Version 3.0 (updated June 2024)
Welcome to the Privacy Policy for www.ontrackpharmacy.com.
The Royal Pharmaceutical Society respects your privacy and is committed to protecting your personal data. ONtrack is a website that offers pharmacy students the opportunity to purchase and complete pharmacy exam practice assessment materials on a subscription basis.
This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how the Royal Pharmaceutical Society collect and process your personal data through your use of this website, including:
• When you browse our website;
• When you log in to our subscribers only section of the website;
• When you interact with any RPS staff or workers;
• When you interact with any surveys or competitions;
• When you request further information about RPS.
This website is not intended for children or anyone under the age of 18 and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
DATA CONTROLLER
This Website (www.ontrackpharmacy.com and our associated web pages, including third party platforms) is operated by the Royal Pharmaceutical Society of Great Britain incorporated by Royal Charter in England and Wales under company number RC00079 and having its principal business address at 66-68 East Smithfield, London E1W 1AW (‘we’ and ‘our’).
For the purposes of the Data Protection Act 2018 and all relevant data protection legislation (including the UK GDPR), we are the “data controller” (i.e. the company who determines the purpose(s) of processing of your personal data, and is responsible for undertaking this processing).
We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy, including any requests to exercise your legal rights. You can contact our data protection officer using the following details:
Calvin Smith
66-68 East Smithfield, London, E1W 1AW
data.protection@rpharms.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), however, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance if you have any questions or feedback.
CHANGES TO THIS POLICY
We review this Privacy Policy periodically, so there may be minor changes from time to time. We encourage all website visitors to frequently check this page for any changes. Any historic changes can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
From time to time, we may introduce new processing activities into our practices. Whenever this takes place, we conduct reviews with relevant staff to ensure that the format of the processing minimises any risks to personal data, and is compliant with all relevant legislation, and we update this privacy policy accordingly.
THIRD PARTY LINKS
This website may include links to third-party websites, plug-ins, and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We only retain data for as long as necessary to facilitate the purpose that it is collected for. We have established processes within our teams and systems which ensure that data which is no longer required or has reached the limit of our stated retention period is deleted. Except where legally obliged to do so, we do not retain an audit trail of these deletions, and we do not retain any records of your personal data beyond the stated retention period.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
| Category | Types of data included | Retention period |
| Identity data | First name, last name, username or similar identifier, and title, and, where you are an RPS member, your RPS membership number. | For the duration of your RPS membership or ONtrack subscription, plus 4 years after your membership lapses / your last login to the website (whichever is more recent). |
| Contact data | Billing address, delivery address, email address and telephone numbers. | For the duration of your RPS membership or ONtrack subscription, plus 4 years after your membership lapses / your last login to the website (whichever is more recent). |
| Financial data | Bank account and payment card details | 6 years after transaction. |
| Transaction data | Details about payments to and from you and other details of products and services you have purchased from us. | 6 years after transaction. |
| Technical data | 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. | 28 days - except for cookies (Cookie expiry periods set out in our Cookie Policy). |
| Profile data | Your username and password, question sessions completed on www.ontrackpharmacy.com, purchases or orders made by you, preferences, feedback, and survey responses. | For the duration of your RPS membership or ONtrack subscription, plus 4 years after your membership lapses / your last login to the website (whichever is more recent). |
| Usage data | Information about how you use our website, products, and services. |
Usage data linked to your profile is retained for the duration of your RPS membership or ONtrack subscription, plus 4 years after your membership lapses / your last login to the website (whichever is more recent). Other usage data is deleted after 28 days |
| Marketing and communications data | Marketing and Communications Data includes your preferences in receiving marketing from us, including marketing relating to ONtrack and the Royal Pharmaceutical Society, and our third parties and your communication preferences. | For the duration of your RPS membership or ONtrack subscription plus 4 years after your membership or subscription lapses |
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.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
| Category of data | Collection method |
| Identity, contact, profile, and career data. | Your institution may provide you with a profile to log in or you may create your own profile on our website. |
| Identity, contact, profile, career, transaction, and financial data. | Direct interactions such as registering a profile, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • Purchase an ONtrack subscription; • Log in to complete ONtrack learning materials; • Email us with a query; • Report a problem with our site; • Share information (e.g. a direct message through a social media platform); • Enter a promotion or competition or complete a survey; or • Give us feedback or contact us. |
| Identity data. | Internal authentication from your existing RPS membership account is used to verify whether you are entitled to a free subscription. |
| Contact, financial, and transaction data. | Third party providers of technical, payment and delivery services (please see glossary for specific third party details). |
| Technical, usage data. |
Automated technologies or interactions with our website. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details. This data may also be accessed by third parties, such as: • Analytics providers (please see glossary for specific third party details); • Search information providers (please see glossary for specific third party details); • Website troubleshooting services (please see glossary for specific third party details). |
| Marketing and communications data. | Direct interactions when you tick boxes to opt in or opt out of marketing through your account and communications from us or unsubscribe to any of our communications. |
4. USING 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 process the data to perform a contract we are about to enter into, or have entered into with you. For example if you subscribe to ONtrack.
