Privacy Notice – The College of Naturopathic Medicine

Contents

Who are we?

We“, “our” or “us” means The College of Naturopathic and Complimentary Medicine Ltd of 25 Wolfe Tone Street, Dublin 1, Ireland.

If you have any questions about this policy or the ways in which we use your personal information, please contact the Privacy Team at The College of Naturopathic Medicine, 25 Wolfe Tone Street, Dublin 1, Ireland. 01 878 8060. dublininfo@naturopathy.ie.

This privacy notice will be updated from time to time to ensure that its contents remain accurate.

To enable you to understand how we are processing your data, we have split this notice into sections, based on who you are.

Enquiries, students and graduates

The information we collect about you and why we collect it.

If you make enquiries about the College or our courses, we may collect your name and contact details in order to register your interest and promote the College. We will use your information to answer your queries, send out prospectuses and send out our newsletter.

As part of your admission to the College we will collect certain enrolment details from you, such as your name, address, nationality, contact telephone number, date of birth, email address, profession, criminal record declaration and health record. We will use your information to enrol you on to the course and to deliver the course to you.

We will also keep records of your course fee payment history and any relevant medical letters you provide to us in connection with the course.

Once you have graduated from the College, we will continue to retain your contact information (as updated from time to time) to keep in touch with you and provide you with news about the College and information about the courses we offer.

The legal basis on which we collect and use your personal information.

Generally, the information is processed in order to enable us to perform our contract with you.

However, we will process your contact information on the basis of our legitimate interests in answering your enquiries and marketing the College. In doing so, we will offer you an opportunity to refuse marketing when your details are first collected and in subsequent messages.

Where the information is special category personal information (e.g. medical information) or details of criminal convictions we will process it with your explicit consent. Please note that we will need to process this information in order to be able to process your application and enrol you on the course.

How long we keep your personal information.

Your information on our contact database will be kept until you exercise your right to refuse our marketing (as described above).

With respect to our students and graduates, we will keep your information for the duration of the course and afterwards for keeping in touch with you (as one of our graduates) until you tell us that you no longer wish to hear from us.

How we share your personal information.

We may share the personal information that you give us with the following organisations (or types of organisation) for the following purposes.

With your consent:

  • whilst you are a student and after you have graduated, limited contact information is shared with the Association of Naturopathic Practitioners (ANP), which is a membership body relevant to our students so that they can invite you to local “continuing professional development” events, provide details of membership and offer free membership to qualifying students; and
  • whilst you are a student, the College will also confirm your status to the ANP to enable you to obtain student status for membership.

All this information is shared on the basis that the ANP’s events and services are directly relevant tothe subjects studied by our students on their courses.

We may also share your personal information with third parties who provide services to the College.

Our Clients in Student Clinics

The information we collect about you and why we collect it.

We will collect relevant personal and medical information about you, including: name, date of birth, age, address, telephone number, email address, sex, marital status, children, occupation, height, weight, waist circumference, and GP contact details.

We may also collect copies of test results, your medical history, and your current state of health as well as any relevant medical letters.

We collect this information to enable our students to conduct a consultation, offer naturopathic advice (nutrition, acupuncture or herbal medicine) and write a case study for their coursework.

The legal basis on which we collect and use your personal information.

We will process this information on the basis of your explicit consent.

How long we keep your personal information.

Your information will be kept for 7 years from the date of your appointment, unless you are under 18 in which case it will be kept for 7 years from the date you reach 18.

How we share your personal information.

Your information will be shared with our students, and the clinic supervisors, during the clinic and after the clinic via email.

We may also share your personal information with relevant third party suppliers (for example those who provide technical support to the online clinic booking system).

Our employees

The information we collect about you and why we collect it.

We will collect relevant personal information about you, including: your name and contact details, your nationality, date of birth, profession, bank details, NI details, a copy of your passport, and a copy of your CV (if applicable). Further information about how we deal with data protection issues is set out in our employee handbook.

The legal basis on which we collect and use your personal information.

