Introduction VDS Training Services Limited is committed to protecting the privacy and security of your personal data.This Privacy Notice explains how we use your personal data and tells you about your privacy rights and how the law protects you. Data Protection Officer contact details Any questions regarding this Privacy Notice and our privacy practices should be sent: By email: privacy@vds-training.co.uk In writing: The Data Protection Officer, VDS Training Services Limited, 4 Haig Court, Parkgate Industrial Estate, Knutsford, Cheshire, WA16 8XZ. By phone: +44 (0) 1565 743862. About us We are VDS Training Services Limited (trading as VDS Training). We are a wholly owned subsidiary of The Veterinary Defence Society Limited (“VDS”, trading as VDS Insurance), a mutual insurance company who provides insurance against claims arising from allegations of professional negligence and the costs of criminal and/or disciplinary proceedings. VDS also provides its members with associated risk management services including advice, training and access to complementary third party insurance products and services. VDS’ members are veterinary surgeons and Registered Veterinary Nurses in the United Kingdom and the Republic of Ireland. In this Privacy Notice ‘VDS Training’, ‘we’, ‘us’ or ‘our’ means VDS Training Services Limited. ‘You’ and ‘your’ mean the individual who has enquired about or purchased a product or service from VDS Training. Our registered address is 4 Haig Court, Parkgate Industrial Estate, Knutsford, Cheshire, WA16 8XZ. We are registered in England and Wales under company number 10727838. We are registered as a Data Controller with the UK Information Commissioner under registration number ZA277556. We develop and deliver non-clinical risk mitigation training for vets, veterinary nurses and other members of the veterinary team. The vision of VDS Training is to ‘support and empower veterinary professionals, teams and businesses to achieve their personal and collective aspirations’. VDS also owns the subsidiary company VDS Support Limited (VDS Support) which introduces access to products and other membership benefits that have a close affinity and resonance with VDS members’ protection and wellbeing requirements. The personal data we collect Personal data can be anything that identifies and relates to a living person. This can include information that when linked with other information, allows a person to be uniquely identified. For example, this could be your name and contact details. We may collect and process the following personal data: · Identity and contact details such as your name, address, other contact details (e.g. email and telephone details), gender, date of birth, employer, job title and employment history, professional qualifications, information about the type of veterinary work or veterinary nursing work that you undertake, information about your attendance at training we have provided, dietary and access requirements for our events, video and/or photographs. · Financial and payment data such as your bank account number, transaction history and other related billing information. · Business information which may include information provided in the course of the contractual or client relationship between you (or your organisation) and us, or otherwise voluntarily provided by you or your organisation. · ‘Special categories of personal data’ which consists of: 1) Health data you may disclose to us such as current or former physical or mental medical conditions, health status, injury or disability information ,or 2) Criminal records data you may disclose to us such as criminal convictions · Product information where you have enquired about or purchased a product or service from the VDS, VDS Training or VDS Support, or from one of VDS Support’s business partners, which may consist of your name, a policy number, a premium amount and a commission amount. · Marketing data such as whether or not you have consented to receive marketing from us, the VDS or VDS Support or from other third parties. · Website and communication usage including details of your visits to our website and information collected through cookies and other tracking technologies, including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access (please refer to our Cookies Statement below). If you provide personal information to us about other individuals (for example, if you are booking a number of individuals on a course or event), you agree that you will inform them about the contents of this Privacy Notice and obtain any required consent in accordance with this Notice. When you call us we may record your call. This helps us with training and lets us monitor the service we provide. When you visit our premises, we may also collect information about you on CCTV, as part of our security and crime prevention measures. Training course and event attendees If you attend a training course or other event run by VDS or VDS Training, your personal data will be collected and processed. This includes personal data that you provide voluntarily (or via a third party booking the event on your behalf), such as your name, contact details, payment information, dietary and access requirements. Videos and/or photographs may be taken of you during the duration of the training course or other event and you may be invited to agree for images of you or any testimonials you may provide to be used in publicity material for any of VDS, VDS Training or VDS Support by signing an appropriate consent form. How we collect your personal data We collect and process personal information that relates to you either: · directly from you (including from forms and surveys that you complete, from your correspondence and phone calls with us and details of your visits to our website); · from our parent company, the VDS, where you are a member of the VDS; · from VDS Support, where you have enquired about or purchased a product from one of VDS’ partner providers; · from third parties such as your employer, business partners or subcontractors; · through our website and other software applications made available by us for use on or through computers and mobile devices; · from our social media pages and other social media content, tools and applications; · from the nominated individual who arranges your attendance at one of our courses or events, or anyone who acts as your agent in connection with the services we provide; · from publicly available sources such as internet search engines, news articles and social media sites. Your personal information may be collected and processed for a number of reasons: · In order to deal with your enquiries, and to create and deliver our range of training courses and other products and services which we, VDS or VDS Support may offer from time to time; · To