• 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.
• Where you have given us consent.
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 logging into our preference centre or by contacting us at pharmpress-support@rpharms.com.
PURPOSES OF USE OF PERSONAL DATA
Below, we have set out a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate). Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
| Purpose/activity | Type of data | Lawful basis for processing (including basis of legitimate interest) |
| To register you as a new user or subscriber, and to allow you to complete your user profile. | (a) Identity (b) Contact (c) Profile |
(a) Performance of a contract with you. |
| To authenticate your entitlement to a free subscription (RPS members only) and to feedback to RPS about member uptake. | (a) Identity | (a) Performance of a contract with you. (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). |
| To process and deliver your subscription including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us. | (a) Identity (b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to recover debts due to us). |
|
To manage our relationship with you which will include: |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services). |
| To enable you to complete learning materials on our website and to track your progress. | (a) Identity (b) Contact (c) Profile (d) Usage |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (to promote the education and development of the pharmacy profession). |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation. |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. | (a) Technical (b) Usage |
(a) Necessary for our legitimate interests (to develop our products/services and grow our business). |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests (to grow our business). See “Marketing” section below. |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
(a) Necessary for our legitimate interests (to grow our business). See “Marketing” section below. |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can sign up for and amend your marketing and advertising preferences through your account on ontrackpharmacy.com - where you can view and make certain decisions about your personal data use.
We have established a preference centre where you can change your email preferences: https://www.ontrackpharmacy.com/my-details.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside the Royal Pharmaceutical Society group of companies for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time. Please note that setting changes can take up to seven days to be fully processed.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchases, including registration for our applications, product/service experience or other transactions.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .
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.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• This will include sharing data with the Royal Pharmaceutical Society and the Pharmaceutical Press.
• External Third Parties as set out in the Glossary.
• 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.
6. INTERNATIONAL TRANSFERS
We share your personal data with the External Third Parties listed in the Glossary (Paragraph 10). This will involve transferring your data outside the European Economic Area (EEA). Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only directly transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries .
• Where we use certain service providers not based in the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection that it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. SECURITY MEASURES
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, 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 following our instructions, and they are subject to a duty of confidentiality.
Where you have access to a secure area of the website, or to any external platform linked to the site, you are responsible for keeping your login details and password(s) confidential and protected. We ask you not to share your password with anyone. You can change your password at any time by logging in. We accept no responsibility or liability if a third party obtains and uses your ID or password. You must tell us immediately if you believe someone may have access to or use of this information.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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.
As a general rule, we keep personal information about subscribers for a period of 4 years following the lapse of their subscription or RPS membership.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
1. 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 processing it lawfully.
2. 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.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legal 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.
4. 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 basis 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.
5. 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.
6. 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.
7. 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.
If you wish to exercise any of the rights set out above, please contact our data protection officer at data.protection@rpharms.com or using the contact details set out at the beginning of this policy.
NO FEE USUALLY REQUIRED
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.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
• Braintree, based in the US, who provide payment processing services.
• Google Ad Manager, based in the US, who provide website advertising services.
• Google AdSense, based in the US, who provide website advertising services.
• Google Analytics, based in the US, who provide anonymised website usage data analytics.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
• OneTrust, based in the US, who provide cookie management services.
• Pingdom, based in the US, who provide website performance monitoring services.
• Redwing, based in the UK, who provide IT, system administration and customer mailing services.
• Survey Monkey, based in the US, who provide surveys for market and business research purposes.
• Zendesk, based in the US, who provide support and workflow services.
