British Pain Society Privacy Policy

INTRODUCTION

This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you join the Society, continuing our relationship with you once we have become a member, providing you with a service or using your data to ask for your assistance in relation to one of our  projects.

It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Policy applies to the personal data of our members, users of our services and events,  and suppliers. 

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the organisation responsible for your personal data will be referred to as "BPS" or "us".

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

SHORT FORM "AT A GLANCE" SECTION

What kind of personal data do we collect?

• In order to provide the best possible membership experience we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, age, contact details, employment details and financial information (your salary band helps us determine fees). 
• We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
• In order to provide the best possible service to members and visitors to our website, we may acquire data on; subscriptions to our services or to our membership, participation in discussion boards or other social media functions, events you attend, posting material or requesting further services.

A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some, for example names and occupations, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly. 

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

How do we collect your personal data?

• We collect your personal data directly from you through our membership subscription forms.
• Information acquired/provided through our website.
• If you contact us, we may keep a record of that correspondence.
• Details of transactions you carry out through the website and of the fulfilment if of your orders for BPS products and services

How do we use your personal data?

• We will use your personal details to help us determine your correct membership category and to allow us to contact you if and when needed.
• We will use your data  to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.  
• Please note that communications to and from BPS staff including emails may be reviewed as part of internal or external investigations or litigation. 

Who do we share your personal data with?

• We may share your personal data with various parties, in various ways and for various reasons such as third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems, or where we outsource any of our business functions. For example, event software solutions for online events).
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place.
• A list of who we may share your personal data with is included in the long form policy.

How do we safeguard your personal data?

• We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. 

How long do we keep your personal data for?

• Your personal data will remain in our membership database for the duration of your membership.  Once you cease to be a member, we are required to keep it in our database for a period of ten years. This also has the advantage of allowing for an expedited process, should you choose to join the BPS again. 
• Your personal data not relating to membership, will only be kept for as long as a business process requires or to fulfil legal obligations to record keeping, depending on which is the longest. 

How can you access, amend or take back the personal data that you have given to us?

• Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us.  We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply. 
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time. 
• Data Subject Access Requests (DSAR): Just so it's clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or delete such information. At this point we may comply with your request or, additionally do one of the following: 
  • we may ask you to verify your identity, or ask for more information about your request; and
  • where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
• Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of your local supervisory authority: 

The Information Commissioner's Office
Phone: 0303 123 1113
Email: [email protected]
Post: Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow 
Cheshire 
SK9 5AF

• If your interests or requirements change, you can update your email preferences yourself within your member record (by signing into your account) or by contacting us on [email protected]

LONG FORM DETAILED SECTIONS

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

During the course of your membership application, we will collect the following information:

• Name
• Title 
• Gender
• Contact details 
• Job title 
• Place of work 
• Financial information (salary band) 
• Work speciality 
• Employment details 
• Member of a pain clinic 
• Member of IASP 
• Special Interest Groups 
• Professional Body 
• Email preferences
  
  Please note that the above list of categories of personal data we may collect is not exhaustive. 
   
• In order to provide the best possible service to members and visitors to our website, we may acquire data on; subscriptions to our services or to our membership, participation in discussion boards or other social media functions, events you attend, posting material or requesting further services.
• We don't collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.

HOW DO WE COLLECT YOUR PERSONAL DATA?

• We collect membership personal data directly from you. Personal data you give to us. BPS needs to know certain information about you in order to ensure your membership is appropriate and we can keep you informed about benefits.  
• There are numerous ways you can share or update your information with us. It all depends on what suits you. These may include:
  • Writing to us at Churchill House, 35 Red Lion Square, London WC1R 4SG
  • Calling us on 020 7269 7840
  • Emailing us on [email protected]

HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

• As an organisation with charitable status, we are required to keep a record of our membership. We generally use membership data to communications and engage with our members in the following ways:
  • Communicating key information such as elections, news and events
  • Marketing activity
  • Surveys
  • Publications
• We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not happy about this, in certain circumstances you have the right to object. 
• To carry out our obligations arising from any contracts entered into between you and us to provide you with the information, products and services that you request from us.
• To provide you, or permit selected third parties to provide you, with information about BPS goods and services which may interest you. We or permitted third parties will contact you by electronic means only if you have consented to this. You can opt-in/out of such notifications by following the instructions on the relevant forms set out on this website (or elsewhere as applicable) or at any time after providing your information.