administer our products and services and those provided by VDS and VDS Support; · To provide veterinary risk mitigation advice and training; · To assist with risk modelling; · To research your opinions and explore new ways to meet your needs; · To assess and develop our products, systems, prices and brand and the products, systems, prices and brand of VDS and VDS Support; · To fulfil any applicable legal or regulatory obligations; · To send you other forms of marketing communications from any of VDS, VDS Training or VDS Support which we believe may be of interest to you (see ‘Lawful Basis for processing your information’, below); · To monitor the use of VDS, VDS Training or VDS Support’s websites and online applications; · To maintain records of your use of the products and services provided via VDS, VDS Training or VDS Support; · To transfer books of business, company sales, restructuring and reorganisation to any appropriate third party who may lawfully require access to your personal information. What we do with the personal data We may use your personal data for a number of different purposes. For each purpose we must have a lawful reason to process it. When the information that we process is ‘special categories of data’ (or sensitive data) we must have a specific, additional legal reason to process such information. Please see ‘Lawful basis for processing your personal data’ below. The lawful basis for processing your personal data Data protection law requires us to rely on one or more lawful grounds to process your personal data. We consider the following grounds to be relevant: Consent Where you provide specific consent to us using your personal data for our business purposes. For example, to send you marketing communications by electronic means. We will provide an option to unsubscribe or opt-out of further communications on any electronic marketing communication sent to you, or you may opt out by contacting us (please refer to "Your right to withdraw consent" below). Performance of a contract We need your personal data in order to perform a contract, or when taking steps to enter into a contract with you, or your organisation. Examples would be where: · we use your personal data for contractual administrative purposes such as registering you as a customer, providing you with information about training or training materials you may have requested, or fulfilling an order for goods or services (whether placed online, over the phone or in person), such as delivering training to you. · to process payments, billing and collection. Legal obligation We need your personal data where necessary so that we can comply with a legal obligation to which we are subject, for example, where we are ordered by a court. Vital interests Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share your data with the emergency services. Legitimate interests This is when we have identified a genuine and legitimate reason for contacting you, which crucially does not override your own rights or interests. Broadly speaking Legitimate Interests allow us to process your personal information if we have a genuine and legitimate reason to do so. Before we rely upon our legitimate interest we will carefully consider and balance any potential impact on you and your rights. Examples of where we apply legitimate interests include: · Your best interests – processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure; · Keeping you informed of our services – by sending you marketing by post (or by email if you have provided your consent to receive electronic marketing) about our training courses, events and activities, products, services and offers, and those from VDS and VDS Support; · Keeping you informed about events and activities, products, services and offers from carefully selected third parties which we may engage with from time to time (where these may interest you or where a benefit is received by VDS Training) · Personalisation – where the processing enables us to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers; · Internal research and analysis – your personal data also helps us to get to know you better. Likewise, keeping a record of your veterinary work helps us to send you relevant information about risk mitigation and products and services that might be of interest to you. We carry out internal analysis on data relating to our customers, to determine the effect of risk mitigation training, better understand behaviour and responses, and identify patterns and trends. This helps inform our approach towards the training we develop and makes us a stronger and more effective organisation; · We process your data to determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you and to provide you with relevant information. To do this, we may make use of profiling and screening techniques of our customer database to communicate with you effectively and efficiently; · Due Diligence – we may need to conduct investigations on customers and potential customers to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption. When the information that we process is classed as ‘special categories of data’ we must have an additional ‘legal reason’. We will rely on the following legal grounds when we process your ‘special categories of data’: • Such use is necessary to protect your vital interests. For example, in the case of medical emergency suffered by an individual at one of our events. • You have provided your explicit consent to our use of your sensitive personal information. When we legitimately process your personal information in this way, we will consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law). Please note that we will only provide you with electronic marketing provided you have opted in to receive those communications. You have the opportunity to opt-out at any time as explained in the “Your right to withdraw consent” section of this notice. When we contact you There are reasons for us to contact you during your relationship with us. That contact may be by email, post, telephone or SMS. We encourage you to let us know your preferences by visiting vds-training.co.uk – Communication Preferences or by contacting the Data Protection Officer (details above). Marketing communications You can tell us if you would like to receive information about products and services we think you might be interested in. For example, to inform you of risk mitigation advice and training, researching your opinions and exploring new ways to meet your needs, assess and develop our products, systems, prices and brand. We may also send you newsletters or other marketing relating to ourselves, VDS or VDS Support. If you would rather not receive marketing communications from us, you can let us know at any time by using the unsubscribe function in