THE ROYAL COLLEGE OF RADIOLOGISTS

Last Updated: 07.08.2023

iRefer Privacy Policy

This Privacy Policy contains 10 sections. Each section starts with a brief summary and is followed by more detailed information.

1 Introduction

Welcome to the iRefer website. This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection law, The Royal College of Radiologists is the controller of that information.

The Royal College of Radiologists (we, our or us) are committed to protecting and respecting your privacy.

This Privacy Policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use. Please read the following carefully.

This policy describes the way we handle and use the personal information that we obtain from you when you visit our website currently located at www.irefer.org.uk (Site).

We are the controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information.

This policy was last updated on the date that appears at the top of this page.

2 Personal information we collect about you

We receive personal information about you that you give to us, that we collect from your visits to our Site and that we obtain from other sources. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.

Personal information that you give to us

We collect the following information if you choose to give it to us when you visit our Site or social media pages or when exercising your legal rights:

your name, title and contact details (email address, telephone number and postal address);
the organisation for whom you work, if applicable;
the login credentials to your account on the Site;
any information you include in correspondence you send to us or in forms you submit to us when using our Site;
details of your orders;
your marketing preferences;
the opinions and other information you provide when responding to user surveys;
your identification information when exercising the rights that you have in relation to our processing of your personal information (see further Your rights in relation to your personal information ); and
in relation to certain refunds, your bank account details.

Information that we collect about you

When you use the single sign-on feature to login to your account, collect from the relevant social media site:

your full name; and
your email address.

When you visit our Site we automatically collect:

the internet protocol (IP) address of your device and details regarding the type of device and browser software you use to access the Site;
details of your use of our Site, namely traffic data, weblogs and statistical data, including where and when you clicked on certain parts of our Site and details of the webpage from which you visited it;
details regarding when and how you consented to receive marketing communications from us (including the time and date you provided your consent); and
cookie, pixels and beacon identification information (for more information please see our Cookies Policy).

3 Use of your personal information

We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive unsolicited marketing communications from us if you have consented and can opt-out of receiving them at any time. We do not share your personal information with companies that would send their marketing to you.

We use your personal information in the following ways:

3.1 Where you have provided CONSENT

We may use and process your personal information to contact you via email or SMS (as indicated by you) with marketing information about our products and services where you have consented for us to do so, including to identify and record when you have received, opened or engaged with our website or electronic communications (see marketing for further details).

We also process your personal information that we collected using certain cookies for which we request consent, as identified in our Cookies Policy.

You may withdraw your consent for us to use your information in any of these ways at any time. Please see Your rights over your personal information for further details.

3.2 Where necessary to comply with our LEGAL OBLIGATIONS

We will use your personal information to comply with our legal obligations:

to keep a record relating the exercise of any of your rights relating to our processing of your personal information;
to use certain cookies that are strictly necessary for the functioning of our Site, as further identified in our Cookies Policy; and
to handle and resolve any complaints we receive relating to the services we provide

3.3 Where necessary for us to pursue a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

for analysis and insight conducted to inform our marketing strategies, and to enhance and your visitor experience; and
to tailor and personalise our marketing communications based on your attributes.

Processing necessary for us to support our visitors with their enquiries

to respond to correspondence you send to us and fulfil the requests you make to us.

Processing necessary for us to respond to changing market conditions and the needs of visitors to our Site and social media pages

to analyse, evaluate and improve our products and services so that your visit and use of our Site are more useful (we will generally use data aggregated from records relating to many people so that it does not identify you personally);
to undertake market analysis and research (including contacting you with surveys) so that we can better understand the way users use our Site;
for product development purposes.

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

to administer our Site and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
for the prevention of fraud and other criminal activities;
to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
for the purposes of corporate restructure or reorganisation or sale of our business or assets;
for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
to use cookies certain that are strictly necessary for the functioning of our Site, as further identified in our Cookies Policy;
to inform you of updates to our terms and conditions and policies; and
for other general administration including managing your queries, complaints, or claims, and to send service messages to you.

3.4 Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT

We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract. This only applies where you are placing an order with us in your personal capacity and not on behalf of an organisation.

Marketing communications: If you give your consent, we may use your personal information to contact you by email or SMS (as you indicate) to send you marketing information. If you do not wish to receive email or SMS communications from us, please inform us by using the unsubscribe link inside the email or code within the SMS or by using the contact information at the end of this policy.

If you opt-out of receiving marketing communications from us, we keep your email address on our suppression list for a defined period to ensure that we comply with your wishes. Please see further The periods for which we retain your retain information.

4 Disclosure of your personal information by us

We only disclose your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.

We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including the operation and maintenance of our Site and social media pages. Our Suppliers can be categorised as follows:

Recipient / relationship to us	Industry sector (& sub-sector)	Location
Advertising, PR, digital and creative agencies	Media (Advertising & PR)	U.K.
Banks, payment processors and financial services providers	Finance (Banking & Payment Processing)	U.K. and U.S.A
Cloud software system providers, including database, email and document management providers	IT (Cloud Services)	U.K.
Facilities and technology service providers including scanning and data destruction providers	IT (Data Management)	U.K.
Insurers and insurance brokers	Insurance (Underwriting & Broking)	U.K.
Legal, security and other professional advisers and consultants	Professional Services (Legal & Accounting)	U.K.
Market research providers	Media (Market Resarch)	U.K.
Website and data analytics platform providers	IT (Data Analytics)	U.K.
Website and App developers	IT (Software Development)	U.K. and India
Website hosting services providers	IT (Hosting)	U.K.

