Skip to main content

The Savvy IMG

Will your internship be accepted for full GMC registration?

Table of Contents

Looking for a step-by-step guide?

Subscribe to the Savvy IMG and grab your FREE 2-year roadmap to UK residency as an IMG.

free

Looking for a step-by-step guide?

Subscribe to the Savvy IMG and grab your FREE 2-year roadmap to UK residency as an IMG.

free

The rules, guidelines and criteria for working as a doctor in the UK change frequently. Please make sure you check the latest official guidance before taking action.

An overview of the issue

If you are applying for full GMC registration through the PLAB route, you will need to provide evidence of internship.

Submitting your internship documents can often feel like presenting your case before a judge. The GMC’s judgement will affect your journey to the UK and can quickly put an end to your dreams if they do not rule in your favour.

Many IMGs face problems in the following areas relating to having their internship accepted:

  1. A gap between graduation and internship
  2. Gaps during internship
  3. Not having rotations in both medicine and surgery
  4. Internship of less than 12 months

In this article, we’ll review the GMC requirements and how these issues can be addressed.

Related: The 4 types of GMC registration

Can The Savvy IMG tell you if your internship will be accepted?

Unfortunately, no. Nobody can tell you 100% that your internship will be accepted.

For this reason, I am unable to answer any messages about whether your internship will be accepted.

Not even the GMC can provide any assurances, but you can contact them to discuss your situation. They can advise you of your options for full registration, but will not be able to give you a final decision. This can only be made once you submit your full application. This means completing all the requirements first including IELTS/OET, PLAB, certificate of good standing etc.

So, what should you do?

You will need to read this article in full and use your professional judgement. Any potential issues with your internship will need explanations and potentially documentation. These are often accepted by the GMC provided you have valid genuine reasons.

You may also find it helpful to post in one of the many IMG Facebook groups to see if anyone has had their internship accepted with a similar pattern to yours. However, bear in mind that this is not a guarantee that yours will be accepted. Every application is different and assessed on a case-by-case basis. You can find a list of relevant IMG groups here.

Ready to find out whether your internship is likely to be accepted?

Let’s review the criteria. The first set of criteria is known as Pattern A.

What are the requirements for Pattern A?

  1. Approved supervised training post – honorary posts, observerships, or clinical attachments are not accepted
  2. Minimum of 12 months duration – this relates to the calendar dates, there must be 12 months from the start date to the finish date
  3. Continuous and uninterrupted – meaning no gaps during internship
  4. Occurred either immediately before or immediately after graduation – meaning no gaps between graduation and start of internship
  5. If the internship was between 12-18 months, there must be at least 3 months in medicine and 3 months in surgery
  6. If the internship was longer than 18 months, there must be at least 6 months in medicine and 6 months in surgery

Those mentioned above are the official requirements however some leeway is permitted in the areas that IMGs have the most problems with.

Potential problems with Pattern A

1. You have a gap between graduation and internship

In general, the longer your gap between graduation and internship the more difficult it is to have it accepted. 

However, valid and genuine reasons for gaps with accompanying documentation tend to be accepted.

Cases that have been accepted in the past according to the experience of other IMGs include:

  • Maternity/paternity leave
  • Carer responsibilities (looking after children or sick family members)
  • Approved period of research
  • Approved period of additional training, education or other clinical experience outside of the internship programme
  • Problems involving the internship programme itself that led to an unavoidable gap outside of the doctor’s control
  • Preparing for exams (postgraduate exams, USMLE etc)

The most important thing in any case is that there is evidence surrounding any gap. Formally approved gaps must have supporting documentation.

2. You have gaps during internship

The GMC allows 5 weeks of annual leave for a 12 month period of internship plus an additional 20 days absence. It’s not stated what the additional 20 days absence can be for but acceptable reasons are probably things like sickness.

For any other prolonged absence you will be asked to provide evidence. Cases that have been accepted in the past according to the experience of several IMGs include:

  • Maternity/paternity leave
  • Carer responsibilities (looking after children or sick family members)
  • Approved period of research
  • Approved period of additional training, education or other clinical experience outside of the internship programme
  • Problems involving the internship programme itself that led to an unavoidable gap outside of the doctor’s control

Again, the most important thing in any case is that there is evidence surrounding any gap. Formally approved gaps must have supporting documentation.

3. You do not have rotations in both medicine and surgery

Your rotation does not need to be specifically labelled “internal/general medicine” or “general surgery”. Branches of internal medicine and branches of general surgery are accepted.

Fulfills the requirement for a rotation in medicine

Fulfills the requirement for a rotation in surgery

Cardiology, respiratory medicine, renal medicine, gastroenterology, neurology etc.

