Privacy Notice

Who we are


We are the British Association of Plastic Reconstructive and Aesthetic Surgeons (BAPRAS). Our registered company number is 02657454 and our registered charity number is 1005353.
Registered office: Royal College of Surgeons of England, 38-43 Lincoln’s Inn Fields, London WC2A 3PE.
Phone: 0207 831 5161
Email: secretariat@bapras.org.uk

Purpose and scope of this privacy notice


BAPRAS respects your privacy and is committed to maintaining your personal information in accordance with the requirements of the EU’s General Data Protection Regulation and the Data Protection Act. We will take all reasonable steps to ensure that your personal data is kept secure against unauthorised access, loss, disclosure or destruction.

This privacy notice will inform you as to how we collect and look after your personal data. It will also help to explain your privacy rights and how the law protects you. 

Our Privacy Notice applies to the administering of memberships and the general supply products and services offered by BAPRAS. Separate privacy notices relating to prospective and current employees are available from the Head of Operations.

Our role in collecting or using your personal data
We are obliged to tell you that BAPRAS acts as a “data controller”. This refers to a specific legal term which signals that we collect personal data and we retain control over how it is used. 

Why we need to collect, use and share personal data
BAPRAS is a membership organisation. 

BAPRAS aims to be the voice of plastic surgery in the UK. We want to raise awareness of the breadth of plastic surgery, to promote innovation in teaching, learning and research and to increase overall understanding of the profession. 

BAPRAS aim to be a resource for plastic surgeons and other medical professionals. 

• We run educational events for both members and non-members. 
• We produce a medical journal, JPRAS, which is published by Elsevier. 
• We began the UK National Flap registry (data processing outsourced) which surgeons input data on flap operations completed in order to evaluate outcomes. 

What types of personal data collected, shared and used
To further our aims, we collect and use personal data from both members and non-members. The kind of personal data that we use can be described as follows.
• Data which identifies you. This includes your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, Medical Council or Registration Number, photograph.
• Data which expresses your personal preferences. This includes dietary requirements.
• Data used to contact you. This includes your billing address, delivery address, email address and telephone numbers.
• Data used for financial transactions. This includes bank account and payment card details.
• Data to facilitate transactions between us. This includes details about payments to and from you; and other details of membership benefits, products and services.
• Technical Data associated with your use of our website. This includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
• Profile Data. This includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
• Usage Data. This includes information about how you use our website, products and services. 
• Marketing and Communications Data. This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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How your personal data is collected


We use different methods to collect data from and about you including through:

• Direct interactions. You will give us your identity, contact and financial data when you become a member by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   • apply for membership or ask for products or services;
   • subscribe to our publications; 
   • request marketing to be sent to you;
   • enter a promotion or survey; or
   • give us some feedback. 

•  Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

•  Third parties or publicly available sources. 
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How we use your personal data


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the membership contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We will process your personal data in ways that enable us to run our operations and manage our relationship with you effectively, lawfully and appropriately, as well as to comply with any legal requirements. 

Personal information provided to us (name, address, email, phone number, etc.) will be used for the purposes outlined at the time of collection or registration, in accordance with the preferences you express, and can be processed by us for a number of different purposes including:

• administration of membership, including for Trainee Members, joint membership of PLASTA and BFIRST;
• fulfilment of orders for goods and services requested, including registration for educational courses, scientific meetings and other events, as well as subscriptions to publications, e.g. the Journal for Plastic, Reconstructive and Aesthetic Surgery (JPRAS);
• communication about membership, events and other activities that we think may be of interest to you;
• abstract submissions;
• grant and bursaries applications;
• administration of donations and legacies;
• research and statistical analysis;
• ensuring that all marketing communications you receive from us are relevant, such as tailoring messaging to our existing members and customers and potential members and customers to reflect their interests;
• complying with legal and regulatory requirements;
• verifying your identity when you contact BAPRAS.

We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes. 

Justifications for using your data
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing your information are:
What we are doing/why  What kind of data is involved (see references above) Why we think this is a lawful reason 
Registering you as a member -Data which identifies you
-Contact data 		 To perform the membership contract we have or will create with you 
To manage your membership, including managing payments and fees and to collect and recover money owed -Data which identifies you
-Contact data
-Data used for financial transactions
-Data to facilitate transactions between us 		 -To perform the membership contract we have or will create with you 
-Because we have a legitimate interest in recovering debts due to us
To manage our relationship with you, which may involve updating you on membership issues, notifying you of changes to policies such as this one, asking you for feedback on our services -Data which identifies you
-Contact data
-Technical data associated with your use of our website 		 -Because we have a legitimate interest in running the organisation, managing administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation 
To administer and protect the business of BAPRAS, to include the management of the website (which may include troubleshooting, testing, system maintenance, reporting and hosting of data -Contact data
-Technical data associated with your use of our website
 -Because we have a legitimate interest in running the organisation, managing administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation 
To deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we use on the website -Technical data associated with your use of our website

 -Because we have a legitimate interest in supporting and informing our membership, and developing the organisation
To use our data analytics to improve our website, membership services, marketing, membership relationships and experiences -Technical data associated with your use of our website

