Privacy Policy
Naveg Academy Fair Processing Notice Last updated: 30 May 2020
Your privacy is very important to us, which is why we make sure you are always in control of what we do with your personal information.
The purpose of this Notice is to tell you what information we collect from you, how and when it will be collected and what happens to it. For the purpose of this Notice, “we”, “our” and “us” refer to Naveg Academy as an organisation (also referred to as “NACAD”).
We are a complex organisation and we interact with people in varied ways. This notice deals with the way we handle information under various headings (Web-site and other users, Members, Candidates, Individuals who work with the NACAD, Organisations who work with the NACAD). Depending on your relationship with the Academy more than one of these categories will apply to you. You should also refer to the information included in the section headed General.
NACAD is a data controller and can be contacted using the contact details below.
This Notice only applies to personal information processed by or on behalf of NACAD. Third party websites and services we link to through our websites have their own privacy policies, independent of us. We hold no responsibility or liability for those independent policies. We encourage you to look for and review the privacy policies of any third-party website you visit.
We will collect information from you when you visit our website, use our services, contact us by telephone or email or receive a communication from us relating to our services. If you are a business customer, this Notice applies to the information you provide to us about individual participants / contacts from within your business (for example directors), or information about you as a sole trader or partnership.
Contact Us
Ground Floor, 4 Quadrum Office Park, 50 Constantia Boulevard, Constantia Kloof, JHB
Tel.: +27 11 678 0653
If you have a specific question about this Notice or how we use your personal information, you should contact us at the above address or email address; please mark your communication as “Data Protection Enquiry”.
Website and Other Users
The Information We Collect About You
We collect information to provide you with a better experience of using our websites and applications and to facilitate our audiences, and visitors to NACAD website and users of our premises and facilities amongst other reasons (see the “How will NACAD use my information?” section below). In order to provide you with access to certain services or data within our websites and applications, or to our services our premises and facilities we will require that you provide certain personal information. This information will include:
- Your name, postal address, telephone number, e-mail address, subscriber name or screen name, password used to access our services, country of residence and/or method of payment;
- personal data related to your professional status, your job title, your practice location, your area of practice, if you are a student or if you contact us with a query about your membership your course information;
- personal and contact details you give us when subscribing to receive marketing information from us (for example name, role and email address);
- information we collect via cookies or similar technology stored on your device about how you use our website
- your IP address;
- information from our web servers about online activity;
- information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
- information you provide if you report a problem with our website or
We will collect and process your personal information in accordance with this Notice.
If you make an enquiry via our website, on the telephone or via email, or via any third party, we will collect the information you provide to us, together with any information provided by that third party. We will monitor and record telephone and written correspondence with you to train our staff and monitor our services.
We also obtain information from other sources of data, including information about you from 3rd party organisations, including providers of healthcare sector intelligence, insights, data and analytics. We will only accept and use information about you from reputable organisations who have either obtained your permission to share your information with us or who have collated information about you from publicly available sources. Occasionally we might receive information about you from a trusted NACAD partner organisation who will have sought your prior consent to share it with us.
How Will NACAD Use My Information?
We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful” reasons for which we are entitled to process your personal data. The table below sets out under which lawful basis we process different information about you, and explains the purpose of that processing. It also sets out the specific rights you have in respect of that processing, which will depend on the basis we process it for.