General surgery, orthopaedics, urology, plastic surgery, breast surgery, ENT etc.

If you do have rotations in both medicine and surgery but they are less than 3 months, the GMC accepts allied medical specialties for medicine and allied surgical specialties for surgery. These are the ones I am sure of:

Accepted as a medical rotation

Accepted as a surgical rotation

Paediatrics

Emergency medicine

Anaesthetics

ITU/ICU

Obstetrics and gynaecology

Ophthalmology

If any IMGs have experience of having anaesthetics or ITU/ICU accepted as surgical specialties since they do technically involve caring for surgical patients, please do let us know through our contact form so we can update this ASAP.

4. Your internship is less than 12 months

This is a difficult one because the GMC is clear that an internship should be of at least 12 months duration. I’m afraid I am unable to provide any further advice on this issue.

If any IMGs have experience of having their internship accepted even if it was less than 12 months, please do let us know through our contact form so we can update this article ASAP.

What if your internship doesn’t meet the Pattern A criteria?

All is not lost as none of these rules are set in stone. The GMC will review all your evidence and give you the opportunity to provide documentation relating to any issues before coming to a final decision. 

You can read the official GMC document that officers at the GMC use to evaluate internship and assess your own situation.

If your internship really does not fit Pattern A, there is a reason it’s called Pattern A – there is another pattern that can be used: Pattern B.

What are the requirements for Pattern B?

  1. Minimum of 24 months duration
  2. Continuous uninterrupted postgraduate experience – clinical attachments and observerships not accepted. Honorary (unpaid) posts wherein you are engaged in active medical practice may be accepted.
  3. Supervised post at a hospital – the hospital must be recognised as suitable for medical teaching and training, and must be regulated by the relevant government authority
  4. At least 3 continuous months in a medical specialty
  5. At least 3 continuous months in a surgical specialty

As with Pattern A, gaps may be accepted for similar reasons as listed above.

We contacted the GMC to clarify the issue of honorary posts. This is what they said:

“Honorary posts and clinical attachments generally consist of research or observing, and our guidance says: “The postgraduate medical experience has to have been undertaken in a public hospital that meets the standards for regulation within its jurisdiction and has established supervision, safety and governance systems in place.”

Therefore we would not normally expect honorary post evidence to be submitted under Pattern B. But, if you state that the honorary contract experience took place in a public hospital, you can submit it for assessment. Although, we couldn’t confirm whether it is acceptable until your application has been submitted and assessed.

We would not consider clinical attachments or observerships to include medical practice and they would not be considered for evidence in Pattern B.”

What if your experience does not fit either Pattern A or Pattern B?

If you apply for GMC registration without fitting either of the 2 patterns, there are 2 possibilities:   

  1. Your application is rejected and you need to apply for provisional registration instead of full registration.
  2. You will be referred to the Registration Investigation (RI) team who will examine your application in more detail.

If you are referred to the RI team you will be given the opportunity to provide evidence related to the questionable aspects of your application. You can also submit further evidence and a cover letter detailing why you have the up-to-date skills and knowledge to be granted full registration. The RI team can either accept this and grant you full registration, or reject this you’ll need to apply for provisional registration.

If the RI team does not grant you full registration you may be able to appeal and may even seek legal assistance. There are cases where full registration has been granted after a long appeals process and through solicitors.

What if your experience is rejected?

If your experience is not accepted then your application for full registration will be rejected. In this case there are 4 options:  

    1. Apply for provisional registration and FY1 (UK internship) through the UK Foundation Programme.
    2. Complete the requirements for Pattern B overseas then reapply for full registration.
    3. Obtain an accepted postgraduate qualification (PGQ) and reapply for full registration.
    4. Apply for full registration through the sponsorship route.

You can read more about each of these options in detail here.

What about gaps after internship?

Gaps after internship are rarely a barrier to GMC registration. However, if you have a long clinical gap, you may need to submit a statement and additional paperwork to show that you are clinically up-to-date.

Take home message

If your internship doesn’t fit the GMC requirements, it doesn’t mean that it will be automatically rejected. Genuine valid reasons with supporting evidence and documentation are usually accepted.

If you do not have a genuine valid reason for the issues in your internship or do not have suitable documentation, then your internship may be rejected. However this is not for certain, the GMC will decide once they receive your application in full.

I am unable to assess your internship and provide any assurances as to whether it will be accepted. I’ll need to refer any messages of this nature back to this article.

Further Reading

Find out the rest of the requirements for GMC registration here.

After GMC registration, what’s next? Find the steps for your specific pathway by taking this quiz.

