This privacy notice is intended to provide transparency regarding what personal data the PGVLE may hold about you, how it will be processed and stored, how long it will be retained and who may have access to your data.

Personal data is any information relating to an identified or identifiable living person (the data subject). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number or factors specific to the physical, genetic or mental identity of that person, for example.

Our Role

The PGVLE is here to facilitate the education, training and development of healthcare staff in conjunction with individual training programmes. Our aim is to enable high quality and effective training and development. All the information we collect is to support these objectives. 

What this privacy statement covers

This privacy statement only covers the processing of personal data by the PGVLE that has been obtained from data subjects accessing the site and also data that has been drawn from respective training programmes and course enrollments. It does not cover the processing of data by any sites that can be linked to or from this website, so you should always be aware when you are moving to another site and read the privacy statement on that website.

When providing the PGVLE with any of your personal data for the first time, for example, when you first login you will be asked to confirm that you have read and accepted the terms of this privacy statement. A copy of your acknowledgement will be retained for reference.

If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing the 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.

THERE IS CURRENTLY NO SCOPE FOR DIRECT REGISTRATION TO THIS SITE. THE PGVLE IS ASKED TO PROVIDE LOGIN DETAILS TO USERS BASED ON THE NEEDS DETERMINED BY COURSE ORGANISERS AND TEACHING PROGRAMME FACULTY (ON BEHALF OF HEE REGIONAL OFFICES). BY UTILISING THE LOGIN THAT WAS SENT TO YOU (AT THE REQUEST OF THE COURSE/TRAINING CONVENER) YOU ACCEPT ALL THE POLICIES ON THIS SITE (THE PGVLE).

Why PGVLE collects your personal data

Personal data may also be obtained from Local Education Providers or employing organisations in connection with the functions of PGVLE.

Your personal data is collected and processed for the purposes of and in connection with the functions that PGVLE performs with regard to workforce education. The collection and processing of such data is necessary for the purposes of those functions. A full copy of the HEE notification to the Information Commissioner setting out all of the types of processing that we undertake can be found on the Commissioner’s website. For further information please refer to HEE’s registration number: ZA120843 on the ICO’s website.

In connection with training the PGVLE collects and uses your personal information for the following purposes:

1. To support your training 
2. To quality assure training programmes and ensure that standards are maintained
3. For Research and Audit

We also collect and use personal information from you so that we can provide HR related support services and education and training to you, for clinical professional learner recruitment, to promote our services, to monitor our own accounts and records, to monitor our work, to report on progress made, and to let us fulfil our obligations as set by HEEWM.

Further information about our use of your personal data in connection with training can be found in the ‘Reference Guide for Postgraduate Specialty Training in the UK’, also known as the ‘Gold Guide’.

Collection and use of data from website users

When you access the PGVLE website, small amounts of information are sometimes placed on your device, including small files known as cookies. These pieces of information are used to improve services for you. For example, we use a series of cookies to monitor website speed and usage, as well as to ensure that any preferences you have selected previously are the same when you return to our website.

Google Analytics for example stores information about what pages you visit, how long you are on the site, how you got here and what you click on. Personal information (e.g. your name or address) is not however collected or stored so this information cannot be used to identify who you are. We do not allow Google to use or share our analytics data.

Full details on the cookies set by Google Analytics are published on the Google website. Google also publishes a browser add-on to allow you to choose that information about your website visit is not sent to Google Analytics.

On a number of pages we use ‘plug ins’ or embedded media. For example, we might embed YouTube videos in pages. The suppliers of these services may also set cookies on your device when you visit the pages where we have used this type of content. These are known as ‘third-party’ cookies. To opt-out of third-parties collecting any data regarding your interaction on our website, please refer to their websites for further information.

We will not use cookies to collect personal data about you. However, if you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies. Please be aware that restricting cookies may impact on the functionality of our website.

HEE as data controller

HEE is the data controller in respect of any personal data it holds concerning trainees in training, individuals employed by HEE and individuals accessing HEE’s website.

Legal basis for processing

The GDPR requires that data controllers and organisations that process personal data demonstrate compliance with its provisions. This involves publishing our basis for lawful processing.

For full details related to HEE Legal Basis for Processing please click here https://www.hee.nhs.uk/about/privacy-notice

DATA WE COLLECT

- User name, surname, email address - essential for account creation

- Rotation and Grade - for organisation and to ensure all users are in appropriate courses

- All other data is user entered for purposes defined below.

The personal data processed by the PGVLE is done so for the purposes of the PGVLEs statutory function, which include:

- Enrolment of Trainees, Trainers and other Users to the PGVLE with access to relevant content

- Collection of feedback for purposes of service improvement

- Anonymised data will be utilised for research and audit purposes

- Where users contribute content to the platform this will be acknowledged unless specific requests are made to the contrary

- Big Blue Button Webinar sessions may be recorded - users will be notified prior to the commencement of recording and any such recording will only be available to a limited audience on the PGVLE

- Forums and Comments are enabled that can be removed at a later date if required.

