Your Personal Information
The General Data Protection Regulation (GDPR) introduces new legal protection for personal information we hold on all European Union (EU) citizens as from 25 May 2018. This tells you what personal information we hold; why we hold this information; and what your rights are under the revised data protection regulations.
Once you have read it, and agree, please complete and sign the declaration at the bottom and return to the below address.
Organisation Name: Anatomy Trains (UK & Europe)
Limited Address: 33 Mount Prospect Park, Belfast BT9 7BG, Northern Ireland
Telephone No: 02890580764
Please direct any enquiries relating to GDPR to firstname.lastname@example.org.
Purpose of Processing the Information we Hold
The purpose of holding and using the information we retain is to support students pursuing an Anatomy Trains course, or those providing services to students registered upon those courses branded as Anatomy Trains programmes and which we have contracted, or a request for a contract to provide such tuition has been made.
Lawful Basis for Holding Information
The lawful basis under which we hold and use your information is threefold; your consent; contractual, to complete contractual obligations; and finally, our legitimate interests, i.e. our requirement to retain the information that students or other stakeholders provide, to ensure that the rights bestowed by the regulations to students of Anatomy Trains courses, and other stakeholders within the EU are protected as required by GDPR, and to promote the brand of Anatomy Trains, without prejudice to other stakeholders legitimate interests.
What Information We Hold and What We Do With It
In order to achieve this we need to ask for and keep information about students, teachers, models, and hosts, and in the case of teachers and hosts, who have contracted to provide instruction, their records of student or other stakeholders, information. We will not use this information for any other purpose (except as required for our legitimate interest, as outlined above) without the individuals prior consent. The information normally to be held is:
- Contact details and any financial details necessary for contract completion
- Qualifications and past related work history
- Any CPD information (including copies of CPD certificates)
- Records of insurance relating to the contractual services to be provided
- Records of communications with you as an instructor/teacher/student of Anatomy Trains courses
- Record of any related product sales, books, DVD’s etc.
- In the case of special category data, i.e. any medical data, the lawful basis must be explicit consent and such information must be subject to rigorous protection
- Specifically, for students, the outcome of assessments (including portfolios of client treatment), workshop evaluations, pictures or promotional material
We may retain this information for any stakeholder with the prospect that there will be future interest in providing or taking, Anatomy Trains courses.
Please note that we use a third-party provider to deliver our promotional material, but they are only allowed to use your name and address to send this to you.
How Long We Keep Your Information For
The criteria used for determining the retention period is as follows:
- For current teachers, hosts and students we keep all information while qualifications from Anatomy Trains are in progress or to ensure our legitimate interest above
- For lapsed teachers, hosts and students we keep all information to enable us to issue a speedy response to any queries or to ensure our legitimate interest as noted above.
- Formal requests to remove information will normally be actioned within 24 hours, except where a case of legitimate interest must be considered by the Board of Anatomy Trains (UK & Europe) Limited. A decision on this will be communicated within 72 hours of such a request.
We are committed to ensuring that personal data is secure. To prevent unauthorised access or disclosure, all stakeholders, specifically hosts and teachers, should put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we hold. To that end, all such data security measures must be agreed by, and informed by, Anatomy Trains (UK & Europe) Limited for all hosts and teachers.
A formal register of all data security measures will be held at the registered office as noted above.
Data Controllers and Processors
In the context of the GDPR requirements, Anatomy Trains (UK & Europe) Limited will be the primary data-controller in Europe. As such, all contractual arrangements between all stakeholders, must be agreed by Anatomy Trains (UK & Europe) Limited for the provision of Anatomy Trains courses within Europe, and appropriately evidenced. Failure to comply will represent prima facia evidence of none compliance with GDPR and treated as a breach by the stakeholder within the regulations. Any consequential penalties will fall upon the party in breach of this privacy notification.
GDPR provides the following rights to all EU citizens:
- The right to be informed: To know how your information will be held and used (this notice).
- The right of access: To see our records of your personal information, so you know what is held about you and can verify it.
- The right to rectification: To tell us to make changes to your personal information if it is incorrect or incomplete.
- The right to erasure (also called “the right to be forgotten”): For you to request us to erase any information we hold about you if you ask them not to hold it anymore
- The right to restrict processing of personal data: You have the right to request limits on how we use your personal information
- The right to data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems.
- The right to object: To be able to tell us you don’t want them to use certain parts of your information, or only to use it for certain purposes.
- Rights in relation to automated decision-making and profiling.
- The right to lodge a complaint with the Information Commissioner’s Office: To be able to complain to the ICO if you feel your details are not correct, if they are not being used in a way that you have given permission for, or if they are being stored when they don’t have to be.
Full details of your rights can be found here.
Anatomy Trains (UK & Europe) Limited/Anatomy Trains Rights
- If you don’t agree to us keeping records of information about you, then we will not be able to accept you, or continue to sponsor you, as a student, teacher, model or host and we will not be able to answer any queries you may have at some point in the future.
- We must keep your records for a certain period as described above, which may mean that even if you ask us to erase any details about you, we might have to keep these details until after that period has passed to protect our legitimate interest.
- We can move records between our computers and IT systems, providing that your details are protected from being seen by others without your permission.