EUPATI is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It also details what will happen in the event of a security breach and how these will be minimised.It applies to personal data provided to EUPATI by individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.We process personal data for several purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.The personal data that is provided to us is ONLY provided directly from the individual concerned.We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality, and security. We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure. Administrator roles for the Moodle, WordPress and Box are regularly reviewed and confidential and personal information is restricted to a need to know basis.
SecurityAll information you provide to us is stored on the secure servers of our vendors. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Moodle platform, you are responsible for keeping this password confidential. Your account and password are issued to you as an individual, and we ask that you do not share your password with anyone.Unfortunately, the transmission of information via the internet is not and cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Data that we holdMoodle – e-learning platform for EUPATI Patient Expert CourseWe provide services to individuals who use our EUPATI Moodle platform.3.1.2 What data is collected?When a new user is created, the minimum data collected is as follows:
- First Name
- Last Name
How long do we hold data for?We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
Data we collect on people who use our servicesWhen people visit our website www.eupati.eu, data is collected through tracking using Google Analytics. This data is of a generic nature. No personal data is collected apart from as mentioned in section 3.2 when an individual registers to receive EUPATI communication.
Why do we process personal data?We process personal data provided by individuals who opt in to subscribe to www.eupati.eu by sending them regular updates or webinar invitations via e-mail.There are several reasons why we will process the personal data that students provide us when using the EUPATI Moodle. As examples, these include;
- Functionality. To allow individuals to use some functionality of our website, certain personal data must be entered for features to work as intended. An example of this is course reporting and completion.
- Security. To keep our site safe and secure, we may sometimes collect personal data, for instance login information and other data that can be used to vouch an individual’s identity.
Sharing personal dataWe will only share personal data with others when we are legally required to do so unless you have given us consent to do soPersonal data held by us may be transferred to:
- Third-party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run, and manage our internal IT systems. For example, providers of information technology, cloud-based software as service providers, identity management, website hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
- Third-party organisations that otherwise assist us in providing goods, services, or information
- Law enforcement or regulatory agencies or those required by law or regulations
Security BreachesEvery effort has been taken to prevent such an occurrence but in the unlikely event of a security breach, the individuals involved will immediately be notified of the extent of the incident and what remedial actions are being taken. The EUPATI Management and Steering Group will also be informed and measures will be taken to ensure that future occurrences are prevented.
Locations of processingWhere possible, personal data resides within the EU territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.
Individual’s RightsIndividuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:
- Individuals may request access to their personal data held by us as a data controller.
- Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
- Individuals may request that we erase their personal data
- Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
- Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
- Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
- If you wish to exercise any of these rights, please send an email to [email protected]