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Privacy Notice for Dental Foundation Trainees

This privacy notice is intended to provide transparency regarding what personal data 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.

HEIW 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. HEIW 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 HEIW 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 can provide FD welfare / pastoral care if necessary.
  • Safeguarding information.
  • Accessing relevant NHS IT systems and EPDP systems.

The functions of HEIW 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, attend and participate in the Meet the Educational Supervisor (MES) event, and at the scheme inductions. 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), the DFT Team within HEIW, and the Foundation Dentists employer NHS Wales Shared Services Partnership (NWSSP).

Your personal data will be retained for seven 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:

  • The appointed Educational Supervisor and practice – for training purposes
  • Welsh Government - for workforce planning, funding, retention and service delivery in Wales
  • NHS Shared Services (NHSSS) - As the employer for Foundation Dentists
  • NHS Business Services Authority (NHSBSA)
  • Primary Care services - for the purpose of Performers list queries
  • 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
  • Speakers delivering online sessions, for the purpose of setting up the sessions, and sharing supporting resources relevant to the session.

HEIW 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.

HEIW 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).

Security of your Information

HEIW takes responsibility to look after your personal information very seriously. This is regardless of whether it is electronic or in paper form.

We also employ someone who is responsible for managing information and its confidentiality to ensure:

  • your information is protected; and
  • inform you how it will be used
  • all staff are required to undertake training on a regular basis. Comprehensive training is required to help protect the information that has been given, used, processed by HEIW
  • the training makes sure that all staff working in HEIW (including the wider NHS), are aware of their responsibilities about the handling of your information regardless of the department that they work in.

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 HEIW immediately if any of your personal data needs to be updated or corrected.

All communications from HEIW 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 HEIW 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 HEIW.

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.

Legitimate interest

HEIW and all its services have a “legitimate interest” in continuing to process personal data where:

  • there is a real business interest being pursued in continuing to process the personal data;
  • the processing is necessary for the business to pursue that interest (i.e. the interest cannot be pursued in another way which is proportionate); and
  • the processing is balanced against the impact such processing will have on the fundamental rights and freedoms of data subjects

It is important that you understand who is responsible for keeping your data safe. We collect your personal data with your express consent for purposes set out in this Privacy Notice.

The lawful basis for processing is set out in the GDPR Article 6. In this case, the function of this system is to deliver a recruitment service for which the processing of personal data is necessary. As a result, you do not have the right to erasure.

For more information, please refer to the Article 6 EU GDPR "Lawfulness of processing" website.

If you have any concerns in relation to how your personal data is processed, please contact the HEIW Dental team

Should you wish to learn further information about legislation relating to confidentiality, 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. Information Commissioner’s Office website

Making a complaint

If you wish to make a complaint about any issues you have experienced regarding your information, then please contact:

Dafydd Bebb
Board Secretary
Health Education and Improvement Wales

If you are still unsatisfied following your complaint and this remains unresolved, you have the right to make a complaint to the:

Information Commissioner’s Office,
2nd Floor,
Churchill House,
17 Churchill Way,
Cardiff, CF10 2HH

Further information

For more information relating to this privacy notice or questions on the content, please contact:

Health Education and Improvement Wales (HEIW)