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EIDO Healthcare Ltd - General Privacy Notice

33 views May 2, 2019 May 3, 2019 eidosupport 0

  1. Important introductory information
    • Welcome to the general privacy notice of EIDO Healthcare Limited (EIDO). We keep this privacy notice under regular review. This version was last updated 1st May 2019.
    • EIDO respects your privacy and is committed to protecting your personal data. This privacy notice will: inform you how we look after any personal data that we collect from or about you; and, tell you about your privacy rights and how the law protects you.
    • If you are a medical professional who has provided us with personal data in connection with your use of any of our services please see Privacy Notice for users of EIDO products at https://support.eidosystems.com/documentation/eido-healthcare-ltd-privacy-notice-for-users-of-eido-products-publications-or-services/ for details of how we look after any personal data that we collect from or about you; and, your privacy rights and how the law protects you.
    • All personal data collected by us is collected in line with the requirements placed on us by any statutory laws or regulations applicable to us from time to time, including the Data Protection Act 2018 and General Data Protection Regulations ((EU) 2016/679) (GDPR).
    • Our products, services, publications and websites are not intended for children and we do not knowingly collect data relating to children.
    • It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
    • EIDO provides healthcare professionals with resources and support relating to informed consent. These resources help healthcare professionals reduce the risk of litigation, provide clear information to patients about medical and surgical procedures and improve the doctor-patient relationship. Our main products are Inform (a library of procedure-specific information documents for patients), Educate (an eLearning resource about informed consent for clinicians), Verify (a digital communication system that informs and surveys patients before and after a hospital procedure) and Vault (a digital solution for obtaining and recording patient consent).
    • You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact our Senior Information Risk Owner (using the contact details in paragraph 1.9 below) in the first instance.
    • The table below provides various information about EIDO, including details of how you can contact us, and our Senior Information Risk Owner (the person within EIDO responsible for overseeing compliance with data protection law).
Company name EIDO Healthcare Ltd
Registration number 4030383
Address 19-21 Main Street, Keyworth, Nottingham, NG12 5AA
Telephone 0115 8781000
Website www.eidohealthcare.com
Email dpa@eidohealthcare.com
Senior Information Risk Owner contact details Alistair Firth
alistair.firth@eidohealthcare.com
  1. Data we may collect about you
    • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    • We may collect, use, store and transfer different kinds of personal data about you which have been grouped together as follows:
      • Identity Data includes first name, last name, job title or similar identifier.
      • Contact Data includes postal address, email address and telephone numbers.
      • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.
      • Usage Data includes information about how you use our website, publications, products and services.
      • Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences, and information regarding your use of, and responses to, our marketing.
  1. How your personal data is collected
    • We may use different methods to collect data from and about you including through:

Direct interactions

  • You may give us your Identity Data, Contact Data and/or Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • submit an enquiry about our products/services;
    • subscribe to our newsletter or publications;
    • request a copy of our Annual Consent Review or another publication;
    • request marketing materials to be sent to you;
    • take part in a competition, survey or promotion;
    • give us your personal data at any event, meeting, exhibition we attend;
    • give us feedback or contact us regarding our products/services.

Automated technologies or interactions

  • As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at https://www.eidohealthcare.com for further details.

Third parties or publicly available sources

  • We may receive personal data about you from various third parties as set out below:
    • Technical Data from analytics providers, such as Google;
    • Identity Data and Contact Data from data brokers or aggregators such as Binley’s Medical Database based inside the EU.
    • Identity Data and Contact Data from publicly available sources, such as Linkedin, Companies House and the Electoral Register.
  1. How we use your personal data
    • We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      • Where we need to comply with a legal obligation.
      • Where you have given your consent.
  1. Purposes for which we’ll use your personal data
    • We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
    • Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 Purpose / Activity  Type of personal data  Lawful basis for processing (including where applicable basis of legitimate interest)
To process your request for a copy of our Annual Consent Review or other publications Identity Data

Contact Data

Necessary for our legitimate interests (to provide you with materials you have requested in order to promote our business)
To process and respond to your general enquiry Identity Data

Contact Data

Necessary for our legitimate interests (to respond to your enquiry and promote our business)
To send to you marketing material in relation to our products/services which may be of interest to you Identity Data

Contact Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and promote our business)

Consent

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy notice

Asking you to send us feedback or take a survey

Identity Data

Contact Data

Usage Data

Marketing and Communications Data

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Identity Data

Contact Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Identity Data

Contact Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and promote our business)
  1. Marketing
    • We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at dpa@eidohealthcare.com.
  2. Third-party marketing
    • We do not share your personal data with any organisation outside EIDO for marketing purposes.
  3. Change of purpose
    • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
    • If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
    • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  4. Disclosure
    • We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.
      • Other members of staff in the same group of companies as EIDO from time to time to ensure the efficient operation of each member of the group;
      • External third parties such as:
        • service providers acting as processors who provide IT and system administration services;
        • professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
        • HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
      • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
    • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
    • Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
  5. International transfers
    • Some of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
    • Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
    • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
  6. Data security
    • We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  7. Data retention period
    • We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
    • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
    • Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
    • In some circumstances you can ask us to delete your data: see your legal rights below for further information.
    • In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
  8. Your legal rights as a data subject
    • At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
      • Right of access – to your personal data (commonly known as a “data subject access request). This enables you to request a copy of the personal data that we hold about you and check that we are lawfully processing it.
      • Right of rectification – of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      • Right to be forgotten – This enables you, in certain circumstances, to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to restriction to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      • Right to restriction of processing – of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
        • If you want to establish the data’s accuracy.
        • Where our use of the data is unlawful but you do not want us to erase it.
        • Where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims.
        • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to us it.
      • Right of portability – of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      • Right to object (to processing) – of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      • Right to withdraw consent – where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    • Where your personal data has been disclosed to a third party (as stated in paragraph 9.1.2 above), any request received from you in connection with your rights set out above will also be shared with such relevant third party as required.
    • Should you require a “data subject access request form”, please contact us using the details set out in paragraph 1.9 above.
    • You will not have to pay a fee to access your personal data (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
    • We may need to request specific information from you to help us confirm your identity and ensure your rights to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    • We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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