1. Introduction
Who we are and what we do
- The Pharmaceutical & Technology Clinical Management Association (previously the Pharmaceutical Care Management Association and trading as the PTCMA) is a Non-Profit Company providing continuing professional development (CPD) programmes in the healthcare environment through webinars, online courses, online journal club sessions, recorded content and live seminars and workshops.
- The PTCMA is sensitive to the personal nature of the information you may share with us from time to time.
Acceptance and changes
- By registering for a PTCMA event or programme, registering on the PTCMA Portal, signing in at a PTCMA event or providing us with your personal information in any other way, you agree to and accept this Privacy Policy (as amended and updated from time to time) and authorise us to process your personal information as set out in this Privacy Policy. You also authorise the PTCMA, our affiliates, employees, consultants, agents, service providers and other third-party collaborators to process your personal information for the purposes stated in this Privacy Policy.
- To the extent that you are providing information about your company of employment or a client company you are warranting that you have the authority to share that information.
- This Privacy Policy explains how we protect and use your personal information in support of and in compliance with the Protection of Personal Information Act, 2013. We will review and update this policy from time to time.
- We will post any modified version of our Privacy Policy at https://www.ptcma.org.za/portal-privacy-policy/. If we change the Privacy Policy in a way that materially lessens or changes our commitment to you, we will provide notice to PTCMA Portal users by email.
Platforms this Privacy Policy is applicable to
- Website: https://www.ptcma.org.za/
- PTCMA Portal: https://portal.ptcma.org.za/
- Moodle site: https://education.ptcma.org.za/
- Any other channel we might gather information from, including Zoom, emails, etc.
2. Scope of this Privacy Policy
- We treat all personal information with respect. We will not use any of your personal information for data mining or for any purpose other than those described in this Privacy Policy.
- We will endeavour to protect all the personal information you provide us from time to time from unauthorised alteration, loss, disclosure, or access.
- This Privacy Policy applies to all external third parties with whom we interact from time to time, including all our individual users, representatives from member and ad hoc client organisations and other users of our products and services. It also applies to our affiliates, employees, consultants, agents, collaborators, service providers and other third parties who help us deliver our services to you.
- This Privacy Policy might contain examples to illustrate how and why your information might be used and in which possible contexts. These examples are to be seen as such and should not be read in a way that will limit the broadness of any clause in this Privacy Policy as they are for illustrative purposes only.
3. Data we collect about you
We collect information about you when you register for our programmes through our website or on Zoom, on the PTCMA Portal, the online course Moodle platform or sign up for our newsletter on the PTCMA website. In addition, third parties may collect information about you when you use our services.
Personal information in this Privacy Policy refers to all information relating to an identifiable living person and an existing company or other juristic person, and includes information relating to you, to your company, or the company you represent.
As such, we may from time to time process the following types of personal information about you:
Profile information
To create a profile on the PTCMA website or sign up for any PTCMA programmes, you will need to provide or give us permission to process the following:
- Personal details and identifiers: names, photographs, addresses, phone numbers, email addresses, professional council registration numbers, SAMA membership details and details from your public social media profiles.
- Demographic information: sex, gender, date of birth and age, nationality, titles and language preferences, information relating to broad based black economic empowerment status or other affirmative action programmes.
- Attendance records: details of meetings, webinars and other events organised by or on behalf of PTCMA that you might have attended.
- Other participation records: comments and questions posted in webinar chat boxes, online course comments, assessment submissions and grades.
- Payment and financial information: billing addresses, bank account numbers, invoice records, payment records, VAT numbers. Online payments may be made through PayFast and will be processed by them as per their privacy policy. The information PayFast gathers will not be accessed or stored by the PTCMA.
- Data relating to your visits to our website and applications: device types, browser types and settings, IP addresses, language settings and other technical communications information.
- Employment details: general occupation category, names, addresses, phone numbers, websites and applications, and email addresses of the organisation and people within the organisation.
