Exams Privacy Notice

About this statement

This statement explains how the Royal College of Paediatrics and Child Health (the Data Controller) uses any information provided by the following groups during the RCPCH examination process:

• candidates,
• examiners,
• sponsors,
• educational supervisors/senior colleagues/Training programme directors 
• people taking remotely invigilated theory exams

Personal data will be collected through general correspondence and more specifically through the RCPCH online account, online examination application systems.

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

We use both TestReach and the British Council to support our theory exams, and we use the Osler platform (provided by Professional Role Players) to support our DCH clinical online exam, they are our data processors. Links to their privacy policies are at the bottom of this notice. 

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.

Candidates

Data we collect and where it comes from

We collect both special category data and personal data about you. Most of this data will come directly from you entering/updating your details in eportfolio and applying to take exams. In some circumstances, we receive information from other organisations, such as the GMC, in line with their privacy notices to improve our data quality. 

Purposes

UKGDPR requires a legal basis for any processing of personal data. Our legal bases for processing your data are:

• "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
• "Public Task" - where we process your data in the public interest 
• "Substantial Public Interest" - where there is a substantial public interest in the processing of your data, in this case to ensure equality of opportunity and treatment
• "Consent" - where you have given your explicit consent for us to do so

Information we collect will be processed for the following purposes:

• 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. (Consent)
• To contact you with examination dates to enable you to book your exam. (Legitimate interest)
• To enable you to book your exam through our booking system (Risr)  (Legitimate interest)
• Where there is a public interest to maintain patient safety and confidentiality (Public Task)
• 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. More information is available in the equality, diversity and inclusion privacy notice. (Substantial Public Interest)
• Provision of Reasonable Adjustments to those who need them. We need to process your special category data to enable us to determine the most appropriate adjustments for your circumstances; to ensure these accommodations are in place for your exams and to communicate with relevant parties (e.g. exam centres, invigilators) to implement these adjustments. (Substantial Public Interest)
• To verify your eligibility for sitting the exam. If we are unable to verify your eligibility, we cannot let you sit the examination. (Legitimate interest)
• Where there is a legitimate interest to do so to ensure candidates are appropriately prioritised or placed for exams in their home country or country of work.
• 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. (Legitimate Interest)
• If you are one of the top scoring candidates, we may contact you to attend an event and/or to offer you an award. We may also ask you if you are interested in helping us by providing input to improve our exams. Please let us know if you do not want to hear from us (Legitimate Interest)
• We will share anonymised statistical information internally to help us to monitor and improve our examination process. (Legitimate Interest)
• We will use the sponsor contact details you provide to share feedback on your exam with your sponsor if you have are awarded a 'deferment score' or we have an unprofessional conduct concern (MRCPCH clinical exam). We will do this where there is a legitimate interest to do so, in order that your chosen sponsor can provide guidance or assistance in the preparation of your future exams.

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

Overseas candidates

Overseas based candidate 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.

Who do we share your data with?

Your data may be used and shared with or transferred to other organisations and individuals, including Deaneries, the GMC (General Medical Council), or relevant regulatory body, educational supervisors, training programme directors, overseas centres and other organisations involved in the planning, management and delivery of examinations held in the UK and overseas using secure channels. 

TestReach and the British Council are our suppliers (data processors) for Theory exams so we will share your data with them so that they can administer your exam on our behalf. If your exam is overseas, this will include transferring your personal data outside of the UK.  

Where personal data relating to theory exams is shared with deaneries and committees, this is pseudonymised.  

Online DCH Clinical exams are run on Osler (Professional Role Players) and we will share your personal data with them to facilitate the exam.  If you do not want us to share your data with Osler (PRP) you will need to take the DCH Clinical exam in person.

Any special category data provided to us in support of a request for reasonable adjustments will only be shared with those who need it to provide the necessary adjustments, and we will comply with all relevant data protection laws and regulations, including contractually obliging any other processors with whom we share it to do the same.

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 MRCPCH 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 DCH clinical exams marks are extracted from the Osler system. We manually check 10% of all marks and feedback to ensure that the process is accurate. You will receive digital mark sheet feedback 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.

How long do we keep your data for?

Exam administration documentation will be kept for one year. Reasonable adjustment information will be kept for the length of the exam. A record of the examination result will be kept permanently.  

British Council who manage our test centres, will retain all information they hold for two weeks from the exam date and then securely delete.  

All handwritten notes made by candidates during the exam (both UK and overseas) will be confidentially destroyed after the exam. The college follows its retention policy when retaining information. Please contact information.governance@rcpch.ac.uk if you have any specific queries in relation to retention. 

Waiting Lists

If you are on a waiting list for a course or exam, please read our Waiting list privacy notice

Examiners

Data we collect and where it comes from

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. 

Who we share data with (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.

Who we share data with (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.

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.

Purposes

UKGDPR requires a legal basis for any processing of personal data. Our legal bases for processing your data are:

• "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. 
• "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
• "Public Task" - where we process your data in the public interest 
• "Substantial Public Interest" - where there is a substantial public interest in the processing of your data, in this case to ensure equality of opportunity and treatment

 The information we collect will be shared for the following purposes only:

• 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. (Contractual Obligation)
• 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. (Contractual Obligation)
• Where there is a public interest to maintain patient safety and confidentiality. (Public Interest)
• 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. (Legal Obligation)
• Provision of Reasonable Adjustments to those who need them. We need to process your special category data to enable us to determine the most appropriate adjustments for your circumstances; to ensure these accommodations are in place for your exams and to communicate with relevant parties (e.g. exam centres, invigilators) to implement these adjustments. (Substantial Public Interest)
• 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. (Contractual Obligation)
• 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. (Contractual Obligation) 
• We will share anonymised statistical information internally to help us to monitor and improve our examination process. (Legitimate Interest)
• We will share confidential performance information internally to help us to monitor and improve the examination process. (Legitimate Interest)

 

How 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.