our emails, by visiting vds-training.co.uk – Communication Preferences or by contacting the VDS Training Data Protection Officer (details above). The recipients or categories of recipients of the personal data From time to time, we may share your personal information with the VDS and VDS Support or with other third parties. We will keep your personal information confidential and only share it with the third parties listed below for the purposes set out in this Privacy Notice. Where relevant, we will share your personal information with: • VDS; • VDS Support; • our business partners or other product providers who we have engaged with in order to provide access to products and services to you; • our professional advisors (e.g. legal, financial, business, risk management or other advisors), bankers, insurers and auditors; • third party service providers, to whom we outsource certain functions such as information and document management, office support, technology and IT services, printing businesses; • Government or other public bodies such as law enforcement and HMRC; • veterinary membership organisations such as RCVS, VCI, SPVS and BVA; • selected third parties in connection with any sale, transfer or disposal of our business; • where necessary, courts and other alternative dispute resolution providers (such as arbitrators and mediators). Transferring your information outside of Europe As part of the services offered to you, the information which you provide to us may be transferred to countries outside the European Economic Area (‘EEA’). You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you are agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. Transfers outside of EEA will be protected by appropriate safeguards, namely the use of standard contractual data protection clauses adopted or approved by the European Commission. How we store your information We apply appropriate technical and organisational measures to encrypt and protect email traffic. If your email service does not support encryption, any emails we send or receive may not be protected. We use strict procedures and security features to protect communications and personal data from unauthorised access. Data is held in the United Kingdom using secure servers, in printed form and in secure off-site storage facilities. We also have 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. How long is your information kept for? We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal data for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. regulatory and tax/accounting purposes). We review our retention periods on a regular basis. Your data protection rights You have certain rights over the personal information that we hold about you. If you want to exercise any of the rights, please contact the Data Protection Officer (details above). We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay. Here is a summary of the rights that apply: Right of access You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. If you want to access your information, please send a description of the information you would like to see and proof of your identity. Right to have inaccurate personal information corrected You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us. If your details change, or if you believe any of the other information we hold is inaccurate or out of date, please let us know. Right of erasure You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, we will do so as far as we are required to. Right to restrict use You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we are not lawfully allowed to use it. Right for your personal information to be portable You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. Right to object (See section below). Right in relation to automated decision-making including profiling You have the right to request us to reconsider a decision or take a new decision that is not based solely on automated processing. A limited amount of automated decision making may take place and where such decision making involves automated processing, including profiling, you also have the right to request human intervention to review the decision. Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office. Your right to object You have the right to object to processing where we are using your personal information: · based on legitimate interests: · for direct marketing; or · for statistical/research purposes. Please contact the Data Protection Officer (details above). Your right to withdraw consent If you wish to withdraw your consent for the processing of your personal data as described in this Privacy Notice, please contact VDS Training’s Data Protection Officer (details above). Your choices As part of your relationship with us we may need to contact you from time to time for administrative purposes. We’re committed to putting you in control of your data so you’re free to change your communication preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and unless you exercise your “right to erasure” (as described above) we will retain your details on a suppression list to help ensure that we only contact you where it is necessary to do so as part of our relationship. How to complain If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, or if you think we have breached data protection legislation, you have the right to complain to the ICO, details below. Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) 01625 545 745 (national rate) Email: casework@ico.org.uk If you fail to provide personal data Where we need to collect personal data under the terms of a contract we may have with you, and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter with you to provide you with our services. Keeping your information up to date We take reasonable steps to ensure your information is accurate and up to date. Please let us know if your details change. Links to other websites Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website. Cookies We may receive information about you if you use any websites that we operate or other services we provide. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies: Strictly necessary cookies These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services. Analytical/performance cookies They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Targeting cookies These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Changes to this policy Any changes we may make to this Privacy Notice in the future will be posted on this website so please check this page to ensure that you're happy with any changes. If we make any significant changes we'll make this clear on this website. Review of this Policy We keep this Privacy Notice under regular review. This Notice was last updated in April 2019.