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Requirements for registration with the GMC

Get to grips with the fundamentals of coming to the UK as an international medical graduate with our comprehensive easy-to-understand guide. In this post we discuss the requirements you’ll need to register with the GMC including PLAB and IELTS.

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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.

Updated: January 17, 2023

The General Medical Council (GMC) is the medical authority in the UK. You need to be registered with the GMC and have a license to practise in order to work as a UK doctor. There are no exceptions.

The whole process of getting registered can be easy and quick, or difficult and long depending on how well you prepare your documents.

In this post I’ll walk you through all the requirements you’ll need to submit for GMC registration so your experience will be as smooth as possible.

The general requirements for GMC registration as an IMG are:

  1. Primary medical qualification and EPIC verification
  2. Proof of English proficiency
  3. Proof of clinical knowledge
  4. +/- Proof of an acceptable internship
  5. Record of activities from the last 5 years or since graduation from medical school
  6. +/- Certificate of good standing
  7. ID check

The exact combination of documents will be different for each doctor depending on individual circumstances but we go over the important requirements here.

1. Primary Medical Qualification (PMQ)

Your PMQ is your medical degree. The GMC will need to be satisfied that your PMQ is from a legitimate reputable university.

So is your university reputable according to the GMC? This is easy to check. It should be included on list A or B, and NOT on List C or D.

If your university is not on any of these lists, you should contact the GMC via email gmc@gmc-uk.org for further advice.

Your university can appear on more than one list:

  • If your school is on list C, even if it is also on list A, then I’m afraid this is the end of your journey until the GMC removes your school from list C. You can email the GMC, but the chances of acceptance are low.
  • If your school is on both list A and D, then you may still have a chance. Graduates from schools on the “grey-list” are assessed on a case-by-case basis. Again, it’s best to email the GMC for guidance.
Official website: 

ECFMG and EPIC verification

Once you’ve established that you have an acceptable PMQ, you will need to have your certificate or diploma verified by a GMC-trusted third party. That’s where the ECFMG and EPIC come in; they are US-based organisations specialising in verifying credentials.

The verification process can take time, so the earlier you do this the better. An ideal time to do this is between after you’ve taken PLAB 1.

The step-by-step instructions to do this can be found here:

Please take note that only your certificate needs to be verified. Transcripts do not need to be verified or submitted for GMC registration.

You can use your previous ECFMG certification for GMC registration. All you have to do is create an EPIC account then make a request to ECFMG to send the report to the GMC.

2. Proof of clinical knowledge and skills

On top of your PMQ with ECFMG certification, you will need to demonstrate that you reach the standard level of medical knowledge and skills expected of UK doctors who have just completed internship.

This can be achieved through 6 main routes.

  1.  PLAB
  2. Acceptable overseas registration exam
  3. Relevant European qualification (REQ)
  4. Acceptable postgraduate qualification
  5. Sponsorship
  6. CESR/CEGPR

1. PLAB (UKMLA from 2024)

PLAB stands for the Professional Linguistic and Assessments Board. The exam has 2 components: PLAB 1 which is a written test, and PLAB 2 which is a practical test.

PLAB is specifically for IMGs who qualify outside the EU. UK graduates and EU graduates do not need to sit PLAB.

Fortunately with the right preparation, PLAB is a very manageable exam and there are good pass rates which are increasing year on year.

Related: What you need to know about PLAB

2. Acceptable overseas registration exam

As of January 12, 2021, you may be exempt from PLAB if you have previously passed any of the following licensing exams:

  • USMLE (Step 1, Step 2 CK & Step 2 CS)
  • AMC (MCQ Examination & Clinical Examination) or
  • MCCQE (Part I & II in English)

This is only applicable if you passed the exams before a certain date:

    • USMLE: On or before 13 March 2020
    • AMC: On or before 5 March 2020
    • MCCQE:  On or before 27 October 2020

You must also have passed the exam in no more than four attempts. If you sat the exam more than four times before passing, you will not be eligible to use this route.

Also, if you have taken and failed PLAB part 1 or 2 after you passed one of the above exams, then you are not eligible for this route.

