Privacy notice - examinations

Protecting the privacy and personal data of our exam candidates, examiners and hosts is highly important to us. The following explains how the RCPCH uses any information you give to us and the way we protect your privacy and to comply with UK Data Protection legislation.

About this statement

This statement explains how the Royal College of Paediatrics and Child Health (the Data Controller) uses any information examination candidates or other key stakeholders provide to us for the RCPCH examination process through general correspondence and more specifically through the RCPCH online account and online examination application systems.

This privacy statement covers both overseas and UK candidates and operational examination stakeholders (examiners, hosts etc.).

Sometimes we will ask our supplier for our theory examinations, BTL, to operate theory exam test centres for us. In these cases, BTL will be joint data controllers with RCPCH in regard to candidate information.

This statement also explains how the RCPCH uses any information that doctors provide to us for the purposes of applying to become an examiner or for carrying out duties as an examiner.

If you have any questions or concerns about how your personal data is used by the College, you can contact the College’s Data Protection officer by writing to: The Information Governance Manager, 5-11 Theobalds Road, London, WC1X 8SH or emailing information.governance@rcpch.ac.uk.

This privacy statement does not cover links within this site to websites owned or administered by other organisations.

This statement also explains how we protect your privacy. Protecting the privacy and personal data of visitors to our site is highly important to us.

Candidates

Data protection legislation

In accordance with data protection legislation, we have a legal duty to protect any information we collect from you.

We collect both special category data and personal data about you. This data may be used and shared with or transferred to other organisations and individuals, including Deaneries/LETBs [we no longer use LETB], the GMC (General Medical Council) or relevant regulatory body, educational supervisors, overseas centres and other organisations involved in the planning, management and delivery of examinations held in the UK and overseas using secure channels. This information will be shared for the following purposes only:

  1. Managing the provision of examination delivery as part of our agreement with you to provide you with the exam. If we do not process your personal data, we will not be able to provide you with this service.
  2. Where there is a public interest to maintain patient safety and confidentiality
  3. Compliance with legal and regulatory responsibilities, including monitoring under the Equality Act 2010. Provision of equal opportunities data is optional, but it will enable us to better monitor equality opportunities within paediatrics.
  4. To verify your eligibility for sitting the exam. If we are unable to verify your eligibility, we cannot let you sit the examination.
  5. We are sometimes asked to verify exam results, but we will only do this where we have legal grounds to do so. For more information please see our verification page.
  6. We will share anonymised statistical information internally to help us to monitor and improve our examination process.

UK

For UK trainees only, this information will subsequently be transferred to trainee’s individual RCPCH ePortfolio accounts to assist with their ongoing assessment.

Overseas

Overseas based candidate and examiner information including name, contact details, RCPCH number and eligibility criteria will be shared with the examination committee of the overseas centres in order to help facilitate examination placement and to prioritise candidates based in that country. In these cases, information may be transferred outside of the EEA, where transfer is necessary for the provision of this service. If we are transferring your data outside of the EEA, we will only do so where it is necessary for us to be able to provide you with the exam as part of our agreement with you and we will always transfer your data securely.

If you are a Hong Kong or Singapore candidate, we will share the personal data on your application form and individual exam results with the oversees centre as it is necessary in relation to your progression within your local training programme. All other centres will receive a breakdown of pass and fail data only, but this will be in an anonymised format, we will not share your individual results.

For Hong Kong candidates, it is also necessary for us to share your personal information with Hong Kong centres so that they can confirm that they have received payment for the exam. If you are registered or anticipate being registered with the GMC then your personal data, including data about your examination results and number of attempts, will be passed to the GMC for quality assurance and research purposes. This includes sensitive data such as ethnicity which is required so that the GMC can assess the fairness of GMC approved assessments for the protected characteristics.

The GMC will also share your data with the UKMED database so that it can be linked with other data about you and used for research purposes. To find out more, see the UKMED website's FAQs for medical students. RCPCH is legally obliged to share this data with the GMC under the Medical Act 1983 to assist the GMC in its objective to regulate medical education in the UK.

How do we make decisions about you

If you undertake the theory exam, we will use a computerised system to calculate your overall mark. We manually mark 10% of the mark sheets to ensure that the process is accurate, and our psychometric team also review pass marks for each question to ensure that the questions are adequate and fair. If you are unhappy with your mark you can submit a request for a theory exam remark. Please refer to Appendix I. Theory examination re-marking policy within the regulations and rules for MRCPCH and DCH examinations.

For clinical exams, these are manually scanned and marked. We manually mark 10% of the marksheets to ensure that the process is accurate You will receive a copy of your mark sheet so that you are able to see how your mark has been calculated. For information on the clinical examinations appeals process please refer to the Clinical examination appeals Policy.v.1.2 within the regulations and rules for MRCPCH and DCH examinations.

