Privacy notice - equality, diversity and inclusion (EDI)

Our contact details

If you are a located in the UK, please contact RCPCH if you wish to make a request or if you have a general enquiry.

Name: Royal College of Paediatrics and Child Health (RCPCH)

Address: 5-11 Theobalds Road, London, WC1X 8SH 

Phone number: +44 (0)20 7092 6000

Email: Data Protection Officer (for privacy/data protection enquiries only): information.governance@rcpch.ac.uk

General enquiries can be sent via our contact form or contact the relevant team directly.

Our EEA representative

If you are located in the EEA (European Economic Area) or EU (European Union), you can contact DataRep if you wish to make a request under EU GDPR.

As we sometimes process personal data of individuals in the EU and EEA area, in either the role of ‘data controller’ or ‘data processor’, we have appointed DataRep as our Data Protection Representative in the European Union for the purposes of EU GDPR (General Data Protection Regulation) so that you can contact them directly in your home country.

If we have processed or are processing your personal data and you are located outside of the UK, you may be entitled to exercise your rights under EU GDPR in respect of that personal data. For more details on your rights in the EU, please refer to the European Commission or the national Data Protection Authority in your country.

If you want to raise a question to RCPCH, or otherwise exercise your rights in respect of your personal data, you may do so by:

• Sending an email to DataRep at datarequest@datarep.com quoting, RCPCH in the subject line
• Contacting DataRep on their online webform
• Mailing your enquiry to DataRep in your country - download list of addresses below.
• For general enquiries about RCPCH and its data processing, please contact: information.governance@rcpch.ac.uk

When mailing inquiries, it is essential that you mark your letters for ‘DataRep’ and not ‘RCPCH’, or your inquiry will not reach them. Please refer clearly to RCPCH in your correspondence. On receiving your correspondent, RCPCH is likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.

Please note this is for GDPR/privacy queries only. If you have a general enquiry, please use the contact details above.

If you have any concerns over how DataRep will handle the personal data they will require to undertake for their services, please refer to their privacy notice.

What information do we collect about you?

RCPCH is committed to ensuring equal opportunities across all its activities. We ask all members, examiners, exam candidates and those representing the College (such as volunteers, officers and committee members) to provide equality, diversity and inclusion (EDI) data, although it is not a requirement to submit these details. 

Diversity monitoring data is provided to us directly by you where you choose to provide it. Diversity monitoring data is special category data under the UK GDPR and includes information regarding:

• ethnicity
• health data including information about disability
• sexuality and gender identification, including reassignment
• religious beliefs.

Why do we collect this information?

Data protection law requires that we have one or more of the following lawful bases to process your information:

• “Consent” – we may ask for your consent to process your personal data. You can withdraw consent at any time. 
• “Contractual Obligation” – where we need to process your personal data either to take steps to enter into a contract with you or to fulfil a contract we already have with you. 
• “Legal Obligation” – where we are required to process your personal data by law or to fulfil a statutory obligation.
• “Vital Interest” – where the processing is necessary to protect someone’s life. 
• “Public Task” – where the processing is necessary for us to perform a task in the public interest, and it has a clear basis in law. 
• “Legitimate Interest” – where we have assessed that the benefits of us processing your data are legitimate and not outweighed by your interests or legal rights. 

We collect diversity monitoring data as it is in the public interest for us to ensure compliance with the Equality Act 2010 and monitor and promote equal opportunities in paediatrics. 

As diversity monitoring data is special category data, we also require an additional legal basis for processing. We process diversity monitoring data under Article 9 of the UK GDPR for reasons of substantial public interest to ensure compliance with the Equality Act 2010 and Schedule 1 of the Data Protection Act 2018 to promote and maintain equality in paediatrics. 

It is not a requirement to submit diversity monitoring data. 

How we use your information

We use the diversity monitoring data shared by members to compare representation and assess our impact on EDI. Data are anonymised, reviewed internally within the College as a reporting tool, with summary reports shared publicly as part of our commitment to accountability. 

Your anonymised data may be used for the following purposes within the College to:     

• compare diversity monitoring data of volunteers and to monitor whether our volunteer cohort reflects the breadth and diversity of our membership
• monitor and report on performance of exam candidates across the protected characteristics
• monitor and report of progression of trainees, eg ARCP outcomes, across the protected characteristics
• feed into the workforce census and AAC process to support campaigning, influencing, workforce planning and evaluation of work such as retention initiatives; 
• ensure our examiner cohort reflects the breadth and diversity of our membership
• report on diversity across all awards, and monitor diversity within our events, media spokespeople and panel members and ensure it reflects our membership.

Who might we share your information with?

The information you provide is stored as part of your membership record with restricted access and used for equal opportunities monitoring, which may include publishing anonymised research. No information that could identify you will be published.

We may share your data with the following for the following purposes:

• General Medical Council (GMC) and Health Education England in an anonymised format to comply with legal and regulatory responsibilities, including monitoring under the Equality Act 2010
• NHS England for the Workforce Race Equality Standard data in an anonymised format to share information on the ethnicity of Royal College members, Fellows and Council members

Your personal data will not be transferred outside of the UK. We do not use your personal data to make automated decisions or undertake profiling about you.

How long do we hold your information for?

We regularly review what information we hold about you and delete it in line with College Retention Schedules. We will retain EDI data for as long as you choose to provide it or for as long as your online account is active. Please see our website privacy policy for information about online accounts, or if you are a member, you can see the membership privacy policy for more information about how long your account is retained.

We will only retain your information for as long as you choose to provide it or for as long as necessary to fulfil our legal or statutory obligations, our business need or because it is of historical importance. This means that we may retain some of your personal information for a set period of time after our relationship with you has ended.

It is not a requirement to provide EDI data and you can update your EDI data at any time by completing the webform; there is no limit to how many times you can submit the form.

Your rights

You have the following rights in relation to your data:

• Right of access and right to have a copy of your personal data in a standard format (right to data portability). You can ask us for a copy of the information that we hold about you. 
• Change any factual errors or inaccuracies (right of rectification). You can update your EDI data by completing the webform. It is your responsibility to update us of any changes to the personal information you have provided. You can also contact us either via our contact form or contact the relevant team directly.
• Delete your personal data (called a right to erasure). We cannot delete all personal data as we may have a legal obligation or because we have a requirement to retain it for a task in the public interest, but we can delete non-essential data. You can also choose the ‘Prefer not to say’ option. 
• Restrict the use of your data (right of restriction). You can request that we deactivate your RCPCH online account or that we only store your data but undertake no further processing. However, this only applies to certain circumstances.
• Object to processing (right to objection). You can ask that we stop using data that is not necessary for fulfilling our legal obligations.

Please contact the RCPCH Data Protection Officer if you wish to make a request. Contact details are at the top of this privacy policy. 

If you are located in the EU/EEA and wish to make a request, you can contact the EEA Representative. 

If you make a request, we have one month to respond to you.

How to contact us or complain

If you are unhappy with how we are using your personal data, you should contact us in the first instance so that we can understand and try to resolve your concern. If we can't resolve the issue you have the right to complain to the Information Commissioners Office (ICO). The ICO is the UK's independent body set up to uphold information rights. 

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website

If you have any questions about our privacy policy, the information we hold about you or you wish to make a complaint, please send an email to: information.governance@rcpch.ac.uk.

Changes to this privacy policy

We keep our privacy policy under review, and we will place any updates on this web page. This privacy policy was last updated on 15 March 2021.