Generally, we will process this information on the basis that it is necessary to perform our contract with you.

How long we keep your personal information.

Your information will be kept for 7 years from the date your employment finishes.

How we share your personal information.

We will also share your personal information with our third party suppliers (for example, our payroll processor).

Our suppliers (including but not limited to lecturers, Directors of Studies, Course Consultants, Course Directors and other freelance contractors)

The information we collect about you and why we collect it

We will collect and process your contact details, banking information and copies of your invoices in order to administer our contract with you.

If you are one of our lecturers we will hold your contact details and banking information, together with details of your CV, association membership, insurance, confidentiality agreement and criminal record declaration.

The legal basis on which we collect and use your personal information.

This information is processed on the basis of necessity to perform our contract with you.

Where that information is special category personal information (e.g. medical information) we will process it because there is a substantial public interest for us to do so.

How long we keep your personal information.

We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For our freelance contractors, it will be 7 years from the date of end of our contract with you.

How we share your personal information.

With your consent, whilst you are a lecturer at the College, limited contact information is shared with the Association of Naturopathic Practitioners (ANP), which is a membership body relevant to you sothat they can invite you to local “continuing professional development” events and provide details of membership. This information is shared on the basis that the ANP’s events and services are directly relevant to you.

Sharing your personal information

We do not share the information with any third party.

Users of our website

The information we collect about you and why we collect it

Our websites may use “cookies” to enhance your experience of it. These cookies may be set by our own websites, or by third parties whose services we use on our websites (such as Google or YouTube). Your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, note that some parts of our website may not function properly.

We may also collect personal information from you when you register on our website, fill out a form, and in connection with other activities, services, features or resources we make available on our website. The information you may be asked for includes your name, email address, mailing address, phone number, nationality, and how you found us. You may, however, visit our website anonymously. We will collect personal information from you only if you voluntarily submit such information to us. Users can always refuse to supply personal information, except that it may prevent them from engaging in certain website related activities.

We may collect non-personal information about you whenever you interact with our website. Third parties whose services we use on our websites may also collect your information. Non-personal identification information may include the browser name, the type of computer and technical information about you by means of connection to our website, such as the operating system and the internet service providers utilised and other similar information.

We will collect and use the personal information collected to run and operate our website, to improve customer service information we provide, to help us respond to your customer service requests and support needs more efficiently, and to improve our website. We may use feedback you provide to improve our products and services, and to send periodic emails.

The legal basis on which we collect and use your personal information.

You have agreed to us placing cookies by consent – by using our website you agree that we may place cookies on your computer or device (as describe above). Most web browsers allow some control of most cookies through the use of browser settings. If you want to find out more information about cookies including how to control what cookies are put on your computer or device and how to delete them then visit http://www.allaboutcookies.org/.

Other information is processed on the basis of our legitimate interests in operating our website effectively.

How long we keep your personal information.

We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some cases, such as when a visitor has registered an account on the website or has made an online purchase, we will retain the relevant personal information for longer, and for a maximum of 7 years from the date of the visitor’s last interaction.

Sharing your personal information

We do not share the information with unaffiliated third parties.

We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

General

How we transfer your personal information outside Europe.

We do not store or transfer your personal data outside Europe.

Automated decisions we take about you

We do not make automated decisions using this personal data.

Your rights

You have a number of rights over your personal information, which are:

  • the right to ask us what personal information about you we are holding and to have access to a copy of your personal information;
  • the right to ask us to correct any errors in your personal information;
  • the right, in certain circumstances such as where our use of your personal information is based on your consent and we have no other legal basis to use your personal information, to ask us to delete your personal information;
  • the right, in certain circumstances such as where we no longer need your personal information, to request that we restrict the use that we are making of your personal information;
  • the right, in certain circumstances, to ask us to review and explain our legitimate interests to you; and
  • the right, where our use of your personal information is carried out for the purposes of an agreement with us and is carried out by automated means, to ask us to provide you with a copy of your personal information in a structured, commonly-used, machine-readable format.