Pass Preparation Privacy Policy

Key points to note

We collect, store and use data which is necessary to provide you with the course you have booked, deal with anything relating to the financial transaction, process your exam result and obtain your feedback.
The data we collect is limited to the data which you input on your online booking, or that you add to your portal page, any additional information provided in written or electronic form voluntarily at a later date, and your financial booking details provided at the point of booking.
In booking onto one of our courses, you consent to us obtaining the data you provide (which is the data you input at point of booking and/or at any of our courses) and consent to us using that data as stated within the remainder of this policy. Therefore, our legal basis for obtaining and using your data as stated is the consent you provide. Another of our legal basis for obtaining this information is our legitimate interest in conducting and managing our business to enable us to give you the best service/product. Please see below in our 'glossary' section for what this means.
It is necessary for us to (securely) share the data we collect with third parties including LetstalkDr and Medical Protection. Your data which we hold will therefore also be subject to any privacy policy they hold, which you should read carefully before you agree to share your data with Pass Preparation.
Your data may be shared with select third parties for marketing purposes. Please email us at support@passpreparation.co.uk if you do not wish your data to be shared.
You have the right to request that your data is removed or edited at any time, however if this impacts on our ability to continue with your booking we will advise you of this. Please contact us via the contact form should you have any request in relation to your data.
More detailed information on the above is contained within the remainder of this document, which you are strongly advised to read in detail before continuing with your booking.

What is the purpose of this Privacy Policy?

Pass Preparation respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on we collect and process your personal data through:

your use of the website, including any data you may provide through the website when you make an enquiry or purchase a product or any course/programme;
your registration for, purchase of or use of any Pass Preparation products and/or Services;
your sending of personal data to Pass Preparation by any other means.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you. It is important that you read this Privacy Policy together with any other privacy policy 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 Policy supplements the other notices and is not intended to override them.

Who we are

The Data Controller for your Data is Pass Preparation. In some circumstances other Pass Preparation affiliated companies may carry out activities on its behalf. A number of other Permitted Users will be using your information if, for example, you book the Medical Protection discounted rate for the Pass Preparation course. The Permitted Users include Medical Protection and LetstalkDr and any other third party who we be engaged with contractually. References to 'we' or 'us' include such affiliates and Permitted Users.

Contact Details

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

FAO of the Data Protection Officer
support@passpreparation.co.uk

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);
We would, however, appreciate the chance to deal with your concerns before you approach the ICO (or other relevant authority) so please contact us in the first instance.

Online purchase of courses.

Credit or debit card details are used for processing payment only. We use Stripe for the processing of payments for courses received through this website.
When you place an order with us you will receive an automatic confirmation email. Your order represents an offer to us to purchase which is accepted upon completion of payment through the online automated system. You should receive immediate confirmation of this acceptance by way of a booking confirmation email. If you do not receive confirmation, please email support@passpreparation.co.uk.
While all reasonable care is taken to protect the confidentiality of your card and personal details, Pass Preparation cannot be held liable if, through no fault of our own, these details are intercepted and used by an unauthorised third party.
If you need to cancel a course booking, for whatever reason, you should first contact us by email at support@passpreparation.co.uk
Pass Preparation retain an overall discretion with respect to cancellation and refunds. In most cases Pass Preparation will provide a refund on cancelled course bookings up to 30 days before the start date of the course.
Customers have a right to withdraw from the purchase of a course and obtain a refund within 14 working days of the day of order subject to the following:
1. This right of withdrawal applies to courses which have been booked more than 30 days prior to the course date.
2. To cancel a purchase, you must inform Pass Preparation by way of a signed and scanned letter to be sent to support@passpreparation.co.uk.
3. We will refund the price paid within 14 days by the same method as used for payment, subject to a deduction for Stripe's handling fee.
Medical Protection discounts must be claimed at the time of booking. No retrospective discounts will be applied upon subsequently obtaining Medical Protection graduate membership.
All prices include VAT (where applicable). Unless otherwise stated there are no delivery charges.
Any purchase contract is in English and all communication between us must be in English. Nothing in this clause is intended to affect your statutory rights.

Course discount Terms and Conditions.

Only medical students with Medical Protection student membership will be entitled to activate the discount on the Passpreparation booking form. Any non-members activating the discount maybe asked to pay the difference following booking should they not hold Free Medical Protection student membership.
MPS reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, this offer with or without prior notice (including, without limitation, in the case of anticipated, suspected, or actual fraud).
The application of the discount shall be administered by PassPreparation and MPS shall not be liable for any failure to activate the discount including, for example, in the event of a technical issue, cyber- incident, data breach, or any other circumstances such as tampering, unauthorized intervention, fraud or failures.

