Privacy Policy

Privacy Policy (version 1 – April 2018)

We respect your right to privacy. This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. Please read this Privacy Policy carefully.

  1. About Us

1.1       In this Privacy Policy, references to “we” or “us” are to The Christie NHS Foundation Trust, whose registered office is at The Christie Hospital, Wilmslow Road, Manchester, M20 4BX, who will be the controller of any personal data processed as described in this Privacy Policy.

  1. Use of the Website and Online Courses and Content

2.1       This Privacy Policy applies only to your use of GatewayC and Online Courses and Content. Partner Institutions who provide the Online Courses and Content or other linking sites found on the Website may also gather information and you should consult those other parties’ privacy policies as appropriate and applicable.

  1. Collection of Information

3.1       When you access GatewayC via any means, registering for access, using online modules and content, respond to or participate in any survey or questionnaire sent to you by us, provide comments via the feedback tab, we may collect, store and use certain of your personal information in line with this policy. We may also ask you for information when you report a problem with GatewayC.

3.2       To register with GatewayC, we ask for your name, email address and your job role.  We also ask for information about the General Practice you are connected with.  As part of your profile on GatewayC you may also provide your location and other information that will help other participants get to know you and help us to tailor the service to suit you. We will also store data you have input as part of your learning on GatewayC.

3.3       We will also collect data relating to your visits to the GatewayC that cannot identify you but records your use of the learning platform, for example, details of how long you have used GatewayC for.

3.4       We may receive information about you from third parties (such as Clinical Commissioning Groups) who will pass on your personal details in order for us to contact you to register on the site.

  1. Use of Your Information

4.1       By accessing GatewayC via any means, registering for access, using online modules and content, respond to or participate in any survey or questionnaire sent to you by us, provide comments via the feedback tab, you agree that your personal information may be collected, stored, used and shared by us and our partners, course and content providers, or third parties we work with, for any of the following purposes:

4.1.i            to provide, maintain, protect and improve the quality of GatewayC, including by conducting anonymised market research, and to protect us and our users;

4.1.ii           to provide you with a personalised browsing experience when using the GatewayC;

4.1.iii          to fulfil any contractual agreements between you and us and any third party who has commissioned the education on your behalf;

4.1.iv         to send you details of modules, study days and events which we think may interest you, unless you opt out as described at paragraph 9.1.3 below.

4.1.v          to manage the personal account that you hold with us;

4.1.vi         to allow you to use the full range of features on or via GatewayC;

4.1.vii        to send you course-specific email notifications and updates about modules you are enrolled on;

4.1.viii       to comply with legal and regulatory requirements;

4.1.ix         to contact you occasionally in order to invite you to share your opinions and experiences of GatewayC;

4.1.x          to allow other partner institutions to perform research (as more fully set out in paragraph 12 below)

4.2       We may use your email address to send you course notices and updates about our Services.

  1. Storage of Information

5.1       All information is stored on secure servers. When you register, we will ask you to choose a password which enables you to access GatewayC. You are responsible for keeping this password confidential. We ask you not to share this password with anyone.

  1. Legal Basis for Processing Your Information

6.1       Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

6.2       However, we will normally collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you/on your behalf via a third party purchaser or (iii) where the processing is in our legitimate interests and not overridden by your rights.

  1. Disclosure of Your Information

7.1       We may disclose your personal information to third parties when permitted by law including:

7.1.i            with your consent;
7.1.ii           to our commissioning organisations who have purchased GatewayC on your behalf;
7.1.iii          to organisations who are undertaking research into the value of GatewayC;
7.1.iv         our provider of customer relationship management services (which allows us, for example, to send personalised email communications to you);
7.1.v          These organisations’ use of your personal data may be subject to their own privacy policies, which are available on their websites.
7.1.vi         if we are under a duty to disclose or share your information in order to comply with any legal obligation.

  1. Data Retention

8.1.     We retain personal information we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with a service you have requested or to comply with accreditation by external bodies, i.e. Royal College of General Practitioners).

8.2.     In line with the fifth data protection principle, when we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  1. Your Rights

9.1.     You have the following data protection rights:

9.1.i            You can edit your personal details via your profile page whenever you wish.  We maintain a procedure in order to help you confirm that your personal information remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners.

9.1.ii           In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the ‘Contacting GatewayC’ heading below.

9.1.iii          You may unsubscribe from certain email communications by following the Unsubscribe link in the email communication itself. You may also update your personal information by logging into GatewayC and visiting your account page. You may also email us at gatewayc@christie.nhs.uk in order to access, correct, delete or update your personal information on our systems. We will answer every email as promptly as possible.

9.1.iv         Similarly, if we have collected and process your personal information on the basis of your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

9.1.v          You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority.

9.1.vi         GatewayC may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. Please check these policies before you submit any personal information to these websites.

9.1.vii        You may obtain a copy of your personal data that we have collected and this will be returned in a commonly used electronic form. If you wish to access your personal data then you will need to make a request in writing to the address found under the heading 13.1 Contacting GatewayC.

  1. Cookies

10.1        GatewayC uses cookies. Cookies are small files stored on your computer’s hard drive which are used to collect your personal information. You may choose to refuse cookies but, if you do so, some of the functionality of GatewayC may no longer be available to you.

  1. Research

11.1        Partner institutions that support GatewayC by purchasing it on your behalf may carry out research on your use of the site. Research will always be conducted in accordance with current best practice.

  1. Updating this Privacy Policy

12.1        We may update or amend this Privacy Policy from time to time, to comply with law or to meet our changing business requirements. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

  1. Contacting GatewayC

13.1        If you have any questions, comments or complaints about this Privacy Policy, please contact us using the details below:

Programme Manager

GatewayC
The Christie School of Oncology
Wilmslow Road
Manchester  M20 4BX
E-mail:   GatewayC@christie.nhs.uk