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Privacy Policy

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Introduction

The Irish College of GPs respects your right to privacy and the protection of your personal data. In order to provide our services, the Irish College of GPs collects and processes personal data about you. The purpose of this Privacy Notice is to provide you, the data subject, with information about the processing of your personal data by the Irish College of GPs, and the rights that you have over your data.

Who we are

The Irish College of GPs, located at 4/5 Lincoln Place, Dublin 2, D02 XR68, Ireland, is a professional body for general practice in Ireland. Our purpose is to encourage, foster and maintain the highest possible standards in general practice. We remain committed to the education and training of GPs, enhancing their skills, competencies and professionalism. We are dedicated to general practice education, training, research and advocacy on behalf of professionals and patients. 
The Irish College of GPs is accredited by the Medical Council as the postgraduate training body responsible for the delivery and governance of general practice training in Ireland. At an international level, the Irish College of GPs is a member of the World Organisation of National Colleges and Academic Associations of General Practice. 
As a data controller, the Irish College of GPs is responsible for determining how and why your personal data will be used under the applicable EU data protection laws, such as the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 . 
Where links contained on our websites redirects you to another website (for example YouTube, X, LinkedIn, Medical Council, HSE, etc..) your personal data in such cases will be processed in accordance with their privacy notices and policies.  

What personal data do we collect?

Depending on the services that you use, the Irish College of GPs may collect and process your personal data for specified purposes, such as the following, non-exhaustive summary of our data processing activities: 

Processing Activity

Personal Data Collected 

To create your MyICGP Account

Name, contact details, and payment details for membership/examination/ course fees

To ensure the effective functioning of the website

IP Address, cookie data, and any information about your use of the website

To circulate our newsletters

Name and contact details

To monitor our premises with CCTV when you visit our offices

CCTV footage

To register for events and conferences

Name and contact details, including payment details for paid events, photographs if applicable

To publish podcasts (audio or video)

Name, contact details, video or audio recordings

To publish blogs and video interviews (GP stories) on BeAGP

Name, title, details that you provide through interviews, images

To verify references provided for GP trainee recruitment and other similar programmes

Name and contact details of referee, job title, place of work, relationship to applicant

To respond to complaints and queries about your membership, course or library information

Name, contact details, details of your query/complaint

To process applications for recruitment for various Irish College of GPs Programmes including but not limited to GP Trainee Recruitment and IMG Rural Programme  

Contact details, professional status, employment history, educational qualification, immigration status, country of nationality, health/medical considerations, proof of identity, photograph, Medical Council Registration Number, psychological assessment, disability information, date of birth, CV

To process your application and manage the delivery Programmes managed by the Irish College of GPs

Name, contact details, specific scheme training preference, anonymised data may be processed for training improvement, research and programme quality assurance purposes

To administer the professional competence scheme

Name, date of initial registration with Medical Council, Medical Council Registration number, GP qualification (Yes/No), country where the GP training was completed, education qualifications, employment history, and evidence of attaining PCS credits

To process personal data provided when undertaking examinations and assessments administered by the Irish College of GPs

Name, contact details, examination documentations, results, recording (video or audio as required) of the candidates during examinations, Trainee ID, profile picture, Irish Medical Council Number, special circumstances or accessibility needs

To fulfil compliance obligations with other organisations, including but not limited to Medical Council and Data Protection Commission

Financial details, including bank account numbers, BIC numbers, debit/credit numbers, and tax details

Additional detail about the purposes for which we process your data may be provided through our various resources, such as “how to use” guides, application forms, scheme guidance documents, etc. We have a separate Privacy Notice for our employees, and those wishing to become our employees, which can be accessed at the time of applying to the Irish College of GPs.

Why we process your personal data

We will handle the personal data you share with us in line with the General Data Protection Regulation (GDPR). Under Article 6 of the GDPR, we must have a lawful basis to process your personal data. The lawful bases we rely on are as follows: 

  • Consent: this is when you give clear consent to us to process your personal data for a specific purpose such as to be photographed at events, subscribing to a newsletter, and other communications or notifications
  • Contractual obligation: this is when there is a contract for service between the Irish College of GPs and you, such as when you create an account on MyICGP, enrol on the PCS ePortfolio
  • Legal obligation: the processing is necessary to comply with legal obligations, such as the Medical Practitioners Act and arrangements with the Medical Council as the regulatory authority
  • Public Task: In certain instances, we might process your personal data for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Irish College of GPs by other organisations such as the Medical Council or the HSE.
  • Legitimate interest: the processing is necessary for our legitimate interest, such as for recording CCTV footage, and facilitating attendance at events and meetings
  • Vital interest: the processing is necessary to protect someone’s life. It is highly unlikely that we will use this legal basis, however there may be limited instances where this applies. 