Course material and online material

Neither the Lecturer nor Pass Preparation give any claims, promises, guarantees or warranties about the accuracy, completeness, timeliness or adequacy of any information, data, wording or graphics, whether written, oral or visual used in connection with this course (“Material”), other than as set out hereinbelow.
Pass Preparation guarantees that you will pass the exam related to the course(s) you have purchased (e.g., medicine finals course / medicine finals exam), contingent in course attendance and completion of mock test material. In the unlikely event of not passing you will be refunded your course fee. Please note carefully, this is not a guarantee that you will pass the exam, but a limited guarantee that if you do not pass, you will be refunded in full. If, for whatever reason, you fail the exam other than by reason of non-attendance, your entire course fee for that exam will be refunded. You will simply need to provide proof that you failed the exam, and a refund will be issued to the card used for booking.
All persons using the Material do so at their own risk. Neither Pass Preparation nor the Lecturer will be liable for loss or damage arising out of or in connection with the use of the Material. This exclusion of liability covers damages of any kind, including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property, claims for third parties and losses sustained while attending Pass Preparation events. Notwithstanding the foregoing, none of the exclusions and limitations are intended to limit any rights a delegate may have as a consumer or other statutory rights which may not be excluded nor in any way to exclude or limit Pass Preparation's or the Lecturer's liability to the delegate for death or personal injury resulting from Pass Preparation's or the Lecturer's negligence.
All Trade Marks, logos, brand names and service marks of Pass Preparation, whether registered or unregistered, remain the property of Pass Preparation, including the terms 'Pass Preparation', 'Pass Preparation Course', 'Pass Preparation Material', and any distinctive wording used by Pass Preparation in its online and printed material. Any use of these names or marks is prohibited without the express prior written consent of Pass Preparation.
The Material has been designed as an integral part of the course solely for the benefit of the delegates attending the course. No part of the Material may be reproduced or shared in any form or for any purposes without the prior permission of Pass Preparation. Any copyright in the Material remains the property of Pass Preparation and/or the Lecturer, as applicable.

Changes to the Privacy Policy and your duty to inform us of changes

On 25 May 2018 the data protection law in the UK and Channel Islands changed. This Privacy Policy sets out your rights under the new laws. 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. We may update this Privacy Policy from time to time. This version was last updated on 11 September 2023.

If you reject the terms of this Privacy Policy

If you do not agree to your personal data being used in accordance with this Privacy Policy, please do not submit your personal data to us through the Website or any other means.

Third-party links

The 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 policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

Your 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data includes billing address, delivery address, postal address, email address.
Eligibility Data includes education/academic history and / or future plans.
Financial Data includes bank account, billing information, payment card details
Identity Data includes first name, maiden name, last name, third party reference number, usernames or similar identifier title, date of birth and gender.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Profile Data includes your usernames and passwords for access to any of our online material.
Other Data includes the course or programme you purchase from Pass Preparation, your test results and any other information you may chose to provide beyond that which Pass Preparation requires.
Technical Data includes 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.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Usage Data includes information about your visit to a Website, including the Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time), products and/or services you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page and any phone number used to call our customer services numbers.

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 Policy.

How is your personal data collected?

We collect your personal data through our online form, or through input on exam papers.

This includes personal data you provide when you:

apply for a course;
submit an online query;
purchase goods or Services from us;

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 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.
Where we have your consent.

Where we are relying on your consent as a legal basis for processing your personal data, you may withdraw your consent to this processing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which legal basis 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 ground we are relying on to process your personal data where more than one ground has been set out in the table below. Please be aware that in the majority of cases we will have a contract in place with you in respect of the course or programme you are undertaking. Therefore, our lawful basis for processing your personal data will be to perform our contract with you.

Lawful Basis

Performance of a contract with you (A)
Consent (B)
Necessary for our legitimate interests of delivering course material, studying how persons use our website and course content and services to develop them and grow the business (C)
To comply with legal obligations (D)

Purpose / activity

to respond to queries or requests for information (A,B,C,D)
to register you for a course (A,B,C)
to deliver the course programme (A,B,C,D)
to manage your payment and/or deal with refund requests and/or to keep records for accounting purposes (A,B,C,D)
to defend any claims brought against Pass Preparation Limited (A,D)
to register you as a new customer (A,B,C)
to process your order (A,B,C)
to manage our relationship with you (A,B,C)
to enable you to participate in a survey or prize-draw (B,C)
to provide third parties with marketing data (B, C)
to administer and protect our website (C)
to deliver relevant website content (C)
to use data to improve our website content (C)

Type of data

The number of the activity / purpose that each type of data below may be used in relation to is as follows:

Contact - 1,2,3,4,5,6,7,8,9,10,11,12,13
Identity - 1,2,3,4,5,6,7,8,9,10,11,12,13
Profile - 1,2,3,4,5,6,7,8,9,10,11,12,13
Transaction - 1,2,3,4,5,6,7,8,9,10,11,12,13
Financial - 1,2,3,4,5,6,7,8,9,10,11,12,13
Marketing and communications - 1,2,3,5,6,7,8,9,10,11,12,13

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 or if you provided us with your details when you entered a competition or registered for a promotion 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.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing us via the consent form.

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

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.

Disclosures of your personal data

We may share your personal data with the parties set out below

External venues where some element of a course or programme (or event) is delivered (Pass Preparation may share Identity Data with the venue for registration and health and safety purposes).
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, including our customer database data. 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 Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

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. Your personal data may be held on by Pass Preparation on an encrypted laptop or secure server and/or on the IT system of another third party company which is providing IT hosting or other data processing services, in accordance with Pass Preparation's arrangement in place with that company. All information that you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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. We will not hold any data for longer than 7 years. Should you wish for your data to be deleted prior to the expiry of 7 years, please contact us via the contact form.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:-

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. Please be aware that this right does not apply to exam scripts or exam marks.
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. Please be aware that this right does not apply to exam scripts or exam marks.
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. Please be aware that this right does not apply to exam scripts or exam marks.
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. Please be aware that this right does not apply to exam scripts or exam marks.
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 services to you. We will advise you if this is the case at the time you withdraw your consent

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 30 working days. Occasionally it may take us longer than this 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.

Glossary

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.

Third parties

We are currently only engaged with Medical Protection and exam markers, and as such any reference to third party relates only to the same.