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Privacy policy

The British Medical Association (BMA) respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you as to how and why we collect, use and share your personal data and will tell you about your privacy rights, how the law protects you and how to contact us.

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

 

BMA privacy policy

  • Important information and who we are

    Purpose of this privacy notice

    This privacy notice applies when you visit our website (www.bma.org.uk). It also applies where you are a member of the BMA (past or present), a registered user of our website or contacting us for any other purposes.

    For example, this includes: when you apply to join the BMA, register with our website, use or purchase a member benefit, sign up to our newsletter, register for BMA events, conferences or services including subscribing to updates or bulletins, take part in a survey, use any of our social tools, take part in any trade union related activities or contact the BMA for any other purpose (including via social media).

    Our website and products and services are not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

     

    Controller

    The British Medical Association is the controller and responsible for your personal data (collectively referred to as "BMA", "we", "us" or "our" in this privacy notice).

    We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.

     

    Contact details

    Our registered office is BMA House, Tavistock Square, London, WC1H 9JP.

    If you have any queries relating to how we use your information please contact our DPO:

    Name: Alan Farmer
    Address: as above
    Email: [email protected]
    Tel number: 0207 387 4499

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 our DPO in the first instance.

     

    Changes to the privacy notice and your duty to inform us of changes

    This version was last updated on 22 May 2018. From time to time, we may change our privacy notice. We will post a notice on our website to notify you of any significant changes or update you by other appropriate means.

    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. As a trade union, we have a statutory requirement to keep an accurate register of members' names and addresses. If you wish to be a BMA member, you must provide this information to us.

     

    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 notice of every website you visit (for example to see how they use your information and to find out how to opt out, or delete, such information).

     

  • 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, BMA ID (membership number) GMC number, title, date of birth and gender.
    • Contact Data - includes postal and billing address, email address, telephone number and photos where you have agreed to provide this such as when participating at a conference.
    • Financial Data - includes bank account and payment details.
    • Transaction Data - includes details about payments to and from you and other details of products and services you have purchased and used from us.
    • 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 BMA ID and password, preferences, feedback, survey responses and opinions.
    • Usage Data - includes information about how you use our website, member benefits, products and services, attendance at events or conferences.
    • Marketing and Communications Data - includes your preferences in receiving marketing and membership communications from us.
    • Membership Data - includes membership subscription, BMA ID, employment status (employed, not employed, self-employed and etcetera), professional categories (branch of practices, grades and specialities) along with workplace(s), employer(s), start and end date.
    • GMC Data - includes licensing registration status and dates, GMC number, qualification country, GP and/or specialist register dates.
    • Case related Data - includes any information you provide to us about an employment or pensions related enquiry for which you require our support and assistance.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

    Sensitive personal information (also known as Special Categories of Personal Data) is information which relates, for example, to your health, sexual orientation, race or religion. We may obtain sensitive personal information about you if you volunteer it during any of your contact with us.

    If you are a member of the BMA, the fact of your membership is itself sensitive personal information, as trade union membership is included in the definition in the legislation. We will not share details of your membership of the BMA with third parties to use for their own purposes without your consent.

    We have additional obligations to treat sensitive personal information with appropriate care, taking into account the nature of that information. The best way to restrict the processing of your sensitive personal data is not to give it to us unless it is necessary for the services you are obtaining from us.

    As well as the fact that you are a BMA member, we also collect the following Special Categories of Personal Data about you: ethnic origin, sexuality, disability, and religious beliefs.

    The BMA is committed to representing a membership that is reflective of the diverse medical workforce in which our members work. As a part of this we seek to ensure that all our members are treated with dignity and respect regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. Effective monitoring is essential in order to fulfil our obligations to members and is a cornerstone of good practice to ensure compliance with equality legislation. While we realise there can be sensitivities surrounding the collection of this information, failing to do so risks reinforcing stigma and invisibility, as well as not addressing the issues affecting minority groups.

    The information you provide to us is confidential and protected by law. The confidentiality of personal information is a top priority for the BMA. Your personal information is not shared with any external organisation, government department, local council, or marketing company. The information collected will be used solely to produce statistics and for statistical research. Analysis of the data will be in aggregate form and will not be used in any way that allows individuals to be identified.

