This privacy notice explains how the Bowel Cancer Screener accreditation programme 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 applying for accreditation the RCP will collect and process the following data:

• Names, professional body, registration number, post held and qualification.
• Screening site and centre working at (including work address).
• Contact details including email and phone number.
• Procedure information where required for accreditation applications including performance and feedback using JAG procedure feedback forms (DOPyS) and details of failed procedures and clinical incidents.
• Assessment details, outcome and accreditation status.
• Name, job title, phone number and work address of finance contact at screening centre.

If you area professional that is, or wants to be, part of our assessment team then wewill collect and process the following data:

• Name, personal or work email address and telephone.

If you area screening centre administrator/programme manager involved in theaccreditation process, the RCP will collect and process the following data:

• Name, work email address and telephone.
• Screening site and centre working at (including work address).

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, including training days
• 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 JAG accreditation programme website 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
• send you details and updates about the programme including terms and conditions, subscription fees and newsletters
• communicate with you on progress of the status of your accreditation status 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

As part of the accreditation process, 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.

How we collect the data

The majority of our information is obtained directly from you as part of our registration and application process which is done online. We also obtain basic contact information from Public Health England which allows RCP to set-up user account on website.

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).

The BCSA programme 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'.

Cookiescannot be used to identify you personally.

For moreinformation about how to remove cookies from your device, or how to blockindividual cookies from being received, please see the instructions andguidance at www.aboutcookies.org.

See belowfor further details about cookies you may encounter while visiting the JAGwebsite. These details include what information is being held, how long you canexpect it to be stored, and how your experience of our website will change ifyou 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 howvisitors use our site. We use the information to compile reports and to help usimprove 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 thewebsite and use the elements within the site. Without this cookie the websitewill not function as intended.

Name:CookieCompliance

Lifespan:Unlimited

Purpose: Tracks confirmation of cookie acceptance for the site on this device Name: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 may share your data with:

• UK health systems in England, Wales, Scotland, and Northern Ireland, for reporting purposes
• Governance group members for the BCSA programme, for reporting purposes.
• 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 accreditation including arranging assessments.

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

We do not share your personal data with any other organisations, but we share your accreditation status data with the organisations listed below.

Bowel Cancer Screening Programme (BCSP) in England

Accreditation of screening endoscopists

JAG is responsible for the operational delivery of accreditation for screening endoscopists. All endoscopists must be accredited in order to provide screening. JAG also hosts the accreditation panel which set the criteria for the accreditation assessments.

JAG share details of the result of each accreditation assessment with Public Health England and NHS England as requested.

Service accreditation

BCSP require services to be JAG accredited prior to permitting them to start undertaking either colonoscopy or bowel scope screening. On an ongoing basis, BCSP use JAG accreditation status as one of the criteria they use to assess a services performance.

If a screening centre loses accreditation, BCSP will review whether screening can continue and will stop screening activity should there be concerns about safety or should a service not regain accreditation in a timely manner. Additionally, BCSP does not undertake quality assurance visits to services if they hold JAG accreditation.

JAG informs BCSP of changes in services’ accreditation status on an ongoing basis and provides BCSP with a copy of all accreditation reports and letters.

Bowel Screening Wales

JAG is responsible for the operational delivery of accreditation for screening endoscopists. All endoscopists must be accredited in order to provide screening. JAG also hosts the accreditation panel which set the criteria for the accreditation assessments.

JAG share details of the result of each accreditation assessment with Bowel Screening Wales.

Bowel Screening Wales are responsible for delivery of screening in Wales. Tosupport their role, JAG routinely share names, email addresses, applicationdata and accreditation status of candidates applying for accreditation.

PublicHealth England

Public Health England (PHE) provides support and advice to the NHS-led national screening programmes. To support their role, JAG routinely share names, email addresses, application data and accreditation status of candidates applying for accreditation.

NHS England/NHS Improvement

NHE England and Improvement commission bowel cancer screening accreditation activity. To support their role, JAG routinely share aggregated accreditation information.

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.

How long we keep your data and why

JAG keeps data relating to your service for as long as you are ether an accredited service or are in the process of becoming one. Any user logins will be deleted upon request from the individual or service, so please make sure to update us if a user or contact is leaving the organisation.

Financial and contractual records will be retained in line with financial law and regulation for at least 7 years.

Please be advised that any service reports will be kept on file permanently so that a record of previous engagement and assessments can be maintained and progress over time can be reviewed. Any staff performance data collected as part of the evidence gathering process for accreditation will be kept on file as per our programme data retention policy.

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.

You have the right to ask us to restrict the use of your data (Article 18), stop your data being used (Article 21) or have your data deleted (Article 17). All requests will be judged on a case-by-case basis, we may refuse a request if it’s incompatible with our requirements or if it will impact on our ability to deliver our service. We will approve all requests that do not impact on our ability to deliver services.

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 confirm with 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:

Email:askjag@rcp.ac.uk

The RCP Data Protection Officer

Email: dataprotection@rcp.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.

Thisprivacy notice was last updated on 5 April 2024.