You might also like

Looking for a step-by-step guide?

Subscribe to the Savvy IMG and grab your FREE 2-year roadmap to UK residency as an IMG.

free

Looking for a step-by-step guide?

Subscribe to the Savvy IMG and grab your FREE 2-year roadmap to UK residency as an IMG.

free

181 Responses

  1. hello,
    im going to apply for gmc registration through pattern A. My internship included
    Pediatrics 1 month
    Emergency unit of internal medicine 3 months
    General surgery 3 months
    Trauma and Ortho 2 months
    Obg gyne 2 months
    Dermatology 1 month

    Is this internship likely to get accepted by GMC?
    IS Emergency (A&E) considered as medicine rotation?
    Thanks

    1. Hi there, A&E can be considered as a medicine rotation since you said it’s the emergency unit of internal medicine. I don’t think there will be a problem. Good luck!

  2. Hi! As an intern doctor (which stands for FY1) in Turkey, I really need some guidance. I’m planning on dropping my rotation in thoracic surgery hence I’ll fail and graduate 1 month later than usual. I’m extremely worried that doing a 13 month internship rather than 12 month will cause me a huge problem on continuing from FY2 when I move to UK. I’ll provide the required surgery period when I graduate, just with a month prolonged graduation. I need an answer as soon as possible.

    1. Hi Ayse, 12 months is the minimum for internship, not the maximum. Some IMGs apply with 24 months internship, so the duration is not an issue. The issue is why you are graduating later than your peers. What’s the reason for dropping a rotation? That might need to be explained. As long as you can provide adequate explanation for everything it should not be a barrier. You may also find it useful to ask IMGs who have recent experience with that in one of the IMG Facebook groups. You can find the links to relevant Facebook groups here on our Useful Links page. https://thesavvyimg.co.uk/useful-links/ All the best!

  3. Excuse me Nick, Indian img from China here. Ive been informed my internship from China is not recognised unless it comes with a special letter that is impossible to obtain in my university. I’m already registered in india with 11 months of work experience, my question is would I be able to get full gmc registration if i were to complete postgraduation in india(3 years )while simultaneously doing any one of the member of royal College exams?

    1. Hi there, yes you can get full GMC reg by doing that. You can also use 12 months of work in India if it’s also considered an internship and fits Pattern A, or you can go with Pattern B after 24 months experience. All the best!

  4. Hello, thank you for your post. I did my overseas internship postgraduate and this meet all the criteria except by the following aspect >> I had more than 3 months in medicine but I wasn’t in any major surgery on theatre qx (unavailable), just only I was involved 3 months related to minor surgery tasks as wound cleansing, burning care, incision-drainage of small abscesses ( I don’t have the rest of fulfills for Surgical rotation). The 1st question is: if does minor surgery (as the examples I wrote) fit the criteria as Surgical rotation? Another thing is my certificate doesn’t specify nothing about what Rotations I did in my internship on the document. May this aspect affect the pattern A? In fact, immediately after completing my internship (for 12 months), I worked as general physician and emergency physician in different private centers for 4 years. May my work experience help to the acceptance of my internship? Thank you so much

    1. Hi Stephanie, I haven’t come across this type of surgical rotation as the only exposure to surgery during internship before so I’m not sure how the GMC will handle it. I would recommend contacting the GMC directly and asking IMGs who have recent experience with that in one of the IMG Facebook groups. If your internship is not accepted for Pattern A, then it’s possible you can use pattern B but you’ll need to work for 3 months in a surgical ward to meet the criteria. Hope it all works out!

  5. Hi , I’m a graduate from India finished my internship in 2019 , I had a gap of 6 months during my internship since I had to take care of my mom since she was unwell , I have 2 years experience in a public hospital and a primary health care center , 1 year each both in the govt sector , will my internship be accepted or will path b work out for me

Leave a Reply

Your email address will not be published. Required fields are marked *

Privacy Overview

This Privacy Policy sets out how we, The Savvy IMG, collect, store and use information about you when you use or interact with our website, thesavvyimg.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective 13th November 2019.