     

    If you fail to provide personal data

    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with membership services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

     

  • 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 Identity, Contact and Financial Data and the Special Categories of Data mentioned above by filling in forms or by corresponding with us by post, phone, email or otherwise.

    This includes, for example, personal data you provide when you:

    • apply to join the BMA;
    • create an account on our website (including when you use our social tools such as BMA connecting doctors);
    • subscribe to our services or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

    Automated technologies or interactions

    As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

     

    Third parties or publicly available sources

    We may receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from analytics providers such as Google based outside the EU.
    • Contact, Financial, Credit and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from data brokers or aggregators.
    • Identity and Contact Data from publicly availably sources such as Companies House.
    • GMC Data such as status as a registered doctor from the GMC register.

    Affinity Partners

    • The BMA has a number of 'Affinity Partners' with whom we have an agreement with to offer discounted, preferential or tailored products and services (such as independent financial advice) to BMA members. These benefits are advertised to our members through the BMA's marketing communications. To qualify for these benefits, the member must state their BMA ID or GMC number when buying a product or service on the Affinity Partner's website. Their name, BMA ID and GMC number is then verified using an online verification tool provided by us.
    • The Affinity Partner will provide personal data back to the BMA in order that we can monitor take up of products or services and understand which offers are of interest to which of our members (to continue to provide useful and relevant services).
    • The data aggregated by the BMA is only ever used in an anonymised form and will not be used to inform any decisions or actions against any individual member.
    • The BMA needs to process this data in order to deliver that service, or to instruct their partners on how to continuously keep on improving them.

     

  • 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 we need to perform the contract, we are about to enter into or have entered into with you.
    • 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 or regulatory obligation.
    • Where it is for our legitimate activities as a trade union and professional body, for instance when you contact the BMA for advice on an employment issue or take part in any of our trade union activities.

    Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 the ways we 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 / Activity Legal basis for processing

    Membership administration such as:

    • registering you as a BMA member;
    • processing your membership including:

      (a) managing payments, fees and charges

      (b) collecting and recovering money owed to us

    • holding your data on our membership database;
    • management and statistical analysis of our membership
    • confirming your identity when you contact us;
    • contacting you about your membership

    (a) Performance of a contract with you

    (b) In our legitimate interests

    (c) In the course of our legitimate activities as trade union and professional body

    Trade union activities such as ballots, elections and campaigns to comply with our legal obligations

    (a) To comply with our legal obligations

    (b) In our legitimate interests

    (c) In the course of our legitimate activities as trade union and professional body

    Equality monitoring

    Consent

    For further information about this please see paragraph 2

    Sharing your personal data within the BMA Some of your personal data will be available to BMA's staff, committee members and elected officials and others formally instructed by BMA for the purposes of carrying out our legitimate activities as a trade union and professional body.
    Collective and individual member representation

    (a) In our legitimate interests

    (b) In the course of our legitimate activities as trade union and professional body

    Employment advice, support and representation

    (a) Performance of a contract with you

    (b) In our legitimate interests

    (c) In the course of our legitimate activities as trade union and professional body

    Where we refer a member's case to external lawyers

    (a) In our legitimate interests

    (b) For the establishment, exercise or defence of legal claims

    Provision of member benefits (via our business partners) such as independent financial advice, insurance, legal and tax advice and learning and development.

    Verification of member's name, BMA ID and GMC number

    (a) Performance of a contract with you

    (b) In our legitimate interests

    (c) In the course of our legitimate activities as trade union and professional body

    To provide you with information and services that you request from us

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities - to respond to your queries and provide any information requested in order to generate and develop business. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.

    To send you alerts, newsletters, bulletins, announcements, and other communications concerning the BMA or which we believe may be of interest to you

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you. You can always opt-out of receiving direct marketing-related email communications or text messages by following the unsubscribe link.

    To invite you to events, conferences or other functions we believe may be of interest to you.

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you. You can always opt-out of receiving direct marketing-related email communications or text messages by following the unsubscribe link.

