This privacy notice is intended to provide transparency regarding what personal data, via DAS, that Health Education & Improvement Wales (HEIW) will collect about you, how it will be processed and stored, how long it will be retained and who will have access to your data.
Health Education & Improvement Wales is a data controller in respect of the personal data held on DAS.
Personal data is information from which an individual can be identified either directly or indirectly when the information is read in conjunction with other data that a data controller holds.
From 25 May 2018 the Data Protection Act 1998 will be replaced by the General Data Protection Regulation and this will be the principal piece of UK legislation concerning personal data. Health Education & Improvement Wales will be subject to the General Data Protection Regulation (GDPR).
DAS Users should be aware that this privacy notice applies to all the processing of your personal data by Health Education & Improvement Wales in relation to your appraisal.
Why your personal data is collected
Your personal data is collected and held to facilitate the appraisal process. Appraisal is a contractual requirement .
DAS was launched in September 2018 to become an online appraisal platform for all Community Dentists in Wales. The purposes are outlined below :
1. To comply with legal and regulatory responsibilities.
2. To quality assure appraisal processes in Wales and ensure that standards are maintained
3. To contact you regarding your appraisal, such as automated emails from DAS to support management of the process
4. To contact you about development opportunities, events, surveys and information that may be of interest to you.
How your personal data is collected
Personal data is collected from the point of registration on DAS.
How your personal data is kept secure
Access to your personal data is restricted to the authorised team within Health Education & Improvement Wales that support and manage the DAS system. Access is also granted on a limited basis to users with specific authorised roles such as Appraisers and Designated Body staff but only where necessary for a specified and legitimate purpose.
Your personal data on DAS will be retained in accordance with the DAS Data Management Policy and GDC retention policy.
How and why your personal data may be shared
Health Education & Improvement Wales and Designated Body staff members have access to data entered into DAS as appropriate to enable effective management of the appraisal process. As detailed above, this includes a range of Quality Assurance activities which are carried out to assess whether the appraisal process is meeting specified standards and remains fit for purpose.
In the unlikely event that your appraiser identifies a concern during the appraisal process about your performance or fitness to practice, they would have a duty to report this in line with GDC Guidance.
Additionally aggregated reports are produced detailing the learning needs and constraints identified by dentists. No individuals will be identified in these reports. In Wales, relevant staff within Designated Bodies and Welsh Government receive annual reports containing aggregated data for the purposes of planning educational provision.
Health Education & Improvement Wales will not transfer your data to a third party unless it is satisfied of the following matters:
1. That there is a fair and lawful basis to share your personal data with the third party.
2. The data will be handled by the third party in accordance with the law on data protection.
Where the data is used for analysis and publication by a recipient or third party, any publication will be on an anonymous and aggregated basis, and will not make it possible to identify any individual. This will mean that the data ceases to become personal data.
Third parties may include the following non-exhaustive list: the UK health departments, Colleges/Faculties, other deaneries, the GDC, NHS Trusts/Health Boards/Health and Social Care Trusts and approved academic researchers.
Your rights and responsibilities
It is important that you work with us to ensure that the information we hold about you is accurate and up to date. Please ensure that your personal and professional details are updated regularly (as required under the declarations section).
All communications from Health Education & Improvement Wales will normally be by email. It is therefore essential for you to maintain an effective and secure email address or you may not receive important notifications regarding your appraisal or other important news and information about your user role.
If at any point you wish to gain a copy of your personal data that is held by Health Education & Improvement Wales you may submit a subject access request in writing. You can download your appraisal information from DAS in PDF format.
The lawful basis for processing are set out in Article 6 of the GDPR. In this case, due to the legal obligation of undertaking your appraisal via DAS, the processing is necessary for you to comply with the law. As a result, you do not have the right to erasure.
If you have any concerns in relation to how your personal data is processed, please contact the DAS Service Desk.
Should you wish to learn further information about data protection, please visit the Information Commissioner's Office (ICO) website. The ICO deals with complaints about how data controllers have dealt with information matters and provides useful guidance.