Examiners

Data protection legislation

In accordance with data protection legislation, we have a legal duty to protect any information we collect from you.

We might collect both special category data and personal data about you. This data may be used and shared with or transferred to other organisations and individuals, including members of the Examiner Review Panel, Examinations Executive Committee, Educational and Training Divisional Committee, the Examinations team, UK and Overseas hosts, other organisations involved in the examiner application process and the planning, management and delivery of examinations held in the UK and overseas. 

This information will be shared using secure channels. This information will be shared for the following purposes only:

  1. Managing the examiner application process as part of our agreement with you to consider your application to become an MRCPCH or DCH examiner. If we do not process your personal data, we will not be able to proceed with the application process.
  2. Managing the provision of examination delivery, including allocating examiners to exam centres in the UK and overseas as part of our agreement with you to as an active examiner on any given exam. If we do not process your personal data, we will not be able to allocate you to examine.
  3. Where there is a public interest to maintain patient safety and confidentiality.
  4. Compliance with legal and regulatory responsibilities, including monitoring under the Equality Act 2010. Provision of equal opportunities data is optional, but it will enable us to better monitor equality opportunities within paediatrics.
  5. To verify your eligibility to become an examiner for the MRCPCH or DCH exams. If we are unable to verify your eligibility, we are unable to process your application to become an examiner.
  6. To verify your continuing eligibility to act as an examiner for the MRCPCH or DCH exams. If we are unable to verify your continuing eligibility, you will be unable to continue to act as an examiner.
  7. We will share anonymised statistical information internally to help us to monitor and improve our examination process.
  8. We will share confidential performance information internally to help us to monitor and improve the examination process.

UK

For applicants to UK examiner positions, in order to process and evaluate your application, your personal data is shared with members of the College Examinations Team, the Examiner Review Panel and the Examinations Executive Committee, Educational and Training Divisional Committee. If you are accepted as an Examiner-Elect, your personal information will be shared with an examination host, the senior examiner for an exam and an examiner-mentor in order to confirm your travel arrangements for an exam and to help you complete the process of becoming an examiner.

For UK examiners, your personal data is shared with members of the College Examinations Team, exam hosts and senior examiners for specific exams for which you have agreed to be placed as an examiner. Post-exam, your personal information is shared with the College Psychometrics team and might be shared with the MRCPCH Clinical Examinations Chair and/or the Officer for Examinations.

Overseas

For applicants to Overseas examiner positions, in order to process and evaluate your application, your personal data is shared with members of the College Examinations Team, the Examiner Review Panel, the Examinations Executive Committee, Educational and Training Divisional Committee and the overseas host/lead and their team. If you are accepted as an Examiner-Elect, your personal information will be shared with the overseas examination host, the senior examiner for an exam, the Principal Regional Examiner for that host centre, and an examiner-mentor in order to schedule your training and confirm your availability as well as to help you complete the process of becoming an examiner.

For Overseas examiners, your personal data is shared with members of the College Examinations Team, exam hosts and their team, Principal Regional Examiners and Senior Examiners for specific exams for which you have agreed to be placed as an examiner. Post-exam, your personal information is shared with the College Psychometrics team and might be shared with the MRCPCH Chair for Overseas Examinations, the MRCPCH Clinical Examinations Chair, the Principal Regional Examiner for that exam, the Senior Examiner for that exam, and the Officer for Examinations.

How do we make decisions about you

If you submit an application to become an examiner for the MRCPCH Clinical exam, we will check your eligibility and evaluate your application and performance as an Examiner-Elect according to the criteria in the Becoming an MRCPCH Clinical Examiners documents available on the College website.

You have the right to withdraw from the application process at any time. If you make yourself available to examine for upcoming exams, we will try our best to allocate you to the centres you have selected but will also have to factor in the need for examiners across all exam centres.

For online examinations

RCPCH provide online invigilation as a service via our supplier, BTL Group Limited. We are the data controllers of your information and BTL are the data processors.

What Information do we collect from you?

If we, offer you (candidate) a test/examination through the online invigilation platform that BTL provides (powered by ProctorExam) and if you choose to take such test/examination through the platform, you consent to the following:

  • You are being monitored over the Internet through your computer via your webcam and microphone during your exam session.
  • You will additionally be monitored via a mobile device via the device's camera and microphone immediately prior to your exam session for an environment check and then during your exam session.

Online invigilation means that you will log on to a test platform through the internet to take your assessment and you will be monitored, sometimes in real time, during your entire assessment session so that your face, voice, desk and workspace will be captured and a recording will be made of these for the purposes of assessment security and the integrity of the assessment process.