Read more about this on the GMC website here

3. Relevant European qualification (REQ)

As of January 1, 2021, IMGs who completed their Primary Medical Qualification (medical school) or are on the specialist register in the EU may be exempt from PLAB. This is now applicable even if you are not an EU national. EU nationals are no longer exempt from PLAB if they went to a medical school outside the EU. 

However, if your REQ is over 2 years old, you should be be able to show that you have been working since graduation. If you have not practiced for 60% of the time since graduation (or over the last five years, if you graduated more than five years ago) in a full time role, plus a minimum of 6 months in the last 12 months, then the GMC may require more information from you or they may require you to sit PLAB.

To check if you have a relevant European qualification, check this list on the GMC website.

4. Acceptable postgraduate qualification (PGQ)

The GMC has a list of postgraduate qualifications that they accept for full registration. This means you can bypass PLAB by having one of the qualification on the list.

This list includes UK postgraduate qualifications such as MRCP and MRCS, but also includes some overseas qualifications so it’s worth checking if yours is on the list. 

You can find the list here.

  • If you have a qualification on this list, then well done! You have already demonstrated your skills and knowledge for full registration. You do not need to take PLAB. All you need to do is have your certificate or diploma verified through ECFMG along with your PMQ.
  • If you have a qualification that is not on this list, you could potentially write to the UK medical Royal College of your specialty to ask whether they would consider your qualification as equivalent to theirs. If your qualification is accepted, then great. If not, you can either obtain a new qualification that is accepted, or you can sit PLAB, or you can obtain sponsorship (see below).
  • If do not have a qualification on this list, you could gain one by sitting the relevant exam eg. MRCP or MRCS, or you can sit PLAB, or you can gain sponsorship (see below).

Related: How to decide between PLAB and MRCP/MRCS

5. Sponsorship

It is possible to gain GMC registration without sitting PLAB or having an accepted PGQ. This is achieved through sponsorship. Some institutions provide sponsorship for GMC registration allowing you to bypass PLAB and PGQ. This is the list of GMC approved sponsors.

For more information about how you can gain sponsorship, please check the official websites and contact them directly. It’s always best to contact the sponsors directly for more information because rules change frequently.

Medical Training Initiative (MTI)

MTI is a type of sponsorship that allows doctors to work in the UK for a maximum of 2 years. Although your visa to work in the UK is only for 2 years, the GMC registration you gain is permanent and will not be revoked after 2 years.

MTI is a great option to gain GMC registration for those who do not plan to migrate to the UK permanently. If you’re interested in short-term training in the UK, you can read more about the options here.

Suggested: How to find cheap short-term accommodation in the UK

6. CESR (Article 14)/CEGPR

If you are already a specialist overseas, then you may be able to gain direct registration as a specialties and be recognised immediately as a UK Consultant. This involves compiling a set of documents demonstrating that you have the equivalent training and experience of a doctor who has completed specialty training (residency in the UK). This is known as the CESR route.

If you are already a practising general/family medicine practitioner, then again, you may be able to do the same and be immediately recognised as a UK GP. This is the CEGPR route

It is a tedious process, and usually unsuccessful for those who do not have any UK experience, but it is a possibility and some IMGs have succeed with this.

Please note that is not enough to submit a CV of your work history for a successful application. The GMC typically expects 800-1,000 pages of documents detailing your training and experience.

You can read more about it in this article:

3. English proficiency

There are different ways to prove to the GMC that you can communicate in English as a medical professional. Which evidence you use depends on whether you are taking the PLAB route or the PGQ/sponsorhip route.

PLAB route

There are 3 options:

1. IELTS Academic version

  • To pass you need an overall score of 7.5 and a minimum score of 7.0 in each of the different sections (reading, writing, listening, speaking) all in the same test.

2. OET Medicine

  • You’ll need to score at least a ‘B’ grade in all sections in the same test to pass GMC requirements.

