TNA Privacy Policy 

1.0 Introduction 

The Nottinghamshire Alliance Training Hub (NATH) hosted by NEMS Community Benefit Services Ltd (NEMS) is commissioned by Health Education England (HEE) and the Nottingham & Nottinghamshire Integrated Care System (ICS) to meet the educational needs of the primary and community care workforce, and bring together NHS organisations, community providers and Local Authorities. 
The Training Needs Analysis (TNA) Survey is a process of determining gaps between the current and desired knowledge, skills and abilities of those working in Primary Care. The survey is published and managed by NATH and comprises of a number of questions looking at staff roles, learning priorities and interest in learning topics, as well as barriers to learning, communication methods and development needs. 
As a “data controller” under the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018, we are required under data protection legislation to notify you of how we will process your personal data. This privacy statement outlines why and how we collect your personal data, it’s use, storage, transfer and security, and provides information about your rights in relation to how we process your data. It applies to all data provided to us as part of the TNA survey. 
Personal data is defined as any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual. When “you” or “your” are used in this privacy statement, we are referring to the relevant individual who is the subject of the personal data. 
We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection. 

2.0 Contact details 

If you have any questions about the survey or would like to discuss anything in this privacy statement, please contact NATH using the details below. 
Nottinghamshire Alliance Training Hub 
NEMS Platform One 
Station Street 
NG2 3AJ 
Tel: 0115 883 6294 

3.0 Collection of personal data 

NATH is the ‘data controller’ for the personal data collected and used in the TNA survey. This means that we decide how to use it and are responsible for looking after the data in accordance with UK GDPR and the Data Protection Act 2018. 
Our policy is to collect only the personal data necessary for agreed purposes. 

3.1 Categories of data 

The types of data we may process as part of the survey include: 
Personal identifiers and contact details (e.g., name, GP Practice, role, email address) 

4.0 Why we collect and use data 

The lawful bases for processing data are set out in Article 6 of the UK General Data Protection Regulation (UK GDPR). The sections of this privacy statement explain our processing of personal data using the legal basis of consent. 
UK GDPR stipulates that processing shall be lawful if the data subject has given consent to the processing of his or her personal data for one or more specific purposes. By indicating that you have read and understood the Privacy Policy before completing the survey, you are giving consent to the processing of your data by NATH for the purposes outlined below: 
To assist NATH in identifying training requirements of the primary care workforce. 
To inform the design and development of educational and training packages to meet local needs. 
To establish training priorities of different groups of staff working in Primary Care across Nottingham and Nottinghamshire. 
To assist in planning Continued Professional Development (CPD) training events open to the whole workforce – short sessions to update skills or knowledge. 
To assist in planning Education Programmes which support ICS priorities linked to population health management that enhance your skills and knowledge. 
To assist in allocating CPD and Workforce Development Funds across Nottingham and Nottinghamshire. 
To signpost individuals to relevant training from other providers (if requested). 
To report training needs based on the Place-Based Partnership localities and Primary Care Networks (PCNs) (subject to a sufficient number of responses per PCN), to support any local discussions about workforce needs. 
To share a summary of the feedback with PLT planning groups, and other partner organisations to foster inclusive partnerships and collaboration to deliver training across the ICS and avoid duplication. 
Whilst some personal information you provide will be mandatory (e.g., job role, GP Practice) for the purpose of understanding local training needs, some data is requested on a voluntary basis (name, email) and is only asked for if an individual requests additional information. In order to comply with data protection legislation, we will inform you at the point of collection, whether you are required to provide certain personal information to us, or if provision of the data is optional. 

5.0 How we will use the data 

All of the information that you provide will be treated as confidential and will only be used for the purposes outlined in Section 4.0 above. 
Your responses will not be identified as belonging to you. Instead, they will be combined with those gathered from other survey participants and will be analysed as part of a group. 
If we ask you for personal information that enables you to be identified (e.g., your name or e-mail address). We will clearly state why we are asking for it and for your permission to use it for that purpose. For example, it might be to inform the winner of a prize draw, or to add you to our mailing list. 
We will process your data only because you have provided your consent to do so. The data you provide will only be used for the purposes for which we collected it, unless we consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent before doing so. 

5.1 Confidentiality 

Your responses to the survey will remain confidential and will only be used by NATH for the purposes outlined in Section 4.0. 
Every effort will be made to ensure anonymity of responses in the reporting of results. By this, results will be aggregated – that is, individual responses will be combined with others and presented as a group in all reporting, neither allowing for the identification of individual respondents nor the attribution of any responses to an individual using identifiers (e.g., Job Title, GP Practice). 
NATH will process the survey responses and apply privacy controls before publishing the results on the website or via any other communication channels. 
Results may be shared internally with other departments, and externally with our partner organisations across the Nottingham and Nottinghamshire ICS where necessary, for the purposes outlined in Section 4.0. 
Examples of external partners we may share the data with include (but are not limited to): 
You will not be required to disclose your name or other personally identifiable information, however you may voluntarily offer personal or contact information at the end of the study if you wish to be contacted by NATH with further information about training, career and/or development opportunities. 

5.2 Data storage 

NATH will retain the survey data you provide in electronic format for up to five years after the survey has concluded, to allow comparisons to be made between the results of two or more surveys. After five years, the data you have provided will be deleted. 

6.0 Rights of Data Subjects 

Your participation in the survey is voluntary. 
Please see below further information about your rights over your personal data. Should you wish to request a copy of your personal data, amend your data, or delete any personal data held by NATH, please complete our online TNA Data Request Form. 

6.1 Access to personal data 

Under UK GDPR legislation, you have the right to request access to information that we hold about you. 

6.2 Rectification of personal data 

You have the right to request for your personal data to be amended or rectified where it is inaccurate, and to have any incomplete personal data completed. Once we are informed that any personal data processed by us is no longer accurate, we will update the information. 

6.3 Deletion of personal data 

You are entitled to ask that all, or part of the record of your involvement in the TNA survey be deleted or destroyed, in certain circumstances: 
The personal data are no longer necessary in relation to the purpose(s) for which they were collected and processed. 
Our legal basis for processing is consent. If you withdraw that consent and we have no other lawful basis for the processing of your personal data. 
Your personal data have been unlawfully processed. 

6.4 Restrict processing of data 

You have the right to restrict our processing of your personal data if your personal data have been unlawfully processed and you request restriction of processing instead of deletion. 

6.5 Right to withdraw consent 

Where we process your personal data using only your consent, you have the right to withdraw that consent before the closing deadline of the survey, without reason, and can do so by contacting us using our TNA Data Request Form and quoting your unique ID. 
This withdrawal can only happen during the window which your personal data is identifiable (i.e., before the survey closing date). Once data has been aggregated (i.e., combined with others and presented as a group in all reporting) it will not be possible to identify individuals, nor attribute any responses to an individual using identifiers (e.g., Job Title, GP Practice). 

7.0 Data security 

The data you provide will be stored on a password protected secure electronic network which is only accessible by specific members of NEMS. 
Only authorised staff will have access to your personal information and are obliged to respect its confidentiality. NATH will not share any personal information supplied by you to a third-party data controller. Nor will we use any of the information you provide for direct marketing or other activities, unless you have explicitly requested or subscribed to this. 

8.0 Complaints 

If you have a concern or complaint about the way we are collecting or using your personal data, please contact us in the first instance. You also have the right to complain to the Information Commissioner’s Office (“ICO”) in the UK (as the UK’s data protection regulator) via the ICO Complaints website. 

9.0 Changes to this privacy statement 

We may need to update this privacy notice periodically. This version was last updated on 15 January 2024. 
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