Privacy Policy
Introduction
Welcome to the LDC Confederation’s privacy policy. The LDC Confederation is a company limited by guarantee, which represents its members (which are Local Dental Committees (“LDCs”)).
The LDC Confederation currently represents the following LDCs:
- Camden and Islington LDC
- North West London LDC
- South West London LDC
- South East London LDC
As part of our efforts in representing your LDC, the LDC Confederation may need to process your personal data.
This privacy policy also applies to personal information we collect when you visit our website. Given the purpose of the LDC Confederation, our website is not intended for children and we do not knowingly collect data relating to children.
The LDC Confederation respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how the LDC Confederation collects and processes personal data which we receive from you directly (or via our website), the NHS or an LDC of which you are a member.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Roles and responsibilities
The LDC Confederation is a data controller and we are responsible for your personal data that is processed or stored on our own systems (collectively referred to as “LDC Confederation”, “we”, “us” or “our” in this privacy policy). On occasion, we may act as a data processor for your personal data that we do not process nor store on our own systems. When acting as a data processor, we are responsible for processing your personal data in accordance with instructions from a data controller (e.g. an LDC).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy, or our privacy practices, please contact our data privacy manager in the following ways:
Full name: Will Newport
Email address: contact@ldc.org.uk
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us or the LDC of which you are a member.
Third party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, physical address, email address and telephone numbers.
- Financial Data includes bank account details and information about apportioned NHS levy contributions.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie notice for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- the NHS; and
- an LDC of which you are a member.
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where we or an LDC of which you are a member are subject to a specific task in the public interest.
To find out more about the types of lawful basis that we will rely on to process your personal data please see the Glossary below.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose:
To manage our relationship with you as a member of an LDC (which is itself a member of the LDC Confederation). This may include:
- notifying you about changes to our terms or privacy policy; and
- notifying you about changes which will either affect us, the LDCs or you as a dental practitioner.
Type of data:
- Identity
- Contact
- Marketing and Communications
Lawful basis for processing (including basis of legitimate interest):
- Necessary to comply with a legal obligation;
- Necessary for our legitimate interests (to keep our records updated and to be able to contact you);
- Public task.
Purpose:
To represent the LDCs of which you are a member.
Type of data:
- Identity
- Contact
- Financial
Lawful basis for processing (including basis of legitimate interest):
- Necessary to comply with a legal obligation;
- Necessary for our legitimate interests (to effectively represent member LDCs);
- Public task.
Purpose:
To enable you to complete a survey and/or provide feedback or commentary on issues relevant to the objects of the LDC, of which you are a member.
Type of data:
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
Lawful basis for processing (including basis of legitimate interest):
- Performance of a contract with you;
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business);
- Public task.
Purpose:
To administer and protect the LDC Confederation and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data:
- Identity
- Contact
- Technical
Lawful basis for processing (including basis of legitimate interest):
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud);
- Necessary to comply with a legal obligation.
Purpose:
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data:
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
- Technical
Lawful basis for processing (including basis of legitimate interest):
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Purpose:
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data:
- Usage
- Technical
Lawful basis for processing (including basis of legitimate interest):
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your LDC membership.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the section above, titled: Purposes for which we will use your personal data.
External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, please contact our data privacy manager.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, please contact our data privacy manager.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about your rights.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary below to find out more about your rights.
If you wish to exercise any of the rights set out above, please contact us.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
Lawful basis
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Public task means processing personal data for a specific task in the public interest which is laid down by law; or exercising official authority (for example, a public body’s tasks, functions, duties or powers) which is laid down by law.
Third parties
External third parties are:
- Service providers who provide cloud-based solutions, IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- The NHS, HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- An LDC of which you are a member and which is itself a member of ours.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you or an LDC of which you are a member. We will advise you if this is the case at the time you withdraw your consent.