 -Because we have a legitimate interest in running the organisation, managing administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation 
To make suggestions and recommendations to you about member services which may be of interest to you -Data which identifies you
-Contact data
 -Because we have a legitimate interest in running the organisation and managing administration
To award grants in some cases -Data which identifies you
-Contact data
 -Because we have a legitimate interest in analysing any request for a grant to make a decision in relation to the same
To administer research through the UK Flap Registry -Data which identifies you
-Contact data		 -Because we have your consent to do so 
To assist with Trainee Members' reciprocal membership of PLASTA, the Plastic Surgery Trainee Association -Contact data -To perform the membership contract we have or will create with you 
 To assist with members' reciprocal membership of BFIRST, the British Foundation for Reconstructive Surgery and Training -Contact data  -To perform the membership contract we have or will create with you 
To assist non-members wishing to be part of Special Interest Groups -Contact data  -Because we have a legitimate interest in assisting these groups 
 To provide other delegates (including trade companies) at BAPRAS events with a delegate list  -Name
-Job title
-Location		 -To enable delegates at a particular event to obtain a list of names of event attendees 

If in the future we intend to process your personal data for a purpose other than that for which it was collected, we will provide you with information on that new purpose and any other relevant information.  

We will hold your information only for as long as necessary for each purpose we use it. 
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Your Marketing Preferences


BAPRAS always acts upon your choices around what type of communications you want to receive and how you want to receive them. However, there are some communications that need to happen regardless of your marketing preferences. These are what we would describe as essential communications to fulfil our promises to you as a member of BAPRAS or a buyer of goods or services from us. We may therefore use your identity, contact, technical, usage and profile data for the following:

• Membership-related mailings, such as your renewal reminders and AGM notices;
• Transaction notification messaging, such as payment confirmation or Direct Debit collection notifications;
• Communications about events you have registered to attend, etc.

We will ask for your express opt-in consent before we share your personal data with any company or charity outside BAPRAS for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us. When you opt out in this way, this will not apply to personal data provided to us as a result of your membership with BAPRAS.

Consent
Where we are processing data based on your consent, we will ensure that you are as fully informed as possible at the time as to how your personal information will be used, with whom it may be shared and how long we will keep it. This is in line with the requirements of the current data protection legislation.

If you have provided consent for the processing of your data, you have the right to withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.  

Your rights
Under the General Data Protection Regulation (GDPR) and The Data Protection Act (DPA) you have a number of rights with regard to your personal data. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as, in certain circumstances, the right to data portability. Your rights are set out in more detail below, in the 'Your Legal Rights' section

Your role in helping us to manage your personal data properly
It is important that the personal data that we hold about you is up to date and accurate. Please keep us informed of any changes to the information you supply to us.

If you fail to supply us with up to date personal data that is necessary for the administration of your membership (or is otherwise required as a matter of law) then we may need to review whether we can continue with your membership.
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Contacting us


To ensure that we process your personal data properly, we have appointed a data privacy manager. 

If, at any time, you wish to update or amend your personal data or preferences, or exercise your legal rights concerning personal data or if you have concerns as to how your data is processed, please write to: 

The Data Privacy Manager
BAPRAS 
35-43 Lincoln’s Inn Fields
London WC2A 3PE

E-mail: secretariat@bapras.org.uk

You also have to right to ask us, in writing, for a copy of all personal data held about you (this is known as a ‘subject access request’). A copy will be sent to you as soon as possible and no later than 30 days after your request. 

If you wish to raise any complaints on how we have handled your personal data, please contact us, and we will investigate the matter and notify you of our findings and any remedial action taken.  If you are not satisfied with our response or believe that we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner’s Office (ICO). 
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Sharing your personal information


BAPRAS may use external third parties to process your personal information on its behalf in accordance with the purposes outlined above. 

BAPRAS may share your personal information with the following groups for the purposes set out in the table above.

• BAPRAS employees, members and volunteers
• The publishers of the Journal of Plastic, Reconstructive and Aesthetic Surgery (JPRAS) and other relevant publications
• PLASTA, the Plastic Surgery Trainees Association
•BFIRST, the British Foundation for Reconstructive Surgery and Trainees
• Event participants and/or exhibitors at our educational courses or scientific meetings
• Organisers of other relevant events we feel might be of interest to you.
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In limited and necessary circumstances, your information may be transferred outside of the EEA or to an international organisation to comply with any legal or contractual requirements. In such circumstances, we will put in place safeguards, such as the use of encryption, to ensure the security of your data. 

Links to third party websites

This privacy policy applies solely to the personal data collected by BAPRAS and does not apply to third party websites and services that are not under our control.
 
We cannot be held responsible for the privacy policies of third party websites and we advise users to read the privacy policies of other websites before registering any personal data.
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Cookies


This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer / device.

Cookies are small files saved to the user's computers hard drive that track, save and store information about the user's interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google's privacy policy here for further information
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Data security and Retention


Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

By law we have to keep basic information about our customers (including your contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data pursuant to your legal rights (see below for further details)

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

Change of purpose 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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Changes to our Privacy Notice


We may change our Privacy Notice from time to time. However, we will not reduce your rights under this Privacy Notice. We will always update this Privacy Notice on our website, so please try to read it when you visit the website
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Your legal rights


You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated
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