Personal Information |
Basis of Processing |
Purposes of Processing |
Source Information Originated From |
Your name, postal address, telephone number, fax number, e-mail address, your job title, career information, GMC number, and method of payment |
It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. |
• To provide you with access to certain services or data without our websites and applications • To create an electronic record of your data to enable your request for information to be processed • To consider any applications you make for membership • To help us manage and run any services we provide to you • To administer and manage the products and services we make available to you • To compile delegate lists for distribution to attendees at our events, or for advertising future courses and events promoting NACAD • To manage and administer events run by NACAD or on our premises or using our facilities • To help us identify products and services which we think will interest you (unless you have asked us not to) • For user account administration within NACAD • To assist us with statistical analysis, profiling, financial risk assessment, compliance/regulatory |
• Logging the Internet Protocol (IP) address of your computer to be able to receive and send information on the internet • Collecting personal data when you register or update your personal details using online forms and accounts • Recording data through cookies |
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reporting, fraud prevention and compliance with our legal obligations, policies and procedures • We will also communicate with you on behalf of other organisation’s, should you opt in to receiving third party communications. |
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information collected in surveys (including exit |
Processing is necessary for the purposes of the legitimate interests of NACAD. |
• To monitor experience with the specific legitimate interest of providing easily accessible, relevant and current services to our members and seeking to continuously develop the accessibility, quality and relevance of our services. We have conducted a balancing test in relation to this interest and consider that our processes have a minimal impact on the privacy of our users and members • For the purpose of maintaining marketing suppression lists. The specific legitimate interest pursued is ensuring compliance with regulations and meeting the wishes of our members. We have conducted a balancing test in relation to this interest and consider that our processes have a minimal impact on the privacy of our users and members |
• Collecting other information from you from time to time to support NACAD’s policy and educational work and as part of member experience surveys or questionnaires |
• name • role • contact details • details of contact with us • date of birth, gender, ethnic origin • membership number |
• You have given us your consent. |
• To enable NACAD to comply with its policies regarding equality • To market to you by email or other electronic means, if you are an individual, sole trader or partnership. • To provide information requested to you. |
• Collecting personal data when you Register or update your personal details using online forms and accounts |
Sharing Information
We will share your personal information within NACAD and Naveg Technologies for the purposes of shared services or business management and optimization.
We will share your information:
- to third parties who operate our premises and services or to provide a service or benefit to you or for us in connection NACAD’s activities, including events and accommodation, facilities and security and those involved in providing and supporting our IT;
- for the purpose of our compliance and regulatory reporting, or to confirm your identity for anti- money laundering purposes
- if we have been asked to provide information about you for legal or regulatory
Retaining Information
We will retain your information for as long as is needed for the purposes set out in this notice or as will be agreed in any specific registration form or other application you complete.
Subject to that, we will retain your personal information for five years.
In certain circumstances, we will be required to retain your personal information for longer, where such retention is required by law or record keeping requirements, including managing our relationship with you, defending any claims, or for tax purposes.
People Who Work With NACAD
The Information We Collect About You
This section applies to individuals (other than employees) who work with the NACAD in any capacity. It covers examiners, assessors, clinical champions, clinical support fellows, clinical and other advisers, members of editorial panels, representatives, and any business dealing with NACAD as a partnership or sole trader
We collect your information in connection with the work you do with the NACAD and any services that you provide to the NACAD, including the recruitment/tendering/procurement process and the management of the contract and your work or services. This information will include:
- Your name, postal address, telephone number, fax number, e-mail address;
- The information you provide in any application form
- The information you provide or record in any electronic portfolio or documents submitted by you in support of any
- information you provide when you register for events and services;
- Your bank details, national insurance number and other tax details
- payment details
We will also obtain information from other sources of data, including referees. We will only accept and use information about you from reputable organisations who have either obtained your permission to share your information with us or who have collated information about you from publicly available sources
We will collect and process your personal information in accordance with this Notice.
How Will NACAD Use My Information?
We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful” reasons for which we are entitled to process your personal data. The table below sets out under which lawful basis we process different information about you, and explains the purpose of that processing. It also sets out the specific rights you have in respect of that processing, which will depend on the basis we process it for.
Personal Information |
Basis of Processing |
Purposes of Processing |
Source Information Originated From |
Your name, postal address, telephone number, e- mail address, your job title, career information, ID number, other details you provide during the recruitment/tendering/procurement process, banking information |
It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. |
• To ensure we hold appropriate records of you, your role in the NACAD, the services you provide to the NACAD • To enable NACAD to comply with the terms of any contract |
The personal information that we hold about you has either been provided by you through the completion of forms or through your communications with the NACAD or |
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• To monitor performance and assess against objectives • To comply with statutory or regulatory duties such as Health and Safety |
by third parties providing services to the NACAD in connection with your appointment |
CCTV (examiners) |
Processing is necessary for the purposes of the legitimate interests of the organization. |
Monitoring and quality assurance of examinations and training
We consider these to be legitimate interests of an organization which administers examinations and qualifications which are key to effective public health care in the UK. We have conducted a balancing test and consider that our processes have a minimal impact on your privacy |
CCTV cameras placed in examination areas |
Sharing Information
We will share your personal information within NACAD and with its wholly owned subsidiaries NACAD Enterprises Limited and NACAD Conferences Limited for the purposes of shared services or business management and optimisation.
