DATA PRIVACY NOTICE
International Association of Ambulatory Surgery
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).
Who are we?
The International Association for Ambulatory Surgery (IAAS) is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
Other data controllers the council works with:
- National Ambulatory Surgery Associations
We may need to share your personal data we hold with them so that they can carry out their responsibilities to the association. If we and the other data controllers listed above are processing your data jointly for the same purposes, then the association and the other data controllers may be “joint data controllers” which mean we are all collectively responsible to you for your data. Where each of the parties listed above are processing your data for their own independent purposes then each of us will be independently responsible to you and if you have any questions, wish to exercise any of your rights (see below) or wish to raise a complaint, you should do so directly to the relevant data controller.
A description of what personal data the council processes and for what purposes is set out in this Privacy Notice.
How do we process your personal data?
IAAS complies with its obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. The majority of personal data held by the IAAS will be
- Linked to data you have provided in contacts with the IAAS – email, written and verbal contact
- Linked to data provided to subscribe to the Newsletter – name and email
- Linked to data you have provided for payment of services if you are a client
- Linked to data you have provided as part of your role as a member of the General Assembly
Please note the IAAS does not maintain a database of personal details of those visiting its website www.iaas-med.com.
The IAAS will process some or all of the following personal data where necessary to perform its tasks:
- Names, titles, and aliases, photographs (GA and ExCo members only);
- Contact details such as telephone numbers, addresses, and email addresses
- Banking details linked to payments for contractors and staff
Seldom used but possible
- Where they are relevant to the services provided by the IAAS, or where you provide them to us, we may process information such as gender, age, marital status, nationality, education/work history, academic/professional qualifications.
Not currently used and no plans to utilise
- Personal data may include sensitive or other special categories of personal data such as criminal convictions, racial or ethnic origin, mental and physical health, details of injuries, medication/treatment received, political beliefs, trade union affiliation, genetic data, biometric data, data concerning and sexual life or orientation.
- These types of data are described in the GDPR as “Special categories of data” and require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
- We may process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest.
The IAAS will comply with data protection law. This says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept and destroyed securely including ensuring that appropriate technical and security measures are in place to protect your personal data to protect personal data from loss, misuse, unauthorised access and disclosure.
We use your personal data for some or all of the following purposes:
- To confirm your identity to provide some services;
- To contact you by post, email, telephone or using social media e.g. Facebook, Twitter;
- To enable us to meet all legal and statutory obligations and powers including any delegated functions;
- To promote the interests of the IAAS;
- To maintain our own accounts and records;
- To seek your views, opinions or comments;
- To send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other new projects or initiatives;
What is the legal basis for processing your personal data?
The International Association for Ambulatory Surgery (IAAS) was founded in 1995 and is a registered charity in Belgium. Its main aim is to promote the worldwide development of high quality ambulatory surgery (aka: day surgery). Most of your personal data is processed for compliance with a legal obligation which includes the discharge of the associations statutory functions. For members of the General Assembly, Executive Committee and Ex Officio members this information will be necessary for communication and payment of expenses. For those signed up for the Newsletter this will merely be your name and email address which will NOT be passed on to other organisations.
We will always take into account your interests and rights. This Privacy Notice sets out your rights and the associations obligations to you.
We may process personal data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with the use of your service for the office functions of the IAAS e.g. accountant, lawyer or bank. Sometimes the use of your personal data requires your consent. We will first obtain your consent to that use.
Sharing your personal data
This section provides information about the third parties with whom the council may share your personal data. These third parties have an obligation to put in place appropriate security measures and will be responsible to you directly for the manner in which they process and protect your personal data. It is likely that we will need to share your data with some or all of the following (but only where necessary):
- The data controllers listed above under the heading “Other data controllers the council works with”;
- Our lawyers, bank or accountant.
How long do we keep your personal data?
We will keep some records permanently if we are legally required to do so. We may keep some other records for an extended period of time. For example, in the UK it is currently best practice to keep financial records for a minimum period of 8 years to support HMRC audits or provide tax information. We may have legal obligations to retain some data in connection with our statutory obligations as a charity. The association is permitted to retain data in order to defend or pursue claims. In some cases the law imposes a time limit for such claims (for example 3 years for personal injury claims or 6 years for contract claims). We will retain some personal data for this purpose as long as we believe it is necessary to be able to defend or pursue a claim. In general, we will endeavour to keep data only for as long as we need it. This means that we will delete it when it is no longer needed.
Your rights and your personal data
You have the following rights with respect to your personal data:
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
The right to access personal data we hold on you
At any point you can contact us to request the personal data we hold on you as well as why we have that personal data, who has access to the personal data and where we obtained the personal data from. Once we have received your request we will respond within one month.
There are no fees or charges for the first request but additional requests for the same personal data or requests which are manifestly unfounded or excessive may be subject to an administrative fee.
The right to correct and update the personal data we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.
The right to have your personal data erased
If you feel that we should no longer be using your personal data or that we are unlawfully using your personal data, you can request that we erase the personal data we hold.
When we receive your request we will confirm whether the personal data has been deleted or the reason why it cannot be deleted (for example because we need it for to comply with a legal obligation).
The right to object to processing of your personal data or to restrict it to certain purposes only
You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, within one month of receiving your request.
The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
You can withdraw your consent easily by telephone, email, or by post (see Contact Details below).
The right to lodge a complaint with the Information Commissioner’s Office.
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Transfer of Data Abroad
Any personal data transferred to countries or territories outside the European Economic Area (“EEA”) will only be placed on systems complying with measures giving equivalent protection of personal rights either through international agreements or contracts approved by the European Union.
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Changes to this notice
We keep this Privacy Notice under regular review and we will place any updates on www.iaas-med.com
This Notice was last updated in May 2018.
Please contact us if you have any questions about this Privacy Notice or the personal data we hold about you or to exercise all relevant rights, queries or complaints at:
The Data Controller, International Association for Ambulatory Surgery