JETS, JETS Workforce and NED: Privacy Notice

This privacy notice explains how the JAG Endoscopy Training System (JETS), JAG Endoscopy Training System Workforce (JETS Workforce) and the National Endoscopy Database (NED) at the Royal College of Physicians (RCP) collects, stores, manages and protects your personal data. It outlines the types of data that we hold and how we use them. The RCP takes its responsibilities around the correct collection, use and destruction of the personal data of its various audiences and stakeholders very seriously and is committed to openness and fairness in the handling of personal data.

What information do we collect about you?

If you are an individual and want to participate in any of these projects, then the RCP will collect and process the data as outlined below.

JETS (JAG endoscopy training system)

  • Name, professional body, registration number, role and job title.
  • Email address(es), phone number(s), current work and correspondence address, registration number (GMC/NMC) and National Training Number.
  • Country, deanery, organisation and hospital worked at currently and historically.
  • Notes from appraisals.
  • Training courses booked and attended.
  • Certification achieved and current level of training.
  • Information regarding procedures performed including performance and feedback using JAG procedure feedback forms (DOPS and DOPyS).

If you are a professional that is, or wants to be, part of our assessment team then we will collect and process the following data:

  • Name, address, personal email address and telephone number.
  • Current employment information including name and address of your existing employer.
  • Employment history and relevant qualifications.
  • Bank account details, where relevant

JETS Workforce

  • Name, email, professional body, registration number, role and job title.
  • Sites worked at.
  • Performance and feedback using JAG procedure feedback forms (DOPS and DOPyS) and information added as witness statements.
  • Training courses booked and attended.
  • NED (National Endoscopy Database)

  • Name, email, professional body, registration number.
  • Sites worked at.
  • Information regarding procedures performed.
  • How will we use your information?

    We use the information you give us to:

    • send you publications, newsletters and updates that are relevant to the programme
    • provide you with the services you registered for and information about our activities and events
    • administer any user accounts we set up for you
    • conduct surveys and process your response to any survey you participate in for research, evaluation and statistical purposes
    • analyse and improve the activities and content offered by the website(s) to provide you with the most user-friendly navigation experience.
    • keep your data up to date and maintain an internal record of your relationship with us
    • communicate with you on progress of the status of your accreditation status (JETS) or if you are one of our assessors provide appropriate feedback on working with you
    • share for research using anonymised data
    • carry out audit and/or gain service intelligence using anonymised data
    • share with appropriate regulatory bodies and stakeholders.

    Patient/sensitive personal data

    We do not require access to any patient identifiable data or any identifiable data which relates to employees of your service. As your service is recognised as the data controller for any patient and employee data you hold under GDPR legislation, it is your responsibility to ensure you process the data accordingly.

    JETS and NED records patient age and gender from procedures performed by endoscopists.

    How we collect the data

    The majority of our information is obtained directly from you online. Procedure information is collected by NED directly from endoscopy reporting systems. Agreement is obtained at service level for this data to be shared.

    If you are an assessor that has expressed an interest in being part of our assessment team we may also capture your data via email.

    We may also obtain your information when we use cookies on our websites (see below).

    JAG uses cookies to ensure you get the best experience on the website. If you wish to, you may change your browser settings at any time. Go to www.aboutcookies.org for information on how to do this.

    What are Cookies

    Cookies are small information files placed on your device and are used to improve services for you by:

    • enabling the service to recognise your device so you do not need to give the same information repeatedly
    • recognising when you have already given a username and password so that you do not need to do so for every subsequent web page you visit
    • measuring how many people are using the services we provide, so we can make them easier and faster to use
    • analysing data, anonymously, to help us understand how people interact with government services.

    When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer, mobile phone or whatever device you are using to access the internet. This information is held in cookies. You can learn more about cookies from the article 'Internet Browser cookies - what they are and how to manage them'.

    Cookies cannot be used to identify you personally.

    For more information about how to remove cookies from your device, or how to block individual cookies from being received, please see the instructions and guidance at www.aboutcookies.org.

    See below for further details about cookies you may encounter while visiting our websites. These details include what information is being held, how long you can expect it to be stored, and how your experience of our website will change if you block individual cookies from being sent to your device.

    Cookie: Google Analytics

    Names: _gat, _ga, _gid, __utma, __utmb, __utmc, __utmt, __utmz

    Lifespan: Up to 2 years

    Purpose: Usage monitoring, these cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site.

    The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, the pages they visited and the technology they were using (browser, device information).

    Further information on the cookies used by Google Analytics can be found here

    Name: ASP.NET_SessionId

    Lifespan: Session

    Purpose: Strictly Necessary, used to maintain an anonymised user session by the server.

    Name: ASPXFORMSAUTH

    Lifespan: Session

    Purpose: Strictly Necessary, you must accept this cookie to be able to login to the website and use the elements within the site. Without this cookie the website will not function as intended.

    Name: CookieCompliance

    Lifespan: Unlimited

    Purpose: Tracks confirmation of cookie acceptance for the site on this deviceName: langLifespan: SessionPurpose: Functionality, used to store language preferences

    Name: __AntiXsrfToken

    Lifespan: Session

    Purpose: Strictly Necessary, used to protect against Cross-site request forgery (also known as XSRF or CSRF).