We will share your information:
- to third parties who operate our premises and services or our business systems, including events and accommodation partners, and those involved in providing and supporting our IT;
- for the purpose of our compliance and regulatory reporting,
- if we have been asked to provide information about you for legal or regulatory
Retaining Information
We will retain your information for as long as is needed for the purposes set out in this notice or as will be agreed in any specific application you complete.
Subject to that, we will retain your personal information for the duration of the period you work with the NACAD (whether in your current capacity or some other) and for a further five years.
In certain circumstances, we will be required to retain your personal information for longer, where such retention is required by law or record keeping requirements, including managing our relationship with you, defending any claims, or for tax purposes.
Organisations which work with the NACAD
The Information We Collect About You
This section applies to organisations which work with the NACAD either in a commercial capacity or as part of any other form of engagement with our work
During the course of that activity we will acquire personal data about your staff and those you work with. This information will include:
- an individual’s name, postal address, telephone number, e-mail address
- information you or the individual provide when registering for events and services;
- personal information included in written or other communications
We will collect and process any such personal information in accordance with this Notice.
How Will NACAD Use My Information?
We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful” reasons for which we are entitled to process your personal data. The table below sets out under which lawful basis we process different information about you, and explains the purpose of that processing. It also sets out the specific rights you have in respect of that processing, which will depend on the basis we process it for.
Personal Information |
Basis of Processing |
Purposes of Processing |
Source Information Originated From |
name, postal address, telephone number, e-mail address, your job title, career information, registration number, other details provided during the recruitment/tendering/procurement process |
It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. |
• To ensure we hold appropriate records of your key personnel and their roles in your organization and in the services you provide to the NACAD • To enable NACAD to comply with the terms of any contract |
The personal information that we hold about you has either been provided by you through the completion of forms or through communications |
Sharing Information
We will share your personal information within NACAD and with its wholly owned subsidiaries NACAD Enterprises Limited and NACAD Conferences Limited for the purposes of shared services or business management and optimisation.
We will share your information:
- with third parties who operate our premises and services or our business systems, including events and accommodation partners, and those involved in providing and supporting our IT;
- for the purpose of our compliance and regulatory reporting,
- if we have been asked to provide information about you for legal or regulatory
Retaining Information
We will retain your information for as long as is needed for the purposes set out in this notice or as will be agreed in any specific application you complete.
Subject to that, we will retain your personal information for the duration of the period you work with the NACAD (whether in your current capacity or some other) and for a further five years.
In certain circumstances, we will be required to retain your personal information for longer, where such retention is required by law or record keeping requirements, including managing our relationship with you, defending any claims, or for tax purposes.
General
Transmission of information online is not 100% secure and we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk.
We will also obtain information about your computer, including where available your IP address, operating system and browser type in accordance with our Cookies Policy.
We will use any of your personal data in connection with any complaint made relating to our service to you, or in respect of reviewing any legal rights or obligations, either on the basis of performing our contract with you or in our legitimate interests to resolve any dispute.
In relation to the information we process as it is necessary for the performance of our contract with you, or to take steps for entering into our contract with you, the consequences of failure to do so would be failure to enter into a contract, failure to comply with the terms of the contract and/or the termination of the contract for breach.
We protect your interests by making it easy for you to control the way in which we use your information. For more information, see the “Control of and access to your information” section below.
We will disclose your personal information to third parties if we are under a duty to disclose or share your personal information, in order to comply with any legal regulations or good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of other persons with whom we have a business relationship, or to purchasers or prospective purchasers in relation to a disposal of our business or assets.
We will use additional third party service providers to support our service to you. This could include business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our services will be provided by organisations with which we have a contractual relationship, including subcontractors, and, accordingly, your personal information will be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.
NACAD will not sell your information.
International Transfer
Some of our IT systems are cloud based so your personal information will be sent outside the European Economic Area or South Africa. We have implemented appropriate technical and organisational measures to protect your personal information in the form of standard data protection clauses. If you would like to obtain a copy of the standard data protection clauses, please contact us using the details above.
Sensitive Information
Where we collect sensitive information for example in connection with examinations or to facilitate event administration it is provided to us by you or on your behalf voluntarily. By giving us this information, you agree that we will use such information as set out in this Notice.
