CPD information you enter on our website in order to fulfil any requirement for revalidation.
• Contact information for colleagues or other delegates who you might book on our courses on their behalf. 
• Other information you provide (such as any information that you provide when you contact us about a booking).
• Content you make available through social media accounts or memberships with third parties.
• Geo-location data.
• Information about your activity on our site; which emails you have opened, which links you have clicked, which content you have accessed, searches you have performed, which emails you have shared.

If you are a clinician or manager in the UK or Ireland and you have never purchased from us

The core purpose of our data processing is to inform you about the products and services we offer via e-mail or post.
We may use data obtained other than from you to ensure that your contact details are up to date.
We collect the following classes of information:

• Title, Name and address of office or surgery, email address

We also utilise a third party, Google, to track the usage and volume of users on our website. The information it collects is not in any way associated with the details we hold about you online.


How we look after your information

We keep your data secure in our database with appropriate security mechanisms in place.
We do not share your data with anyone else or any other organisation unless it is necessary for the purpose for which you have given us the data or required by law. Examples are given below:

• We may share basic information on the attendees at a course with the venue and/or event organiser.
• We may pass data to other organisations, known as Data Processors, to provide specific services to us. An example would be providing data to a mailing house in order to send a newsletter. A contract is always in place with a Data Processor, and they are not allowed to do anything with your data other than what we have requested.

We require these service providers by contract to safeguard the privacy and security of personal information they process on our behalf.


Our responsibilities

The law requires us to tell you the basis on which we process your data.

• Some activities (for example sending you emails which promote our courses and products and those of our partners) require your consent. If the law requires your consent to process data in a certain way then we will obtain it before carrying out that activity.
• Other activities are carried out to fulfil a contract or agreement. Examples include sending you a confirmation email after booking on a course or ordering a handbook. Each requires us to know who you are and to process your information in order to do the thing you have asked us to do. If a contract is in place then we will process your data based on that contract.
• In all other cases the law allows us to process your data if it is in our legitimate interest to do so, but only so long as we need to and your “interests or your fundamental rights and freedoms are not overriding”. We may send you postal mailings under this basis.

We will keep data for as long as is needed to complete the task for which it was collected. Relationships between Red Whale and delegates may be long term, and so we expect to keep your data for as long as that relationship exists, or until we no longer need it.


Your rights

You have a variety of rights about the way we process your data. These are as follows:

• Where our use of your data requires consent, you may withdraw this consent at any time. You can do so by clicking the unsubscribe button at the bottom of every email we send you.
• Where we rely on our legitimate interest to process data, you may ask us to stop doing so by contacting us at mail@red-whale.co.uk.
• You may request a copy of the data we hold about you.
• You may ask us to change or stop the way in which we communicate with you or process data about you, and if it is not required for the purpose you provided it, then we will do so. Activities such as fulfilling our contractual obligations to you, may mean we cannot entirely stop processing your data.  However, we will always endeavour to comply with such a request.
• If we fail to address an issue or complaint within the time applicable by law, you have the right to contact the Information Commissioner’s Office (ICO) on https://ico.org.uk/global/contact-us/ or their helpline on telephone: 0303 123 1113

Contacting us

If you have any questions about this privacy notice, about the way in which we process your data, or if you wish to change the way we use your data, including how we communicate with you, then please contact us:

GP Update – Red Whale, University of Reading, Reading Enterprise Centre, Earley Gate, Whiteknights Road, Reading, RG6 6BU
E: mail@red-whale.co.uk


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