Privacy Notice - SecurMedSecurMed

Privacy Notice

BACKGROUND:

SecurMed UK understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://securmed.org.uk and as described in Parts 5 and 6, below, we do not collect personal data on this website about you unless you contact us. Any personal data we do collect will only be used as permitted by law.

Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Notice, you must STOP using our Site immediately.

1. Information About Us
Our Site is owned and operated by SecurMed UK, a non-profit organisation set up to establish the UK Medicines Verification System for the UK, registered in England under company number 10276927.

Registered address: SecurMed UK, Wey House, Farnham Road, Guildford GU1 4YD
Data Protection Contact: Jerome Bertin, General Manager
Email address: info@securmed.org.uk
Telephone number: +44 20 3855 056

Postal address: SecurMed UK, PO Box 528, Twickenham TW1 9PT

2. What Does This Privacy Notice Cover?
This Privacy Notice applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children. Additionally, this Privacy Notice is not intended to apply to personal data collection during the recruitment.

3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights in certain circumstances,which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know.

  1. The right to access the personal data we hold about you.
  2. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  3. The right to be forgotten.
  4. The right to restrict (i.e. prevent) the processing of your personal data.
  5. The right to object to us using your personal data for a particular purpose or purposes.
  6. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling.  We do not use your personal data in this way.

To exercise your rights as outlined above, please contact us using the details provided in Part 10.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 10.

5. What Personal Data Do You Collect and How?
Subject to the following, we do not collect any personal data from you.

If you contact us or send us an email, we may collect your name, your email address, and any other information which you choose to give us.

Purposes for which we process your personal data The basis on which we can do this (this is what the law allows)
To register you on our Customer Relationship Management (CRM) system and to deal with any queries The processing is necessary
· To perform a contract with you; and
· For our legitimate interest in the provision of services to our contacts.
In order to perform our contractual obligations to you. This would include:
· processing and performing any bookings and order placed by you;
·  orders placed by us where you are a supplier;
· making or receiving payments, fees and charges; and
· collecting and recovering money owed.
The processing is necessary.
· To perform any contract entered into with you; and
· Our legitimate interest in recovering debts owed to us.
In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation. The processing is necessary for us to comply with the law.
In order to use your personal data in an official role which we have been designated to carry out by an official authority (e.g. the government or MHRA), or where we are otherwise carrying out tasks which are in the public interest (e.g which have been designated as such by government, or which would otherwise be deemed in the public interest) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In order to manage our relationship with you including:
· to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
· to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances); and
· to send you information you have requested;
· to deal with your enquiries; and
· to ask you to leave a review or feedback on us.
The processing is necessary.·
· To perform any contract entered into with you; and
· Our legitimate interest in recovering debts owed to us.
In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations. The processing is necessary:

· for our legitimate interest in provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; and
· necessary to comply with the law.

6. How Do You Use My Personal Data?
If we do collect any personal data (i.e. if you contact us), it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.

As stated above, we do not generally collect any personal data, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email.

7. How and Where Do You Store My Data?
It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area from time to time.

In connection with such transfers:

  • the relevant safeguard in place is the standard data protection contractual clauses between us and the recipient; or
  • this is made on the basis of an adequacy decision, including

(a) the Privacy Shield for transfers to the US; or
(b) the European Commission has decided that the relevant non-EU country ensures an adequate level of protection.

Personal data security is essential to us, and to protect personal data, we take the following measures:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

We will store your personal data for the time period, for long as we consider legally necessary or for as long as we need it for our business requirements.  We keep the length of time that we hold your personal data for under review.

8. Do You Share My Personal Data?
We may share your personal data with third parties for certain purposes.

Your personal data may be transferred to a third party including in the event of a re-organisation, dissolution or liquidation. Any such third may continue to use your personal data in the same way that we have used it, as specified in this Privacy Notice (i.e. to communicate with you).

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

In some cases, we share with third party data processors who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice as we use third party providers such as IT and outsource providers or contractors.

In some cases, we share with external professional advisers such as accountants, bankers, insurers, auditors and lawyers and the MHRA.

9. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@securmed.org.uk
Telephone number: +44 20 3855 0656
Postal Address: SecurMed UK, PO Box 528, Twickenham TW1 9PT

11. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Notice was last updated on 12 September 2018.