It is your responsibility to ensure that only you will be recorded during an online invigilation testing session and that no one else will be physically in the room where you are testing and that no one speaks to you during your testing sessions.

If you use the online invigilation service to take assessments, BTL may also collect and record further information about you when you take the exam which is online invigilated, such as:

  • your name, email address
  • captured facial photo, captured ID photo/government issued ID
  • physical (visible) health data/condition (by virtue of video recording), racial/ethnic origin/religious beliefs (by virtue of video recording)
  • IP address, browser agents, browser and operating system identifiers, screenshots of your PC
  • your exam setting (home, office etc), all recorded video streams (computer, webcam and mobile
  • name of the exam you are sitting and other assessment based data that may be collected, including information about browser version, appVersion, appName, product and appCodeName, video frame size, type and library used for encoding, framerate, jitter, packet loss and bandwith.

Prior to the start of your online invigilated test you will be required to take a picture of yourself. The collection of such data is necessary if you choose to use the online invigilation function. 

Why do we collect this information?

The video and audio recordings are standard test procedures for our online invigilated tests and your video and audio recording will be, where necessary, used for purposes of:

  • identity verification (these checks are undertaken manually)
  • online observation
  • incident resolution such as fraud prevention
  • test security
  • for the integrity of the test and testing process.

If you do not want to take your exam remotely and use online invigilation, you can book your exam in one of our test centres.

As collection is based on your consent, you can withdraw consent at any time by contacting onlineinvigilation@rcpch.ac.uk. Please note that if you withdraw consent after the application
window has closed you will be charged for the exam. If you withdraw consent, all data relating to your online exam will be deleted, although we may keep a record that you have sat the exam.

How long do we keep hold of your information for?

BTL will retain your personal data for six months. After this, RCPCH may retain your data for up to six years from closure of a case if there is an investigation or other legal disclosure request in line with applicable laws.

Who might we share your information with?

If you agree to online invigilation, video recordings of your exam sessions, as well as image capture, will be supplied to BTL and RCPCH, to assist with the management of your exam and for audit purposes. When you use the online invigilation service, BTL use selected third party service ProctorExam that is hosted in in Germany (Frankfurt Region), to process your data on our behalf. As part of the provision of the service you agree that some or all of the above personal data may be processed outside the UK and EEA. In such circumstances, and if you are based in the UK or EU, BTL will, as required by GDPR, ensure that your privacy rights are protected by appropriate safeguards, such as EU model contract clauses.

As part of the online invigilation services you also agree to allow your personal data to be transferred by BTL to RCPCH, from whom you seek certification. We require your personal data so that tests can be correctly administered, and certification can be processed, granted and administered. For more information about how RCPCH, may collect and use your personal data we encourage you to review our full privacy policy.

For all data subjects

Your rights

You have certain rights with regards to the data we hold about you. You can ask us to delete your personal data, change any inaccuracies, restrict what we use your personal data for or ask us to stop processing your data. You can also request that the data we hold about you is given back to you or given to another service provider in a commonly used format. This is called data portability. You are also entitled to a copy of the information we hold about you. However, there are some restrictions that apply to these requests, such as where we have overriding legal requirements we have to comply with.

To find out more about your rights, visit the ICO website or to make a request please contact the Data Protection Officer on information.governance@rcpch.ac.uk or writing to: Information Governance Manager, RCPCH, 5-11 Theobalds Road, London WC1X 8SH.

If you have any concerns about the way your personal data is handled, please contact the College in the first instance. If you are still unhappy you do also have the right to complain to the ICO by contacting casework@ico.org.uk.

Site usage

We undertake end-to-end tracking of exam user journeys so that we can monitor and make improvements to our exams. This includes information about what pages you visit, how long you are on the site, how you got here and what you click on. We also use cookies for authentication purposes and to validate an active browsing session.

Security

Our systems will have appropriate security measures in place to protect the loss and alteration of your information. Any documents/data sent to you from the RCPCH becomes your responsibility. RCPCH cannot be held responsible for the security of data copied to and held outside of its systems or its accuracy. Such information should only be accessed from a secure computer and/or held in a safe place.

Changes to this policy

These terms are subject to change at any time by the RCPCH. Any such changes will be posted online. Please check these terms on a regular basis to make sure you are aware of any changes made by the RCPCH. Your continued use of this site or engagement with examiner application or allocation processes after changes are posted indicates that you agree to these terms as updated and/or amended.

If the privacy policy changes in any way, we will place an updated version on the website. Regularly reviewing the privacy policy page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties. See all MRCPCH and DCH examination rules and regulations.