- Activity Logs - individual user activity within the platform and the courses are recorded and form part of the system data. It is utilised for assessing user engagement and may be shared with relevant programme directors as requested.

Any special category data (including data relating to racial or ethnic origin, political opinions, religious beliefs, sexual orientation and data concerning health) will only be collected anonymously as part of specific approved surveys

Please note that not all of the HEE legal bases will apply for each type of processing activity that the PGVLE may undertake. However, when processing any personal data for any particular purpose, one or more of the above legal bases will apply.

Information that we may need to send you

We may send you information about specific course related information to you based on your enrolments. We will avoid to send any generic information which if necessary will come directly from HEE.

Transfers Abroad

The GDPR imposes restrictions on the transfer of personal data outside the European Union, to third countries or international organisations, in order to ensure that the level of protection of individuals afforded by the GDPR is not undermined.

Your data may only be transferred abroad where HEE is assured that a third country, a territory or one or more specific sectors in the third country, or an international organisation ensures an adequate level of protection.

How we protect your personal data

Our processing of all personal data complies with the General Data Protection Regulation principles in line with Health Education England’s data protection registration held with the Information Commissioners Office.

The personal data we hold may be held as an electronic record on data systems managed by HEE or as a paper record. These records are only accessed, seen and used as required and/or permitted by law by staff who need access to personal data so they can do their jobs and other partner organisations under data sharing agreements.

The security of the data is assured through the implementation of HEE’s policies on information governance management.

We make every effort to keep your personal information accurate and up to date, but in some cases we are reliant on you as the data subject to notify us of any necessary changes to your personal data. If you tell us of any changes in your circumstances, we can update the records with personal data you choose to share with us.

We will keep personal data for no longer than necessary, in line with our records management policy, and the NHS records retention schedule within the NHS records management code of practice.

Sharing personal data

So we can provide the right services at the right level, we may share your personal data within services across HEE and with other third party organisations such as the Department of Health, Higher Education Institutions, NHS Trusts, clinical placement providers, colleges, faculties, other HEE local offices, the GMC, NHS Trusts/Health Boards/Health and Social Care Trusts, approved academic researchers and other NHS and government agencies where necessary, to provide the best possible training and education and to ensure that we discharge HEEs responsibilities for employment and workforce planning for the NHS. This will be on a legitimate need to know basis only.

We may also share information, where necessary, to prevent, detect or assist in the investigation of fraud or criminal activity, to assist in the administration of justice, for the purposes of seeking legal advice or exercising or defending legal rights or as otherwise required by the law.

Where the data is used for analysis and publication by a recipient or third party, any publication will be on an anonymous basis, and will not make it possible to identify any individual. This will mean that the data ceases to become personal data.

Open Data

HEE policy is to observe the Cabinet Office transparency and accountability commitments towards more open use of public data in line with relevant and applicable UK and European legislation. HEE would never share personal data through the Open Data facility. To this end, HEE will implement Information Governance protocols that reflect Information Commissioner’s Office recommended best practice for record anonymisation, and Office of National Statistics guidance on publication of statistical information.

Your rights with respect to data held on the PGVLE

Right to rectification and erasure

The GDPR extends and strengthens your rights as a data subject. Under the GDPR you have the right to rectification of inaccurate personal data and the right to request the erasure of your personal data. However, the right to erasure is not an absolute right and it may be that it is necessary for PGVLE to continue to process your personal data for a number of lawful and legitimate reasons.

Right to object

You have the right in certain circumstances to ask the PGVLE to stop processing your personal data in relation to any PGVLE service. As set out above, you can decide that you do not wish to receive information from PGVLE about matters of policy affecting education, training and workforce. However, the right to object is not an absolute right and it may be that it is necessary in certain circumstances for PGVLE to continue to process your personal data for a number of lawful and legitimate reasons. 

If you object to the way in which PGVLE is processing your personal information or if you wish to ask PGVLE to stop processing your personal data, please review the Privacy & Policies section of your user profile and make a data request. However, if we do stop processing personal data about you, this may prevent PGVLE from providing the best possible service to you.

Subject Access

You can access a copy of the information PGVLE holds about you by making a data request via the User Profile. This is free of charge.

Data Portability

The GDPR sets out the right for a data subject to have their personal data ported from one controller to another on request in certain circumstances. You can request the opportunity to download all data that the PGVLE holds on you and share as you wish with any third party.

Your responsibilities

It is important that you work with us to ensure that the information we hold about you is accurate and up to date so please inform PGVLE if any of your personal data needs to be updated or corrected and maintain the accuracy of your user profile.

All communications from PGVLE will normally be by email. It is therefore essential for you to maintain an effective and secure email address or you may not receive information or other important news and information about your employment or training.