Communicating key information

• We may periodically send you information that we think you may find interesting or information we are legally required to communicate to you. These may include, but are not limited to:
  • Notices of elections and Annual General Meetings
  • Outcomes from consultations with stakeholders such as NICE
  • News items about the Society

Marketing Activities

• We may periodically send you information that we think you may find interesting. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
  • enable us to develop and market benefits and services 
  • advise you of events you may be interested like the Annual Scientific Meeting and Study Days
  • provide you with information about certain benefits that you are eligible for by virtue of your membership.

Surveys

From time to time we will send out surveys to our membership to help us gather information and increase engagement. These surveys are entirely options for you to complete but do help us to make sure the Society is meeting your needs as a member.

Sending your publications

As a member, you are entitled to receive copies of the British Journal of Pain and Pain News. You are able to opt out of this mailing list.

• We may, from time to time, need your consent for some aspects of these activities which are not covered by our legitimate interests and we will ask you for this either when you join as a member or when you renew your membership annually.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

• Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:
  • Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation)
  • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems, or where we outsource any of our business functions. For example, event software solutions for online events). We may share your data with the following companies:
  • Caritas Management Group Ltd
  • Calm Digital Ltd
  • SAGE Publishing
  • BD & M Ltd 
  • Sandison Lang & Co 
  • Hempsons 
  • Bottomline Technologies
  • Access Storage
  • Wazir Medical Events Ltd
  • Prezzidium
  • Cvent Europe Ltd
  • Kenes International Organizers of Congresses SA
     
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place/ We may share your data with the following companies:
  • Adept 

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

• We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. 

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

• We will delete your personal data from our systems once you have ceased to be a member for 10 years. After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. We keep it for this long to allow for an expedited process, should you wish to rejoin.
• Your personal data (not relating to membership), will only be kept for as long as a business process requires or to fulfil legal obligations to record keeping, depending on which is the longest. 

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

• One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
• To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our members and suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests
  • we are processing your data for the establishment, exercise or defence of a legal claim.
  • If your objection relates to direct marketing, we must act on your objection by ceasing this activity. 
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so. 
• Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR)
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing. 
• We would only be entitled to refuse to comply with your request for one of the following reasons: 
  • to exercise the right of freedom of expression and information
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority
  • for public health reasons in the public interest
  • for archival, research or statistical purposes or
  • to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
• Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest. 
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it and
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of your local supervisory authority: 

The Information Commissioner's Office
Phone: 0303 123 1113
Email: [email protected]
Post: Information Commissioner's Office
Wycliffe House 
Water Lane
Wilmslow
Cheshire
SK9 5AF

https://www.gov.uk/data-protection/make-a-complaint

• If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact [email protected]  Please note that we may keep a record of your communications to help us resolve any issues which you raise.
• If your interests or requirements change, you can update your email preferences yourself within your member record (by signing into your account) or by contacting us on [email protected]
• It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

• Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by the BPS, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."  
• We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient membership service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please email [email protected] 

SUPPLIER DATA:

• We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services. 

CONSENT

• In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. This consent will be opt-in consent. 
• Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we'll make sure we give you enough information
  • you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
  • you need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way. 

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

• Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".
• This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

GLOSSARY

• Members – includes all people who are current members of the BPS or who have an application pending. 
   
• Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or staff. 
   
• General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it. 
   
• Staff – includes employees and interns engaged directly in the business of BPS (or who have accepted an offer to be engaged), working within the Secretariat.
   
• Council – includes all elected and co-opted members of the BPS Council.
   
• Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to BPS. All of our suppliers have an individual data processing agreement in place.

Appendix 1 – HOW TO CONTACT US

The BPS entity responsible for processing the personal data can be contacted as follows:

Phone:  020 7269 7840
Email: [email protected]

You can get in touch with us:

• to access, amend or take back the personal data that you have given to us
• if you suspect any misuse or loss of or unauthorised access to your personal information
• to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data)
• with any comments or suggestions concerning this Privacy Policy