Related: IELTS vs OET

3. Your PMQ

  • To use your PMQ as evidence of English it has to meet certain criteria:
    1. The PMQ was taught and examined solely in English, and
    2. At least 75% of your communication with patients, their relatives, and colleagues, was also in English.
  • You cannot use this route in any of the following circumstances:
    1. Your university is on this list.
    2. You have failed IELTS or OET in the past.
    3. Your medical school is not willing to produce a certificate confirming that they fulfil the English requirements.
    4.  It has been more than 2 years since you passed your final exam and you don’t meet the additional criteria (see below).
  • Even if you meet all the criteria, the GMC still holds the right to reject your PMQ as proof of English proficiency, particularly if you studied in a country where English is not the first and native language.

According to the GMC, you can prove you’ve maintained English skills if you’ve been employed or you’ve studied a postgraduate course in a country where English is the first and native language.

You’ll need to submit a reference from your employer, tutor or lecturer. The reference must cover at least three months full-time study or employment within the last two years. You can download the reference form and read more about it here.

If you can’t meet this requirement, then you need to retake IELTS or OET.

According to the GMC, you can prove you’ve maintained English skills if you’ve been employed in a country where English is the first and native language.

You will need references from all your employers for the past 2 years. You can download the reference form and read more about this here.

If you can’t meet this requirement, then you need to take IELTS or OET.

Ascension, Australia, Bermuda, British Antarctic Territory (BAT), British Indian Ocean Territory (BIOT), Canada, Falkland Islands, Gibralta, Guernsey, Guyana (formerly British Guiana), Ireland, Isle of Man, Jersey, New Zealand, Pitcairn, Singapore, South Africa, Sovereign Base Areas of Akrotiri and Dhekelia on Cyprus (CBA’s), South Georgia and the South Sandwich Islands, St Helena, Tristan da Cunha, United Kingdom, United States of America, US Virgin Islands.

Caribbean Islands: Antigua and Barbuda, Anguilla, Bahamas, Barbados, British Virgin Islands, Cayman Islands, Dominica, Grenada, Grenadines, Jamaica, Montserrat, St Kitts and Nevis, St Lucia, St Vincent, Trinidad and Tobago, Turks and Caicos Islands

Source

PGQ or Sponsorship route

There are 3 additional ways to prove your English proficiency if you are going through the PGQ route or the sponsorship route as long as you have not previously failed IELTS or OET.

  1. You’ve worked as a doctor in an English speaking country.
    • This is an option if your PMQ was not taught in English but you have worked as a doctor in a country where English is the first and native language for the past 2 years.
  2. You have a UK job offer.
    • If you already have a job offer in the UK and you have fulfilled your future employer’s own requirements for English then this is an option. However, most employers will require you to take an English test such as IELTS or OET.
  3. You passed an English test elsewhere.
    • You can use this option if you have passed the English test for registration in a country where English is the first and native language. So for example, you passed the test for registration in Australia. This has to be within the last 2 years.

4. Proof of internship or equivalent experience

Provisional registration

If you are applying for provisional registration, then you can skip the requirement for internship. Keep in mind that with provisional registration, you can only apply to a formal FY1 training post through the UK Foundation Programme. You will not be eligible for any other type of job as a doctor, not even a non-training FY1 position.

Related:

Full registration through the PLAB route

If you’re applying for full registration through the PLAB route, the GMC will want to verify that you have had clinical-based experience and training equivalent to the first year of the UK Foundation Programme AKA Foundation Year 1 or FY1.

This can done through one of 2 ways:

  1. An internship programme of at least 12 months duration or
  2. Continuous postgraduate medical practice for at least 2 straight years.

While postgraduate work should obviously have taken place after graduation, internship can be either in your final year of medical school or the year right after graduation.

Both types need to have taken place at a public hospital under supervision. That means if you worked as a doctor seeing patients on your own in a private clinic or doing home visits, then this will not count.

There are also requirements for how much time was spent in medical and surgical rotations.

 Formal internship (12-18 months long)Formal internship (longer than 18 months)2 years postgraduate medical practice
Minimum time in medicine 3 months6 months3 continuous months
Minimum time in surgery 3 months6 months3 continuous months

You will need a certificate or letter from the hospital you completed your internship or postgraduate experience at. The letter must contain the dates and specialties of all your clinical rotations.

