1. Who we are
The World Federation of Occupational Therapists (WFOT) is the official representative of occupational therapy and occupational therapists worldwide. Founded in April 1952, the WFOT was recognised as a Non-Government Organisation (NGO) by the United Nations in 1959. WFOT allows members to be actively engaged in promoting the development and growth of the profession around the world and actively pursues the maintenance of professional standards, particularly those relating to undergraduate education. This is in partnership with each country’s national occupational therapy body, who contribute as member organisations to the direction, effort and success of the World Federation. You can find out more about WFOT at https://wfot.org/about/history.
2. Our Responsibilities
WFOT owns and operates wfot.org, otion.wfot.org, learning.wfot.org , occupational-narratives.wfot.org, and bulletin.wfot.org (the ‘websites’ or ‘website’). These have been setup to provide members and the public information and services.
As referred to in the EU General Data Protection Regulation 2016/679 (GDPR) and UK GDPR, WFOT (“we”, “us” or “our”) acts as the data controller for the websites and membership information supplied from the occupational therapy national association of each member country.
WFOT acts in this position because WFOT:
- Determines which personal data must be processed for the correct execution of the services it provides;
- Determines for which other purposes the personal data may be processed as long as these purposes are in accordance with the purpose for which the personal data were obtained by WFOT;
- Must comply with legal obligations; and
- Has developed general terms and conditions that are directly applicable to the customers and the members.
This privacy policy covers all the information provided on the websites and what to expect us to do with your personal information when you contact us or use one of our services.
3. Information We Collect And How We Use It
To provide information and services to you, WFOT will collect and process personal information provided by you for the following purposes:
Becoming a Member of WFOT
If you decide to join WFOT, you will provide your personal information to your national association along with a payment, or this will be included as part of joining your national association. The national association securely transfers the information required by WFOT to set up your membership. This transfer is necessary to carry out your request to become a member of WFOT and forms an agreement between you and WFOT. For EU data protection law our lawful basis for processing data for this purpose is Article 6, (1)(b) processing is necessary for the performance of a contract to which the data subject is party.
Sale of, and access to, goods and services
WFOT also process personal data to execute the sales of goods and services. This includes the sale of goods through https://wfot.org. To carry out your requests for these goods and services we must process the personal information you provide. For EU data protection law our lawful basis for processing data for this purpose is Article 6, (1)(b) processing is necessary for the performance of a contract to which the data subject is party.
Access and participation in WFOT initiatives and resources
To fulfil your request to access and participate in WFOT initiatives and resources you enter into an agreement with WFOT and we capture and process a set of personal information provided by you. Such initiatives and resources include WFOT online forums, courses, surveys and forms. For EU data protection law our lawful basis for processing personal data for this purpose is Article 6, (1)(b) processing is necessary for the performance of a contract to which the data subject is party.
To send members a newsletter and marketing information
If you decide to sign up and consent to our newsletter you provide a set of personal information so we can add you to our mailing list. By signing up you consent to us sending you a newsletter and relevant marketing information. For EU data protection law our lawful basis for processing personal data for this purpose is consent under Article 6, (1)(a), consent you have the right to withdraw at any time, without affecting the lawfulness of processing based on consent carried out before its withdrawal;
Further examples of the uses made of your information
We may also record the IP address used when you use our services. This to ensure that activity is legitimately created by a human and not by a script/computer.
You may also be asked to disclose personal information to us so that we can provide assistance and information to you. Such data is used to provide online technical support and troubleshooting.
If you use our websites, the following personal data may be processed (also depending on your acceptance of cookies):
- Your Internet protocol address;
- The kind of browser or computer you use;
- Number of links you click within the site;
- City or country from which you accessed the site;
- Date and time of your visit;
- Name of your Internet service provider;
- Web page you linked to our site from;
- Pages you viewed on the site;
This is statistical data about our users' browsing actions and patterns which allows us to ensure that content from our site is presented in the most effective manner for you and for your computer.
For those of these data which do not fall under the consent to cookies (cf. §9), for EU data protection law our lawful basis for processing personal data for this purpose is our legitimate interest under Article 6, (1)(f), processing is necessary for the purposes of the legitimate interests pursued by the controller.
4. Do We Process Sensitive Personal Data?
WFOT’s websites, services and products are not aimed at activities that require special categories of personal data to be processed. WFOT therefore requests that you do not provide any of such information. Furthermore, WFOT has no intentions of collecting personal data about website users who are minors, even if they have permission from their parents or guardians. Unfortunately, WFOT cannot check whether a website user is a minor and therefore WFOT advises parents or guardians to be involved in their children’s online activities in order to prevent minors’ data from being processed by WFOT.
5. How Long Do We Keep Your Personal Data?
When you use WFOT services your information is stored securely on our servers for as long as we have a business need for it.
WFOT will not retain your personal data longer than the mandatory statutory period or, if such a mandatory statutory period does not apply, no longer than is strictly necessary for the realisation of the purposes for which your personal data were obtained.
6. How Do We Secure Your Personal Data?
The protection of your personal data is of utmost importance to WFOT. To ensure the security of your data and compliance with applicable laws and regulations, we have implemented a range of technical and organisational security measures.
Our technical measures include network segmentation to control access and limit potential exposure, and the use of firewalls and anti-DDoS systems to safeguard against unauthorised access and cyber-attacks. We adhere to industry best practices for encryption and system configuration.