Contents

  • Summary
  • Our details
  • When you visit our website
  • When you use our website
  • Marketing communications
  • Information obtained from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Changes to our Privacy Policy
  • Children’s Privacy

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: The Savvy IMG
  • How we collect or obtain information about you: when you provide it to us e.g. by contacting us, registering, uploading and downloading from our website, completing registration forms, posting blogs, or signing up for content such as newsletters. From your use of our website, using cookies and occasionally, from third parties such as mailing list providers.
  • Information we collect: name, contact details, social media information, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), engagement history and transaction history.
  • How we use your information: for administrative and business purposes (particularly to contact you, to improve our business and website, to fulfil our contractual obligations, to advertise our and other’s goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.)
  • Disclosure of your information to third parties: user information can be shared with partners for specific types of content and events where a user has registered their information. Other disclosures are only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No, The Savvy IMG, does not sell data. However, when you register or sign up for certain types of content, your registration data can be shared with sponsors and partners. Examples of where we do this include event registrations, webinar signups or whitepaper downloads. We will always make it clear where any information provided will be shared with other parties.
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as marketing automation tracking on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy.
  • Transfers of your information outside the European Economic Area: By using our website, your information may be transferred outside of the European Economic Area. We take personal data seriously and as such we ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
  • Use of profiling: we use profiling to understand our users better through web and marketing analytics, provide targeted advertising and deliver a personalised user experience.
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not collect what is commonly referred to as ‘sensitive personal information’.

Our details

If you have any questions about this Privacy Policy, please contact the data controller.

The data controller in respect of our website is The Savvy IMG.

You can contact the data controller by sending an email to info@thesavvyimg.co.uk.

When you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website called BlueHost Inc. the privacy policy of which is available here: https://www.endurance.com/privacy/privacy

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser use.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using a cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookie policy.

When you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Enquiry forms

When you contact us using an enquiry form, we collect your personal details and match this to any information we hold about you on record. Typical personal information collected will include your name and contact details. We will also record the time, date and the specific form you completed.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Messages you send to us via our contact form may be stored outside the European Economic Area on our contact form provider’s servers.

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We record customer-facing phone calls for training and customer service purposes.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

When you use our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Social Media Tools

We have a wide range of social media tools to be able to use on our website. These tools include (but not limited to); Sharing, Likes, comments and submitting content both on and off our website. By using these tools, you are providing your consent to store and use the submitted data whether personal information or general information both on and off our website.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you give your consent to us storing and using submitted content using the steps described above.

We may also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Information you submit may be stored both inside and outside the European Economic Area on our servers as well as third-party servers such as Facebook.

For further information about the safeguards used when your information is transferred outside the European Economic Area.

Registering on our Website

When you register on our website or via teachable, we collect the following information; Your Name, Email.

If you do not provide the mandatory information required by the form, you will not be able to interact with our website or on Teachable.

You can view Teachable's privacy policy here https://teachable.com/privacy-policy

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to provide access to content, allows you to download content and facilitates the running and operation of our business.

We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.

Transfer and storage of your information

Information you submit to us via the registration form on our website may be stored outside the European Economic Area on our third-party hosting provider’s servers.

Marketing communications

Our content, goods and services

When signing up for content, registering on our website or making a payment, we will use the information you provide in order to contact you regarding related content, products and services.

We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

You can opt-out from receiving marketing communications at any time by emailing info@thesavvyimg.co.uk

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information on related business services, in order to assist your organisation, grow.

Third party goods and services

In addition to receiving information about our products and services, you can opt in to receiving marketing communications from us in relation third party goods and services by email by ticking a box indicating that you would like to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.

Information obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We can often receive information about you from third parties. The third parties from which we receive information about you can include partner events within the marketing industry and other organisations that we have a professional affiliation with.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one.

In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as marketing data services.

We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.

You can opt-out from receiving marketing communications at any time by emailing hello@thesavvyimg.co.uk

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information on related business services.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business

These include the following: Internet services, IT service providers and web developers.

Our third-party service providers are located both inside and outside of the European Economic Area.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 3 months.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 36 further month(s), after which point we will archive your information.

Newsletter: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe).

Membership: we retain the information you used to sign up for our memberships for as long as you remain subscribed (i.e. you do not unsubscribe).

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

    • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
    • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
    • whether we have any legal basis to continue to process your information (such as your consent);
    • how valuable your information is (both now and in the future);
    • any relevant agreed industry practices on how long information should be retained;
    • the levels of risk, cost and liability involved with us continuing to hold the information;
    • how hard it is to ensure that the information can be kept up to date and accurate; and
    • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers;

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information may be transferred and stored outside the European Economic Area (EEA) in the circumstances set out earlier in this policy.

We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to the data controller using the details provided at the top of this policy.

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

Further information on your rights in relation to your personal data as an individual

You can find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here:http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to the data controller using the details provided at the top of this policy.

  • to object to us using or processing your information where we use or process it in order
  • to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to info@thesavvyimg.co.uk, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

Our website does not allow you to register any ‘Sensitive Information’, however if we ask for this, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by contacting us by using the details at the top of this policy.