If we process any special category personal data the lawful basis under Article 9 would apply. To gain a more granular level of understanding on how the Irish College of GPs may process your personal data, please contact our Data Protection Officer at dataprotection@icgp.ie or, where applicable, please consult the specific guidance documents, code of conducts or handbooks for these activities. 

How we secure your data 

We use a range of physical, technical, and organisational measures to ensure that we keep your personal data secure, accurate and up to date. These measures include education and training for relevant staff to ensure they are aware of our data protection obligations when processing personal data; administrative and technical controls to restrict access to personal data on a need-to-know basis; technical security measures, including firewalls, encryption and anti-virus software; and physical security measures such as staff security passes to access our premises. 

How long do we hold onto your personal data

The Irish College of GPs will only retain your personal data for as long as is necessary to fulfil the purpose for which the data was collected. This period will also include and, in certain instances be informed by, legislation that creates a legal obligation for the Irish College of GPs to retain your personal data for regulatory purposes. To gain specific information about retention periods applicable to your personal data, contact our Data Protection Officer at dataprotection@icgp.ie 

In certain circumstances the Irish College of GPs may anonymise your personal data so that it can no longer be associated with you. Once the anonymised data ceases to be relevant for the processing activity, the Irish College of GPs may destroy your personal data securely in accordance with applicable laws.

Who will have access to your personal data 

The Irish College of GPs shall only share strictly necessary information about you to processors, controllers or other third parties for purposes identified in a contractual agreement and bound by the obligations prescribed by the GDPR and the Data Protection Act 2018. The Irish College of GPs will ensure staff members who are trained in data protection and are bound by confidentiality agreements and contracts will have access to your personal data on a need-to-know basis.

We may in limited circumstances transfer your personal information outside the European Economic Area (EEA). However, you can expect a similar degree of protection in respect of your personal information with additional safeguards in place, namely the use of the data transfer mechanisms outlined in the GDPR. 

The third parties that the Irish College of GPs shares data with on a regular basis to fulfil its obligations are the HSE, Medical Council, Global Payments, Risr, and service providers for the purposes of GP Trainee recruitment, IT and security.   

Cookies on the website 

Cookies are little pieces of text stored by your browser on your computer at the request of our servers. These often enable a specific functionality or enhance your user experience of visiting our website. These help to keep the website secure and analyse website traffic and how people use our website. You are always free to decline our functional and other similar cookies anytime you visit our website. Certain cookies classified as strictly necessary are installed on your device by visiting our website.

To learn more about cookies classification and to withdraw your consent to cookies please visit the Irish College of GP’s cookie policy and consent management page. You may also manually delete cookie files from your browser at your discretion. To disable cookies through your browser, follow the instructions usually located within the “Help,” “Tools” or “Edit” menus in your browser. However, please note that when you decline cookies, certain features of our website may be affected. If you have any questions or concerns on cookies, please contact our Data Protection Officer at dataprotection@icgp.ie 

Your rights as a data subject

Your rights as a data subject are provided under the GDPR and the Data Protection Act 2018.

They are as follows:

  • Right to be informed – You have the right to be informed in a clear and transparent manner regarding our processing activities, such as through this privacy notice.
  • Right of access – You have the right to request a copy of the information we hold about you and to check that we are lawfully processing it.
  • Right to rectification – You have the right to ask for incorrect, inaccurate or incomplete personal data of yours to be corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Right to seek erasure of your personal data (right to be forgotten) – You have the right, in certain circumstances, to request that your personal data be erased from our records.
  • Right to seek restriction of processing your personal data – You have the right to ask us to suspend the processing of your personal data in specific circumstances.
  • Right to object to processing of your personal data – You have the right to request that we stop processing your personal data or prevent us from processing your data in specific circumstances.
  • Right to data portability – You have the right to receive your personal data in a machine-readable format and send it to another controller, in certain circumstances.
  • Right to withdraw consent - You have the right to withdraw consent from the Irish College of GP’s communications and notifications, including newsletters.  
  • Right not to be subjected to automated decision making and profiling without human intervention and which results in a legal consequence or significantly impacts you. 

These rights may be subjected to certain exemptions or limitations that are available under the GDPR and the Irish Data Protection Act. If you wish to exercise any of your rights or want to know about the applicable exemptions, please contact the Data Protection Officer at dataprotection@icgp.ie If you are not satisfied with the resolution of your request by the Irish College of GPs, you may also raise your concern by way of a representation to the Data Protection Commission, Ireland through their website.

Data Protection Officer (DPO)

The Irish College of GPs has duly appointed Trilateral Research Limited as its Data Protection Officer (DPO). If you would like to learn more about how the Irish College of GPs processes your personal data or want to exercise your rights and raise any concerns, please contact the Irish College of GPs DPO directly (at dataprotection@icgp.ie OR Irish College of GPs, 4/5 Lincoln Place, Dublin 2, D02 XR68, Ireland, Contact No. 01 6763705). 

This notice is kept under regular review and is therefore subject to change. 

Last Updated: October 2024