How long we retain examiner data 

Examiner information will be disposed of one year after termination of the appointment.

Other Involved individuals

Sponsors

For the MRCPCH Clinical examination, we ask candidates to provide the name, position, work place, email address, and relationship to candidate of their chosen sponsor.

The role of the sponsor is to recommend that the candidate is ready to take the MRCPCH Clinical examination and to provide support and guidance for future exams if the candidate secures a 'deferment score' (a low score) or if there is an unprofessional conduct concern. The processing of sponsors personal data is based on consent, which we ask candidates to confirm that they have. Sponsors can withdraw consent at any time by contacting clinicalexams@rcpch.ac.uk. They also have several other rights outlined in our ‘Your data rights’ page.

Educational Supervisors/Training Programme Directors/Senior Colleagues

Occasionally a candidate will ask their educational supervisor and/or training programme directors or other senior colleagues to support their application for an extension to the normal registration period or for additional attempts to sit any of the MRCPCH examinations.  In these instances candidates will ask their supervisor/colleague to complete a section of their application form.

The personal data of the supervisor/colleague collected via these forms are:

Name, relationship to the candidate, place of work, phone number, and email address. 

The data collected via this form will be used only to confirm the identity of the supervisor/programme director/senior colleague and determine whether the extension or further attempts will be granted.  The adjudicating team may need to contact the supervisor to discuss the application.

How long we keep your data

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.

Remotely Invigilated Theory Examinations

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

Data we collect

If we, offer you (candidate) a test/examination through the online invigilation platform that TestReach provides 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, TestReach 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 we collect this data

UKGDPR requires a legal basis for any processing of personal data. Our legal bases for processing your data are:

"Public Task" - where we process your data in the public interest 
"Consent" - where you have given your explicit consent for us to do so

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) (consent)
• online observation (consent)
• incident resolution such as fraud prevention (public task)
• test security (public task)
• for the integrity of the test and testing process. (public task)

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 theoryexams@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 we keep your data

Any exam remote video recordings are retained for six weeks from the end of the exam, unless there is an investigation or concern which requires the video to be kept for longer.  

For more information on how your personal information is processed for online invigilation, please see the TestReach Privacy Policy. 

Who we share your data with

If you agree to online invigilation, video recordings of your exam sessions, as well as image capture, will be supplied to TestReach and RCPCH, to assist with the management of your exam and for audit purposes. 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, TestReach 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 TestReach 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.

Online DCH Clinical Examinations

RCPCH provide a platform for candidates to be assessed for the clinical component of the DCH examination. This platform is called Osler and is managed by Professional Role Players. We are the data controllers of your information and Professional Role Players are the data processors.

Data we collect

DCH candidates sitting the clinical component on Osler consent to the following:

You are being monitored over the Internet through your computer via your webcam and microphone during your exam session.
DCH candidates and examiners will log on to the exam platform through the internet to take their exam. You will be monitored in real time, during your entire exam session so that your face, voice, desk and workspace will be captured.

It is your responsibility to ensure that only you will be on camera during an exam 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.

Professional Role Players may also collect and record further information about you when you take the exam such as:

• Your name, email address
• ID photo/government issued ID and DCH admission document,
• Physical (visible) health /condition, racial/ethnic origin/religious beliefs
• IP address, browser agents, browser and operating system identifiers,
• Your exam setting (home, office etc),
• Name of the exam you are sitting and other assessment based data that may be collected, including information about browser version etc.

 

Why we collect this data

UKGDPR requires a legal basis for any processing of personal data. Our legal bases for processing your data are:

• "Public Task" - where we process your data in the public interest 
• "Consent" - where you have given your explicit consent for us to do so

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:

• Enabling access to the Osler platform (consent)
• Confirming your identity and eligibility to take the exam, (public task)
• Physical (visible) health /condition, racial/ethnic origin/religious beliefs (consent)
• IP address, browser agents, browser and operating system identifiers, (consent)
• Your exam setting (home, office etc), (consent)
• Name of the exam you are sitting and other assessment based data that may be collected, including information about browser version etc. (consent)

 

How long we keep your data

Any exam remote video recordings are retained for six weeks from the end of the exam, unless there is an investigation or concern which requires the video to be kept for longer.  

For more information on how your personal information is processed for online invigilation, please see the Osler Privacy Policy, linked below.

Who we share your data with

When you agree to online invigilation, video recordings of your exam sessions, as well as image capture, will be supplied to Osler (Professional Role Players) and RCPCH, to assist with the management of your exam and for audit purposes. 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, Osler will, as required by GDPR, ensure that your privacy rights are protected by appropriate safeguards, such as EU model contract clauses.

For all data subjects

Understanding GDPR and your data rights

To help you understand more about the information in this and all our privacy notices, see our page, Understanding GDPR and your data rights. This explains common words and phrases used in our privacy notices, describes our use of artificial intelligence (AI) and details the rights you have in relation to the processing of your personal data under UK General Data Protection Regulation (UK GDPR).

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.

Data Processor Privacy Notices

TestReach: https://www.testreach.com/testreach-privacy.html

British Council: https://www.britishcouncil.org/about-us/how-we-work/policies/information-security-privacy

Osler (Professional Role Players): PDF Opens in a new window

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.
 

Last reviewed 10 October 2025