Data Anonymisation And Aggregation
We will anonymise or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymised or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct risk assessment and analysis of costs and charges in relation to our products and services. We will share anonymised or aggregated data with third parties.
Control of and access to your information
You can exercise your data privacy rights as follows:
Your Right |
What Does It Mean? |
Right of access |
Subject to certain conditions, you are entitled to have access to your personal information which we hold (this is more commonly known as submitting a “data subject access request”). |
Right of data portability |
Subject to certain conditions, you are entitled to receive the personal information which you have provided to us and which is used by us by automated means, in a commonly-used machine readable format. |
Rights in relation to inaccurate personal or incomplete data |
You will challenge the accuracy or completeness of personal information which we use about you. If it is found that personal information is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate. If you believe any personal information we have about you is incorrect, please update it or contact admin team at [email protected]. |
Right to object to or restrict our use of your personal information |
Subject to certain conditions, you have the right to object to or ask us to restrict the use of your personal information. |
Right to have personal information erased |
Where we are using your personal information with your consent (and subject to certain conditions), you are entitled to have your personal information erased (also known as the “right to be forgotten”), e.g. where you think that the information we are using is inaccurate, or the use is unlawful. |
Right to withdrawal |
You have the right to withdraw your consent to any use for which you have previously given that consent. |
If you would like to exercise any of these rights or you have any questions about this Notice, your employment or your dealings with us, in relation to our use of your personal information, please refer to the admin team.
If you consider that we are in breach of our obligations under data protection laws, you will raise your complaint with the Information Commissioner’s Office (https://ico.org.uk/global/contact-us/). You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR.
Marketing Preferences
NACAD wants to share information and news about our products and services with you. We can do this in various ways including e-mail, post, SMS, phone or social media (or such other method(s) as will become relevant) but only if you would like us to. Your privacy is very important to us, which is why we make sure you are always in control of what we do with your personal information.
Subject to your consent if required by applicable law, we will use your personal information to provide you with direct marketing information about our products and services as well as those of third parties, and we will permit those third parties to send their own direct marketing to you.
We will ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. Once you have provided your express consent for us to contact you on our behalf, or on behalf of other organisations, there are a number of methods available to you in order to change your preferences, to correct or update your personal information at any time by:
- clicking the ‘unsubscribe’ link in any promotional e-mail you receive from us
- contacting our product or service team where a correction is required
- contacting us at [email protected]
In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Cookies Statement
What are cookies?
A cookie is a text file that is stored on your computer or mobile device by a website that you access. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.
Cookies do lots of different things, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. They allow a website to identify that you are a new visitor every time you move to a new page on the site – for example, when you enter your login details and move to another page it won’t recognise you and it won’t be able to keep you logged in.
By using and browsing the Nacad website, you consent to cookies being used in accordance with our policy. If you do not consent, you must turn off cookies or refrain from using the site.
Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.
What types of cookies are there?
Broadly, there are 3 types of cookie:
Third party cookies
Third party cookies are set by another website. For example, we use a third-party analytics company who set their own cookie to perform this service.
Session cookies
Session Cookies are stored only temporarily during a browsing session and are deleted from the user’s device when the browser is closed.
Persistent cookies
Persistent cookies are saved on your computer for a fixed period (usually a year or longer) and are not deleted when the browser is closed. They are used where we need to know who you are for more than one browsing session. For example, we use this type of cookie to store your preferences, so that they are remembered for the next visit.
They are used on the main NACAD website and Online learning sites.
Why does NACAD use cookies?
To provide personalised services to individual users. and to improve your user experience by enabling the website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a persistent cookie’).
To help us to monitor and improve the services we offer.
Managing Cookies
For more information about cookies and managing them, please contact [email protected] However, you should be aware that disabling certain cookies may cause the website not to function properly.
How to control cookies
The NACAD shop pages provide further information about processing of data collected via online ordering. NACAD shop terms and conditions.
Processing and retention of personal data
All personal data is processed in accordance with the South Africa & European data protection and privacy electronic communication laws and regulation. We will not pass any of your personal data to outside organisations or individuals without your express consent.
You have a right to know about the personal information the NACAD holds about you, and to have your data corrected or deleted.
Changes to This Notice
We will change this Notice from time to time in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Notice accordingly. We encourage you to check this Notice online for changes.