    Who do we share your information with and why?

    We share your data with:

    • Weblogik Ltd who are a Software Company under contract to the RCP to provide hosting and development of the programme websites, which is necessary for delivering the programmes
    • Accreditation assessors who are professionals working in the healthcare sector under contract to the RCP. We share your data with assessors for them to liaise with you on progress of your certification.

    Weblogik Ltd, all RCP assessors and other contractors are bound by the required legal and regulatory contractual clauses regarding confidentiality and data protection.

    The following individuals can also access your data through the JETS website:

    • Training leads, clinical leads or nominated deputy of any trust(s) or organisation(s) you are a currently a member of
    • Trainers of any trust(s) or organisation(s) you are a currently a member of who you have setup a list on the system with
    • For medical trainees with Specialist Registrar, ST3, ST2, ST1, LAT or LAS job role data will be available to regional training programme directors
    • Course administrators, centre leads and course faculty for courses you apply to

    The following individuals can also access your data through the NED website:

    • Clinical leads or nominated deputy of any trust(s) or organisation(s) you are a currently a member of

    We do not share your personal data with any other organisations but we do share your accreditation status data with the following organisations:

    Research

    JAG uses anonymous data for research provided the application for data is deemed appropriate by the JAG research committee. This may include the use of evidence provided for the purpose of service accreditation. All research outputs are published so that learning can be taken forward by endoscopy services. Individual services are not identifiable in any research outputs.

    Medical and surgical training deaneries

    Training programme directors for each region can access data regarding trainees (if on specialist register, ST3, ST2, ST1, LAT or LAS) attached to their deanery. This includes summary data and also access to the portfolios of each trainee.

    How long we keep your data and why

    The JAG programmes keep data relating to your account indefinitely. This is because the data is used for audit and research purposes to continually improve quality of training provision.

    Any user log-ins can be deleted upon request from the individual or appropriate service lead.

    If you are an assessor and your contract has ended, financial and contractual records will be retained in line with financial law and regulation for at least seven years after the end date. We will maintain some data such as your name and tenure on our assessor database for reference. Some personal data, such as your name and title, will continue to be available in historic assessment reports and historic comments on the website.

    Your rights relating to your personal data:

    If you are working with us an assessor, or are part of our JETS training programme then you have the following rights:

    • access to your data (Article 15)
    • have a copy in a standard format (Article 20)
    • restrict the use of your data (Article 18)
    • stop your data being used (Article 21)
    • have data deleted (Article 17)

    You have the right to access information which identifies you as a living person, held on RCP systems (Article 15). You also have the right to a copy of your data in a standard format, where technically possible (Article 20). For more information please contact the data protection officer.

    Where do we keep your data?

    The RCP hosts your data upon servers located within the EU, in accordance with current recommended data governance practices in the UK.

    How do we protect your data?

    We ensure that there are appropriate and operational measures in place to protect your personal data, in alignment with the requirements of Cyber Essentials and the Data Security Protection Toolkit.

    We have appropriate technical controls in place to protect your personal data including:

    • The RCPs external network perimeter is protected via dual boundary firewalls
    • Anti-virus and malware software/solutions have been deployed to all networked computers
    • All networked systems use password based authentication. Passwords must conform to a controlled standard
    • Networked systems are monitored externally via a managed SIEM solution, which provides real-time analysis of security alerts generated by applications and network hardware
    • Vulnerability scanning on all internal and external systems is carried out daily.
    • Mobile and removable devices are encrypted in line with organisation policy. Mobile smart devices can be remotely wiped on demand

    We have appropriate operational measures in place to protect your personal data.

    We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors. Unstructured data is monitored via a third party solution designed for this express purpose and any changes to file permissions generates an alert.

    We have a robust audit framework in place to ensure internal and external measures and obligations are in place and being maintained.

    We have appropriate contractual measures in place to protect your personal data:

    • Where we have contracted third parties to support us in the delivery of the accreditation programme a contract is in place that sets out our expectations and requirements, especially regarding how they manage the personal data they process on our behalf, or have access to.
    • Third parties are asked to complete a bespoke data security framework toolkit as part of the procurement process, which checks that they have the capability to meet the required standards when handling or processing RCP owned data.
    • Third parties invited to work on our systems are asked to complete a non-disclosure agreement, prior to accessing RCP information systems.

    Who to contact at the RCP and how to complain

    If you have any concerns about how your personal data is being collected and processed, or wish to exercise any of your rights detailed in this Privacy Notice please contact:

    The RCP Data Protection Officer

    Email: dataprotection@rcplondon.ac.uk

    Tel: +44 (0)20 3075 1505

    If you are not satisfied with how your information is managed by the RCP, you have the right to complain to the Information Commissioner Office.

    The ICO can be contacted at https://ico.org.uk/global/contact-us/

    Concerns can also be logged via the ICO website https://ico.org.uk/concerns

    Future Changes

    If our information practices change we will update this statement to reflect that. Regularly reviewing this information ensures you remain aware of what data we hold and use.

    This Privacy Notice was last updated on the 10 June 2020.