This privacy notice is intended to provide transparency regarding what personal data the Wales Deanery 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.
The Wales Deanery is a data controller in respect of the personal data it holds concerning Foundation Dentists in Wales.
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. The Wales Deanery will be subject to the General Data Protection Regulation.
Foundation Dentists (FDs) should be aware that this privacy notice applies to all the processing of your personal data by the Wales Deanery in relation to or arising from your role.
Why your personal data is collected
Your personal data is collected and held for the purposes of:
- Supporting the management of the training programmes – personal data collected for this purpose will be kept in your training file, which will typically contain your recruitment data (application form, recruitment documentation and any immigration records), Interim Record Competency Progression (IRCP) and Final Record of Competency Progression (FRCP) summary and any significant communication and information pertinent to the effective management of your training and education.
- To quality assure training programmes and ensure that standards are maintained - via local and national quality assurance teams such as feedback opportunities following each Study day with Training Programme Directors (TPDs) and the Advisory Board for Dental Foundation Training (ABFTD) national survey.
- Identifying workforce planning targets – your data will be used to determine areas that we can focus on to help build the dental workforce in Wales.
- Maintaining patient safety through the management of performance concerns – your personal details may be shared with the General Dental Council (GDC) should there be significant concerns regarding your fitness to practice.
- To communicate with you about training opportunities, events, surveys, Electronic Personal Development Portfolio (EPDP) activity and information that may be of interest to you.
- To facilitate a transparent approach to DFT in Wales.
- To support and advise all stakeholders involved with Dental Foundation Training (DFT) in Wales.
- To ensure we are able to provide FD welfare / pastoral care if necessary.
- Safeguarding information.
- Accessing Cardiff University IT systems and EPDP systems.
The functions of the Wales Deanery are carried out in the public interest. The processing of FDs personal data is necessary for the purposes of those functions. Sensitive personal data that we may need to share includes information relating to your health or criminal record should your employer or the GDC need to be made aware.
How your personal data is collected
Personal data is collected when you enter the DFT National Recruitment process, submit the Dental Foundation Training Contract, and attend the Meet the Educational Supervisor (MES) event (photos for the applicant booklets). Personal data is also captured and stored on the EPDP in line with Health Education England’s (HEE) records management policy and the NHS records retention schedule within the NHS records management code of practice.
How your personal data is kept secure
Access to your personal data is restricted to the authorised team within Health Education England (HEE), and the DFT Team within the Wales Deanery.
Your personal data will be retained for six years after you have left your FD role, at which point your personal data will be confidentially and securely destroyed.
How and why your personal data may be shared
This information is kept in a hidden electronic database with limited access.
Your personal data may be shared with –
- Welsh Government
- NHS Shared Services (NHSSS)
- NHS Business Services Authority (NHSBSA)
- Performers list
- Local Health Boards (LHBs)
- Health Education England (HEE) – for the Electronic Personal Development Portfolio (EPDP)
- Committee Of Postgraduate Dental Deans and Directors (COPDEND)
- Third parties for reporting or research purposes and management of services such as portfolios
The Wales Deanery will only transfer your personal data to third parties using secure channels and where it is needed to manage your Dental Foundation Training role, for example issues with performance and professional registration and integrity or issues relating to payments.
The Wales Deanery will not transfer your data 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: British Dental Association (BDA), Welsh Government, GDC, Occupational Health, Health Inspectorate Wales (HIW).
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 so please inform the Wales Deanery immediately if any of your personal data needs to be updated or corrected.
All communications from the Wales Deanery 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.
If at any point you wish to gain a copy of your personal data that is held by the Wales Deanery you may submit a subject access request in writing.
In certain limited circumstances, you have a right to object to processing that is likely to cause you damage or distress, or to any decisions made by automated means that significantly affect you.
You also have a right to have inaccurate personal data rectified, blocked, erased or destroyed.
If you wish to exercise any of these rights or have any concerns in relation to how your personal data is processed, please contact the Wales Deanery.
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.