Please read this article for more details about internship:

No. Clerkship refers to the clinical rotations undertaken during medical school. It is a basic GMC requirement of an acceptable medical degree (source). It is not considered the same as FY1 or internship.

FY1 prepares doctors for independent practise. At the end of it, doctors gain full registration. Clerkship or medical school clinical rotations do not result in full registration or a medical license.

The equivalent of FY1 is internship or a house job.

Be careful of labelling clerkship or clinical rotations as equivalent to FY1 in your CV or job application. You may be accused of inflating your experience which can turn into a serious probity issue with the GMC.

Full registration through the PGQ or Sponsorship route

In paragraph 6 of the GMC guidance for internship, it states that “applicants applying through the PGQ or Sponsorship routes are considered to have demonstrated the necessary experience for full registration.”

This means that your internship does not need to meet the same criteria as the PLAB route. If the GMC officer handling your case is giving you a hard time about internship even if you’re applying through the PGQ or Sponsorship route, do refer them to the guidance linked above.

5. Record of activity the past 5 years

The GMC want to know what you’ve been up to after your medical degree for the past 5 years only, or since you qualified from medical school if you qualified less than 5 years ago. You do not do provide a record of activities for anything more than 5 years ago. The sorts of activities you can include in your record are: medical work, non-medical work, clinical attachments, unemployment, maternity leave, study leave, vacation, and career breaks.

You only need employer references if you’ve done medical work without being registered, or any non-medical work.

Registration through the sponsorship route requires that you have been actively practising medicine in the last 5 years. You do not have to be continuously practising for the whole 5 years but you should have been active for 3 years in total, including the most recent 12 months. This is not a requirement if aim to gain GMC registration via PLAB or an acceptable postgraduate qualification such as MRCP, MRCS, MRCOG etc. 

6. Certificate of Good Standing

If you’ve been working as a doctor overseas anytime in the past 5 years, then the GMC expects that you are registered as a doctor with the relevant medical authority in order to legally practise medicine there. You will need to obtain a Certificate of Good Standing (CGS) from that medical authority. 

  • If you are registered or hold a license with more than one medical authority, you need a CGS from each and every one you’ve been registered with over the last 5 years. 
  • If you have been registered somewhere in the past but haven’t been registered with them for more than 5 years, then you don’t need a CGS from them.
  • If you are registered somewhere in the last 5 years but have never actually worked there, you still need a CGS.
  • If there is no medical authority where you’ve worked, you’ll need to contact the GMC for further advice.
  • If you have been working without any registration or official license to practise because it is not required to work as a doctor for any reason, you’ll need to contact the GMC about your situation for further advice.
  • If you are not registered with any medical authority because you have not yet worked as a doctor, then you do not need to submit a Certificate of Good Standing

Some countries have a medical council or medical board for every region; check which ones the GMC accepts certificates from in this database.

7. ID Check

Once your application is approved, you will have to come to the UK to have your passport verified for ID checks. 

For those going through the PLAB route, the ID can be checked on the day of the PLAB 2 exam to avoid an additional journey to the UK.

Deadlines

These tend to be strictly followed although sometimes the GMC may grant some leniency if you contact them directly. If you do not fall within the set time limits and the GMC does not grant any leniency, then you will have to repeat some of the steps so do make sure you adhere to rules!

  • Your registration must be approved within 2 years of passing any English test.
  • PLAB 1 must be taken within 2 years of passing an English test, but if you wait this long you will have to repeat the English test for GMC registration.
  • PLAB 2 must be taken within 2 years of passing PLAB 1.
  • Your application for either provisional or full registration must be approved within 2 years of passing PLAB 2.
  • Your application for full registration must be approved within 3 years of passing a postgraduate qualification, if it has been more than 3 years then you will need to show that you have been working and kept updated since then.

Take note that these time limits are for when your registration must be approved. This means you do not have up to 2 or 3 years to apply. If you apply too close to the time limit, your registration may not be approved in time.

  • Any references from employers are only valid for 3 months.
  • A Certificate of Good Standing is only valid for 3 months.