We also utilise strong authentication methods to ensure only authorised personnel can access sensitive data. All data transfers are encrypted to prevent interception and unauthorised access, and continuous monitoring and alerting mechanisms are in place to detect and respond to potential security incidents. Furthermore, website traffic is encrypted using HTTPS, providing secure communication between your browser and our servers.
On the organisational side, we implement role separation to minimise the risk of unauthorised access or changes by dividing duties among different personnel. We follow least-privilege principles, ensuring access rights are assigned based on the minimum necessary privileges required to perform job functions. Personnel who have access to sensitive data undergo thorough screening, and we maintain strict procedures for managing adjustments, incidents, vulnerabilities, and suppliers. Continuous training of our staff is conducted to keep them updated on the latest security practices and threats. The functionality and effectiveness of our security measures are tested periodically to ensure the ongoing protection of your personal data.
7. Who We Share Your Data With
To provide you goods and services, WFOT works with a range of suppliers. These third parties operate under contract with WFOT and we will share your information with these parties where it is necessary to deliver the goods and services you have requested.
These suppliers are data processors under data protection law and can only process your information in line with the instructions we provide in their contract. These include specific clauses to protect your personal information. They will not share your personal information with any organisations apart from us. They will hold it securely and retain it for the period we instruct.
WFOT ensures that your personal data are always processed in a careful manner, protected with at least the same level of security we maintain for the confidentiality of your personal data. WFOT nevertheless remains fully responsible for these processing operations and will therefore take all reasonable administrative, technical and physical measures to protect your personal data against unauthorised access, unintentional loss or alteration.
We will not share your information with any third parties for the purposes of direct marketing.
In some circumstances we are legally obliged to share information. This would relate to regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure.
8. Where We Store Your Personal Data
When providing our services, your personal data may in some cases be processed by third parties (as processor or independent controller) outside the European Economic Area (EEA) or UK. If your personal data is processed outside the EEA or UK, in a third country (a country without an adequate level of protection as indicated by the European Commission), WFOT ensures that:
(i.) the correct contract is concluded with regard to data processing (processor agreement or controller-controller provisions if desired), and
(ii.) an appropriate transfer mechanism is in place, such as EU Standard Contract Clauses.
Our suppliers providing data storage services undergo regular audits of their facilities to ensure their information security complies with international standards and meets our contractual requirements.
In this way WFOT ensures that your personal data is always secured to at least the same level for the confidentiality of your personal data to be guaranteed.
If you want to find out more about how your information is stored and who is involved, please get in touch using the contact details provided in this policy.
9. Do We Use Cookies?
We may use cookies to personalize or enhance your user experience. In particular, we use PostHog cookies for the purposes of managing the performance and design of the site. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.
We use the following cookies:
With the exception of strictly necessary cookies, you can accept or decline cookies simply clicking the appropriate selection of the cookie banner or come back on your choice by clicking on the cookie settings icon displayed left downside your screen.
10. What Are Your Rights?
Unless WFOT cannot execute these rights based on a legal obligation or whenever exceptions apply, you may request to exercise your rights to:
Access by data subject
You have the right to access information we hold about you. Your right of access can be exercised in accordance with the General Data Protection Regulation (GDPR) or applicable data protection law.
Data Rectification/Erasure
You have the right to have your data rectified if you believe it is inaccurate and/or erased if you believe it is no longer necessary for us to process your data or you have withdrawn your consent (where consent was given to process data in the first place).
Data portability
You can request access to your data, and for the data to be provided to you in an accessible format (e.g. in a word processing document or spreadsheet) at any point.
Object
You have the right to object to your data being processed by us and can request that it is no longer processed.
Restriction of processing
You have the right to obtain from us restriction of processing in accordance with the General Data Protection Regulation (GDPR) or applicable data protection.
You can send your request to exercise your privacy right(s) to [email protected].
WFOT prefers to establish that this request originates from you and that you are who you say you are. If we are not capable of verifying it is you directly, WFOT may ask you to provide additional information, such as a copy of your identification (i.e. a passport or identity card). Please make sure that in this copy your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) have been redacted to protect your privacy.
WFOT will then respond to your request as soon as possible, but in any case within one month after receipt, unless the request is of such excessive nature that we may extend that period with another two months.
11. Changes To This Statement
WFOT has the discretion to update this privacy statement at any time. We will make a good faith effort to notify the public of any changes. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy statement and any updates.
This document was last updated 30/04/2024.
12. Contacting Us
If you have questions, comments, and requests regarding this privacy policy, we are contactable by post and email using the information below:
World Federation of Occupational Therapists
PO Box 53187
London
United Kingdom
E18 9DF
Email: [email protected]
13. Report A Concern
If you believe that WFOT has used your personal data unlawfully or if you are not satisfied with WFOT’s response to your question or request, you have the right to file a complaint with the relevant Data Protection Authority (in the UK, this is the ICO). More information about your complaint possibilities can be found here. For contact details of all EU Data Protection Authorities, click here.
14. Our Data Protection Officer
WFOT has appointed a Data Protection Officer (DPO). Among other things, the DPO is responsible for supervising the processing of personal data by WFOT, taking stock of data processing and advising and training our employees on the responsible use of personal data.
If, in spite of the above, you suspect that your data is not properly handled, secured, has been misused or if you believe that WFOT does not adequately process your personal data, please reach out to our DPO via [email protected].