1.0 Introduction
The Faculty of Medical Leadership and Management (FMLM), takes the protection of personal data very seriously and strictly adheres to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-UK).
This privacy notice gives you information on how FMLM collects and processes your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.
We have appointed a Data Protection Officer (DPO) who is responsible for monitoring and providing guidance on our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.
2.0 Why we Collect your personal information
We collect your personal data for one of the following purposes:
- To manage communications between you and us.
- Where we need to perform a contract that we have entered into with you.
- To provide you with information you have requested or which we may feel may be of interest to you.
- To ensure the safe operation of our website and to monitor the performance of our website.
- For marketing and advertising purposes.
- To allow you to create an account and access resources via the FMLM website.
- To process membership applications and provide membership services to you.
- To process Fellowship applications.
- To provide Appraisal and Revalidation services.
- To administer the recruitment and management of Clinical Fellows Schemes.
- To process payments to and from you.
- To process payments.
- To process event registrations.
- FMLM collect information from you to be able to administer the activity for which you signed up to access and to communicate with you for the purposes of effectively providing this service to you.
- Information about what data FMLM collect and how it will be used is outlined at the relevant collection point where FMLM request information from you.
- FMLM collect personal data for statistical purposes to analyse current and historic trends in service usage.
- FMLM collect data relating to your career stage including job title, career grade, region and specialty to be able to provide you with relevant information including services, programmes and events that you may be interested in accessing.
2.1 How FMLM handles your data within specific business areas
Clinical Fellows Schemes
For each of the leadership schemes, upon submitting an application to a scheme, candidates consent to their data being shared between FMLM and potential host organisations.
Fellowship Applications
Application data is managed by FMLM and is shared for the purpose of assessing applications and to make relevant recommendations on awarding fellowship. All assessors act of FMLM’s behalf and treat all data with the strictest confidence.
Application material for successful applicants i.e. those awarded fellowship at any level, is retained indefinitely as FMLM will have the right to retain this information for public interest purposes (Article 17) as the award of Fellowship is an accreditation of an individual's skills and experiences.
Application material for unsuccessful applicants i.e. those not awarded fellowship on any level, are retained for one year after assessment.
Membership
FMLM membership records are all administered online via the FMLM CRM.
Membership records are kept indefinitely for the purpose of maintaining records of public interest and for monitoring historic trends and reporting. Inactive membership records will be reviewed annual to ensure only appropriate data is stored.
Events
Details of events registrations are kept indefinitely for reasons of public interest, security and CPD records for events that these are applicable for.
FMLM will only collect data from a delegate that is required for the administration of the event.
Any sharing of data with third parties is outlined during the registration process for each specific event.
Delegates will have the option to share their data with sponsors as outlined in the registration process.
FMLM Applied
FMLM Applied Ltd provides leadership development programmes to organisations. FMLM Applied collects limited personal and professional data from commissioning organisations on behalf of participants.
FMLM Applied will only collect and hold data from a participant that is required for the administration of the programme. FMLM Applied will only share data with third parties explicitly involved in the running and administration of the programme.
3.0 Lawful Basis of Processing Information
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
- The data subject (you) has given consent to the processing activity taking place.
- If the processing is necessary for the performance of a contract.
- If the processing is necessary for compliance with a legal obligation to which the controller is subject.
- If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners e.g. for direct marketing purposes, to prevent fraud or to ensure the network and information security of our IT systems.
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
The purpose test – to identify the legitimate interest.
Necessity test – to consider if the processing is necessary for the purpose identified.
Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.
4.0 What Information we collect and where from
We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:
- Name, address, telephone number, email.
- IP address
- Your country of birth, nationality.
- Date of birth and gender.
- Employment history.
- Professional background/experience.
- Job title.
- Qualifications.
- Organisation information and personal stories.
4.1 Special Category Data
We may collect the following special category data from you:
- Health data.
- Racial or ethnic original.
- Religious or philosophical beliefs.
- Data concerning sex life or sexual orientation.
We will only process special category data where we have an Article 9 exception allowing us to do so, in this case, processing is necessary for reasons of substantial public interest.
5.0 How Long we Keep Information For
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 16 of this policy.
6.0 Security of personal information
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 16 of this policy.
7.0 Children's information
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.
8.0 Your individual rights
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
The right to object:
You can exercise this right if:
- Processing relies on legitimate interest.
- Processing is for scientific or historical research.
- Processing includes automated decision making and profiling.
- Processing is for direct marketing purposes.
The right of access:
- You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
- We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
The right to be informed:
We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
The right of rectification:
If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
The right to erasure:
If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
The right to restrict processing:
You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
- Processing is unlawful.
- We no longer need the personal data, but it is required for a legal process.
- You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
- If you are exercising your right to rectification.
The right to data portability:
- You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
- Processing is based on consent.
- Processing is by automated means (i.e. not paper based).
- Processing is necessary for the fulfilment of a contractual obligation.
If you have any question about these rights, please see "additional information", section 16 of this policy.
9.0 Consent
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
10.0 Failure To Provide Personal Information
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
11.0 Cookies
Our website uses cookies. Please see our cookies policy for full details of the cookies used.
12.0 Automated Decision Making
Your personal data is used in automated decision making (a decision made solely by automated means without any human involvement)/ profiling (automated processing of personal data to evaluate certain conditions about an individual) e.g. for direct marketing purposes, updating data or to ensure the network and information security of our IT system.
Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.
13.0 Transfers To Third Parties
FMLM may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
- Business partners, universities, academics, suppliers, contractors for the performance of any contract we enter into with them or you.
- Companies within our group where necessary for administrative purposes and to provide services to you.
- Third parties that support us to provide products and services e.g. IT support, cloud-based software services, providers of telecommunications equipment).
- Marketing services providers.
- Payment service providers.
- Recruitment service providers.
- Professional advisors e.g. lawyers, auditors.
- Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
14.0 Transfers Outside Of The UK
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).
We may share personal information to third parties outside of the United Kingdom (UK). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
- Standard Contractual Clauses plus UK Addendum.
- International Data Transfer Agreement.
- An exception as defined in Article 49 of the EU GDPR.
For more information about transfers and safeguarding measures, please contact us using the information in section 16.
15.0 Right to complain
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on enquiries@fmlm.ac.uk.
You can also contact us:
By Post: FMLM, 167-169 Great Portland Street, Fifth Floor, London, W1W 5PF.
By Phone: 020 3137 3643.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
By Email/Live Chat: https://ico.org.uk/make-a-complaint/
By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)
16.0 Additional information
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO via enquiries@fmlm.ac.uk
17.0 Policy Review and Amendments
We keep this Policy under regular review. This Policy was last updated on in May 2024.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.