When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.

We may disclose the personal information to other third parties as follows:

any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event;
if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals or regulators; and
single sign-on service providers if you choose to log into our Site using this feature. This Site incorporates a feature provided by social media and other digital service providers that allows you to log into your account on this Site using the same login you have already set up with those providers. This feature is known as a ‘single sign-on service’. When you choose to log in using these services, we collect your first and last name, as well as your email address.

5 Transfers of your personal information outside of Europe

Except in a limited number of cases, we do not transfer your personal information outside of Europe. Where we do, we take measures to protect your personal information.

Some of the information you provide to us may be transferred to countries outside the UK and European Economic Area (EEA). These countries may not have similar data protection laws to the UK and EEA. Countries outside these locations to which we transfer your personal information are listed in the table under Disclosure of your personal information by us however in respect of all our Suppliers, your personal information may be sent to such countries in the course of their provision of remote support services.

Where we transfer your information outside of the UK and EEA in this way, we take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected in the ways required by data protection law as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information using standard clauses issued by the UK data protection regulator or the UK Secretary of State and relying on decisions the latter issues declaring that a country is adequately protective of personal information to a degree that allows us to safely transfer your personal information to that country. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy or access to the relevant documents.

If you use our services whilst you are outside the UK and EEA, your information may be transferred outside the UK and EEA in order to provide you with those services.

6 Security and links to other websites

We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to our Site may not be completely secure, so please exercise caution. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.

We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Site, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties.

Our Site may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites‚ so we encourage you to read their privacy policies. We are not responsible for the privacy policies and practices of other websites (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience.

In addition, if you linked to our Site from a third party website, we are not responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

7 The periods for which we retain your personal information

We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a very short period whilst for others we retain it for a period of 7 years after the information is no longer required for business reasons so that we can deal with any legal proceedings that could arise.

We retain your personal information for the following periods:

Type of personal information	When do we receive your personal information?	How long do we keep your personal information after we receive it?
Details regarding when you have consented to receiving marketing from us	When you complete the consent form	2 years from the date you complete the form.
Location and frequency of your visits	When you create an account on our Site	5 years from the date you create an account.
Details of your orders	When our systems record your order	7 years
Your identification information in relation to the processing of your personal information	When we you provide this to us following our request to verify your identity	3 years
Opinions /other information you give via surveys	When you submit your form online	2 years if you have completed a feedback questionnaire, then archived. Up to 2 years for all other research.
IP addresses other than Authorised IPs (see our Terms for further information) and type of device	When you use any of our websites or apps	1 month from the date of collection.
Authorised IPs (see our Terms for further information)	When we set up your access to the Site	7 years from the date your organisation’s subscription ends.
Details of your use of our website, including cookies, pixel and beacon information	When you visit our Site	Various periods - please see our Cookies Policy for details of individual expiry periods of cookies.

The only exceptions to the periods mentioned above are where:

you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Your rights in relation to your personal information);
you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your rights in relation to your personal information);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
we archive the information, in which case we will delete it in accordance with our deletion cycle in accordance with good industry practice; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.

8 Your rights in relation to your personal information

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.

Find out more..

You have the following rights, some of which may only apply in certain circumstances:

to be informed about the processing of your personal information (this is what this statement sets out to do);
to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

to object to processing of your personal information;

Where we rely on our legitimate interests as the legal basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

to withdraw your consent to processing your personal information;

Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

to restrict processing of your personal information;

You may ask us to restrict the rocessing your personal information in the following situations:

where you believe it is unlawful for us to do so,

you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

to have your personal information erased;

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

to request access to your personal information and information about how we process it;

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

to electronically move, copy or transfer your personal information in a standard, machine-readable form; and

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

rights relating to automated decision making, including profiling.

You have rights in relation to significant decisions made about you based purely on automated processing. We do not intend to make decisions about you in such ways but will update this policy if this changes.

To find out more about each of your rights, please click the ✓ icon next to each right above. To exercise these rights, please contact us using the details at the end of this policy.

You have the right to lodge a complaint with the UK data protection regulator. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website, where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.

9 Changes to our Privacy Policy

Please check this page regularly for changes to this policy. We will email you with changes if we hold a valid email address for you.

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our Site and/or by contacting you by email. Any changes will take effect 7 days after we post the modified terms on our Site or after the date we notify you by email. We recommend you regularly check this page for changes and review this policy each time you visit our Site.

10 Contact and legal information

You can contact us with your queries in relation to this policy or for any other reason by post, email or by phone.

To contact us in relation to this policy, including to exercise any of your rights in relation to your personal information, please contact our Data Protection Team by email at irefer@rcr.ac.uk.

For anything else, including general enquiries, please contact us by post at The Royal College of Radiologists, 63 Lincoln's Inn Fields London WC2A 3JW, United Kingdom, or by phone on 020 7405 1282.

The Royal College of Radiologists is a body constituted by Royal Charter in England and a charity registered with the Charity Commission for England and Wales with charity registration number 211540.