For this purpose, the processing of personal information in our possession from time to time refers to anything that is done with your personal information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Content
We also create or record content from time to time that may include your personal information, such as:
- Recordings of meetings and webinars held virtually on Zoom and other digital platforms which will be shared from time to time on the PTCMA platform using Vimeo and other video sharing sites.
- Records of your interactions in the Zoom chat box for feedback and question review purposes – if shared with everyone, this will include your name, if sent directly to the meeting chair or tech support, only the content of the message will be shared.
Presenters
- Meetings will be recorded from time to time as requested by the co-facilitator providing the unconditional educational grant. Permission for the presentation content to be recorded will be discussed between the presenter and the co-facilitator. If the request for a recording is presented to the PTCMA, we will assume consent from the presenter.
- The personal information of the presenter is provided by the co-facilitator. An email will be sent to the presenter with all the meeting details as well as all the personal information received. It is the responsibility of the presenter to review the information and respond should anything be incorrect or if they do not want their information used as set out in this Privacy Policy. Should the presenter not respond, their logging into the meeting will be seen as agreement and acceptance of this Privacy Policy.
- Additional information collected on presenters include their field of specialty, current position, qualifications and short bio. This will be circulated on the invitation and used to introduce the presenter in the meeting. In addition the bio will be shared with the CPD offices to apply for CPD accreditation.
4. How we collect your data and why we collect it
We may collect or receive personal information about you in the course of our relationship with you:
- In the course of providing educational services to you or your organisation in person, through Virtual platforms such as Zoom and when we visit you.
- Directly from you or otherwise, for example from your company of employment or other organisation through whom you receive the benefits of our products and services, or, in the case of presenters, from the co-facilitating company providing the unconditional educational grant.
- When you visit or interact with our website (ptcma.org.za), Portal (portal.ptcma.org.za), online course (education.ptcma.org.za) or our various social media platforms.
- When you make your personal information public
- When you register to use any of our products or services including interactive webinars, online courses, live events and newsletters.
- When you interact with any third-party content on our online platforms or linked from our online platforms.
- This includes analytics gathered by Google Analytics as per their Privacy Policy, and Vimeo, the programme used to share recordings and other video content, as per their Privacy Policy.
Correspondence
Records of your communications and interactions with us, including email and WhatsApp correspondence, may be stored from time to time if the content is necessary for the services provided or for accountability.
Purposes for which we process personal information
- We will process your personal information only in the ordinary course of our business of providing educational content and related services through our various products.
- As the PTCMA is a non-profit organisation, we rely on co-facilitators to provide unconditional educational grants to make our meetings possible. By agreeing to this Privacy Policy, you allow us to share the following information with the co-facilitator of whichever session you might attend:
- Your name and surname
- Company name
- General occupation
- Council registration number
- Duration of meeting attendance
- Any information and questions you might post to everyone in the chat box
- Views of videos and completion of MCQs
This is for the co-facilitators’ internal processes and compliance.
- We may also otherwise subject your personal information to processing during the course of various business-related activities, including:
- Operating our business
- Analysis, evaluation, review, collation of information and reporting in order to understand our audience and encourage future grants
- Compliance with legal and CPD requirements
- Transfer of information to our consultants and other third parties as they assist in providing our services.
- We may process your personal information for relationship management and marketing purposes in relation to our services, for purposes of providing the services we deliver to you, for accounts management, and for marketing activities in order to establish, maintain and improve our relationship with you and our services providers. We may also analyse your personal information for statistical purposes.
- We may process your personal information for internal management and management reporting purposes such as conducting internal audits, implementing internal business controls, providing central processing facilities and for management reporting analysis.
5. Whom we share your data with
Our associates include the PTCMA Executive Committee, directors, employees and advisors. We also have a number of third-party service providers, including providers of information technology services and products, communication services, networks and products, data providers and storage, file storage, printing, scanning and copying service providers, CPD accreditation service providers, auditors, tax consultants, financial advisors, insurers, brokers and other professional services.