    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy

    (b) Asking you to leave a review or take a survey or participate in market research

    (a) Performance of a contract with you

    (b) To comply with a legal obligation

    (c) It is in our legitimate interests and

    (d) in the course of our legitimate activities (to keep our records updated and to study how members use our products / services)

    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (c) To comply with a legal obligation

    To deliver relevant website content including social tools (such as BMA connecting doctors) and measure or understand the effectiveness of the work we do

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities (to study how members use our products / services, to develop them, to grow our business and to inform our marketing strategy)

    To use data analytics to improve our website, products/services, marketing, member relationships and experiences

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities (to define types of members for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To make suggestions and recommendations to you about products or services that may be of interest to you

    (a) It is in our legitimate interests and

    (b) in the course of our legitimate activities (to develop our products / services and grow our business)

     

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

     

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.

     

    Third-party marketing

    We will not share your data outside the BMA group of companies for marketing purposes without your consent.

     

    Opting out

    You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or 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 you becoming a member, a product / service purchase, product / service experience or other transactions.

     

    Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

     

    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.

     

  • Disclosure of your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

    • Internal Third Parties as set out in the Glossary
    • 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 data processors and service providers to use your personal data (which we have shared with them) for their own purposes and only permit them to process such personal data for specified purposes and in accordance with our instructions.

    Please note, if you purchase a product or service (as a member benefit) from our Affinity Partners or other business partners you will become a client of theirs and will have a direct relationship with them. This means that they will be responsible for the personal data they collect from you and for informing you of their use of your personal data.

     

  • International transfers

    We may transfer your personal data to countries outside the European Economic Area (EEA). This may include circumstances where we use service providers who are based outside the EEA or who use "cloud" infrastructure which means that their servers could be based overseas. We understand our obligation to protect your personal data and consider carefully the appropriateness of these services.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

     

  • Data security

    We understand that the security of your information is important to you. 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. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access.

    Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.

    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.

    Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal data. 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

    How long will you use my personal data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    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 requirements.

    The criteria we use for retaining different types of personal data, includes the following:

    • General queries - when you make an enquiry or contact us by post, email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than one (1) year if we have not had any active subsequent contact with you.
    • Direct marketing - where we hold your personal data on our database for direct marketing purposes, we will retain your information for no longer than two (2) years if we have not had any active subsequent contact with you.
    • Legal and regulatory requirements - we may need to retain personal data for up to seven (7) years after we cease providing services and products to you, where necessary, to comply with our legal obligations, resolve disputes or enforce our terms and conditions.

    Specific examples include:

    • Membership records - we retain a record of your membership for seven (7) years after your membership ends or lapses for any reason.
    • Case files - we retain your case file for seven (7) years after your case is closed. Where we have given specific advice to a member this may have be retained for a longer period, for example pensions advice may be retained for fifty (50) years.
    • Website use - data relating to your activity when logged into our website is retained for two (2) years after last log on.

    In some circumstances you can ask us to delete your data: see 'request erasure' below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

     

  • 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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. We will advise you if this is the case at the time you withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact:

    Head of Records and Archives, Records and Archives Department, BMA House, Tavistock Square, London, WC1H 9JP Email: [email protected]

     

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

     

    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 may 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.

     

  • Contact our DPO

    Contact details

    Our registered office is BMA House, Tavistock Square, London, WC1H 9JP.

    If you have any queries relating to how we use your information please contact our Data Protection Officer (DPO):

    Name: Alan Farmer
    Address: as above
    Email: [email protected]
    Tel number: 0207 387 4499

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 our DPO in the first instance.

     

  • 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.

    Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    Legitimate activities as a trade union and professional body means the processing of your personal data with appropriate safeguards so that we can carry out our trade union activities and provide you with the support and services you would reasonably expect from a member association and professional body of doctors.

     

    Third parties 

    Internal Third Parties

    Other companies in the BMA Group acting as controllers, joint controllers or processors who are a part of providing our products and services (such as the BMJ and BMA Law).

     

    External Third Parties

    • Service providers acting as processors who assist in the operation of our organisation and in the provision of services such as IT and system administration and support services, data storage, hosting and back up services, back office functions, mailing houses, call centre services (FPC) and trade union administration.
    • Affinity Partners and other business partners acting as processors, joint controllers or controllers in their own right who provide some of our member benefits (for more information please see paragraphs 3 and 5 above).
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators (such as the ICO) and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • Market research and survey providers acting as processors who help to develop and improve our services.