Once you submit all your documents to the GMC your application will stay open for 3 months. During that time the GMC may request for missing documents. Each time they ask you will have only 2 weeks to produce the missing paperwork. This is usually not enough time for a lot of things!

So make sure you give everything they ask for the first time. 

If your application is not approved within 3 months then you will have to submit a new application and you might even need to repeat some of the requirements as they might be outdated by then.

Summary

In conclusion, the requirements you need to submit depend on which route you take. Which route to take will depend on your level of experience and training, and your ideal career pathway. PLAB is certainly the easiest starting point for the majority of IMGs who are quite early on in their careers. It is also the most flexible in terms of job and training opportunities. 

Whatever you decide, I recommend creating an online GMC account as early as possible and start completing your requirements systematically. Once all requirements are complete, it’s time to hit submit!

Further resources

Find out what requirements you need for your individual circumstances with this GMC tool. I’ve completed the first 2 questions for you and you just need to complete the rest.

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.

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

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158 Responses

  1. Hi,

    I am a UK IMG. I have just gotten my MD. I transferred from one caribbean medical school to another before clinicals, to do Clinical rotations and electives within the UK. I wanted to join UKFPO. I have been totally devastated to find out that I am coming up short on some clock hours. My PMQ is currently unacceptable by the GMC. I was wondering how to proceed and what options I have to getting additional clock hours?

    Kind Regards

    1. Hi there, sorry to hear that, must have been a big shock. Unfortunately we are not familiar with this problem or how it can be dealt with. You may need to go back to your medical school and request further rotations to increase the hours. We recommend joining one of the IMG groups on FB to see if anyone has had recent experience with that and find out how it was handled. Relevant Facebook groups are listed on our Useful Links page. Best of luck, hope it works out!

  2. Hello!

    Im an argentinian doctor and I finished my general surgery training and plástic surgery speciality ( 2 especialities) in Argentina but I have been working as a general doctor (without speciality ) in Spain for the last 6 years,
    I have IRISH PASSPORT, so how this apply in my case. Do i have to consider myself as IMG who have to take the PLAB?
    Can I work as a general doctor whitout speciality to get a salary while prepare to get a surgical training in UK.
    Is it possible to get a surgery training after a long break? Beside that im 43 years old
    What would you think will be the best pathway in my case?
    Thank you very much for all the help you provide .

    1. Hi Cecelia!
      To answer your questions:
      1. You’re most likely exempt from PLAB. Please contact the GMC directly to confirm. However you will not be exempt from IELTS/OET.
      2. Generally no, all jobs are in a specific specialty. The most general job you could probably apply for is in an Urgent Care centre.
      3. It depends on what surgical specialty you want to pursue, some will deem you overqualified for training eg. General Surgery
      4. CESR-CP or CESR depending on eligibility.
      Please see our surgical guides here:
      https://thesavvyimg.co.uk/category/specialty-guides/

      Hope that helps. Best of luck!

  3. Hi, I have been trying to register for a GMC reference number via GMC online platform, but it keeps taking me back where it says “Find your route”.
    Kindly help pls

  4. Hi Nick,
    Do you know if Anatomy Demonstrator/Lecturer is considered as medical or non-medical work? I mean do I need to add an Employer Reference Form for it?

    1. Hi, since a lecturer is not seeing or managing patients it is considered non-medical as far as I know and you will need an Employer reference form. You can contact the GMC to confirm. Best of luck!

  5. Good day …
    This is me Dr. A/rahman , Sudanese living in Saudi Arabia , healthcare provider ( general & emergency ) medicine practitioner
    having the experience of more than ” 20 ” years career.
    I will be so glad if you guide me on how to get engaged or join the UK market for overseas GPs doctors…
    I am determined to make use of my vast experience in the UK.
    Is there fast tract way to join the UK-NHS as GP-ER practitioner activist ?
    Please to contact me on: +966 -538483878 or +966578825141 ( both on WhatsApp) and call….thanks

    1. Hi there, the requirements to work in the UK are essentially the same as anyone else. If you need further guidance, please see the RCGP website and contact them for advice on coming to the UK as a GP. Best of luck!

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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.