- We may disclose your personal information to our associates and service providers, for legitimate business purposes, in accordance with applicable law. In addition, we may disclose your personal information:
- If required to do so by law.
- If required to do so by regulatory authorities, upon request.
- If your right of participation is based on your company of employment or membership of another association.
- In these cases, your personal information might be shared from time to time for the company to review their membership, for KPI purposes, and as a measure to ensure up-to-date information.
- Where necessary for purposes of, or in connection with, actual or threatened legal proceedings.
- If we sell or otherwise transfer all or any portion of our business or assets, including as part of a reorganisation, dissolution or liquidation.
- If our website uses third party advertising, plugins or content.
- If required by our service providers, such as providers of data hosting services and document review technology and services internationally.
International Transfer of Personal Information
We may share your personal information to recipients outside the borders of South Africa provided that:
- We recognise that foreign operators must be subject to laws, binding corporate rules, enforceable policies, or binding agreements which provide a similar or higher level of data protection to that applicable in South Africa.
- They undertake to protect your personal information in line with all applicable data protection legislation and regulation.
- Such sharing is necessary in order to provide our services, or the services are by their nature internationally based, such as data and cloud hosting services.
As such we will review our relationships with such operators and, to the extent required by applicable law, will require them to be bound to only process your personal information with our prior written instructions, and to use appropriate measures to protect the confidentiality and security of such personal information.
6. Data storage and security
- We implement appropriate technical and organisational security measures to protect your personal information in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access, in accordance with applicable law.
- All the information you share on the PTCMA Portal is saved on a secure, dedicated server.
- Some basic information will be stored on Campaign Monitor – they are fully GDPR compliant and secure.
- All PTCMA documentation, including formats of your personal information, is stored on a secure online cloud-based server.
- Payment details for the payment gateway when paying for online courses, workshops or other products or services are stored on a third-party (PayFast) server as per your account with them. The PTCMA does not store this information, neither do we have access to it.
- Where there are reasonable grounds to believe that your personal information in our possession has been accessed or acquired by any unauthorised person, we will notify you and the relevant regulator, unless a public body responsible for the detection, prevention or investigation of offences, or the relevant regulator, informs us that notifying you would impede a criminal investigation.
- Because the internet is an open system, the transmission of information via the internet is never completely secure. Although we will implement all reasonable measures to protect your personal information in our possession, we cannot guarantee the security of information transmitted electronically and we cannot be held liable for any loss of privacy that occurs during the course of such transmission.
7. Data Accuracy and Minimisation
The personal information provided to PTCMA should be accurate, complete and up-to-date. Should personal information change, the onus is on the provider of such data to notify PTCMA of the change and provide PTCMA with accurate data.
- PTCMA will restrict its processing of personal information to data which is sufficient for the fulfilment of the primary purpose and legitimate secondary purposes for which it was collected.
- PTCMA will only retain and store personal information for the period for which the data is required to serve its primary purposes and legitimate secondary purposes, and for the periods required to comply with any applicable legal requirements.
8. What rights you have over your data
You may have rights under South African law to access your personal information and to ask us to rectify, erase and restrict use of your personal information.
You also have access to your profile on the PTCMA Portal where you can review your information and update as needed.
You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us, and to withdraw consent to the use of your personal information.
9. Cookies and Similar Technologies
We may process your personal information by our use of cookies and similar technologies, for purposes of recording information about the devices and browsers you use and, in some cases, your preferences and browsing habits.
When you visit our website, we may place cookies on your device, or read cookies already on your device, subject always to obtaining your consent where required and in accordance with applicable laws.
10. Marketing
We may process your personal information for the purposes of providing you with information regarding services that may be of interest to you and you may unsubscribe for free at any time.
If you currently receive marketing information from us which you would prefer not to receive in future, please email us at info@ptcma.org.za.
11. Contact Details
You may contact us with any queries relating to this privacy policy or the processing of your personal information. Please address your queries to:
- The Data Protection Officer
- PTCMA
- Attention: Janine Janse van Rensburg
- Email: janine@ptcma.org.za