DATA PRIVACY POLICY

AUGUST 2018

PH Medical Communications Ltd.

Background

This Privacy Policy sets out how and why PH Medical Communications Ltd. collects, uses and stores your personal data and our legal basis for its use, to ensure you remain informed and in control of your information. Please read this policy carefully to understand how PH Medical Communications Ltd. processes your personal data. If you have any questions about how PH Medical Communications Ltd. processes your information, please see the 'How to contact PH Medical Communications Ltd.’ section below.

Changes to this privacy policy

PH Medical Communications Ltd. may change this privacy policy from time to time by updating this page in order to reflect changes in the law and/or PH Medical Communications Ltd.’s structure and privacy practices. You are encouraged to check this privacy policy for changes whenever you visit the website www.phmedcomms.com.

How to contact PH Medical Communications Ltd.

PH Medical Communications Ltd. can be contacted at PH Medical Communications Ltd., St Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, UK, SG6 1PT.

Types of personal data collected

Personal data are defined as information from which an individual may be identified. The nature of the personal data collected about you will depend on the nature of your interaction with PH Medical Communications Ltd. and may include the following:

  • Your contact details, such as title, name, postal address, email address, mobile and/or landline telephone number
  • Your date of birth, age, gender
  • Your nationality
  • Your bank account details
  • Details of beneficiaries such as next of kin
  • A record of communications with you, such as telephone calls, WebEx's, emails or letters
  • Your participation in, or provision of services related to, programmes we have executed either as PH Medical Communications Ltd. or on behalf of its third-party clients
  • Remuneration, including honoraria/fees for service and expenses payment in relation to your participation in, and contribution to, programmes and services
  • Information obtained from yourself or third parties, including personal information and information about your academic and medical background, and clinical practice

Sources of your personal information

Most of the personal information PH Medical Communications Ltd. processes is provided directly by you, and by your administrative support staff. PH Medical Communications Ltd. may also obtain these data from its third-party clients on whose behalf it is performing services, and from public sources, such as journals, hospital department websites and other public websites.

Uses of your personal data

PH Medical Communications Ltd. and its partners, agents and suppliers use your personal data, including any of the personal information listed under ‘Types of personal data we collect’, for the following purposes, which include, but are not limited to:

  • Enabling you to take part in medical communication programmes executed either as PH Medical Communications Ltd. or on behalf of its third-party clients
  • Booking travel and providing other logistical support on your behalf when participating in, or providing services related to, medical communication programmes
  • Understanding how best to engage with you in the development, execution and follow up of medical communication programmes
  • Performance of market research and analysis either as PH Medical Communications Ltd. or on behalf of its third-party clients
  • Monitoring and keeping records of communications between you and PH Medical Communications Ltd. staff
  • Provision of insight and analysis of medical experts both for PH Medical Communications Ltd. and for the benefit of its third-party clients whom it supports to deliver medical communication programmes
  • Sharing of information, as needed, with business partners such as third-party clients and travel agents
  • Compliance to requirements stated in contracts between PH Medical Communications Ltd. and its third-party clients
  • Exercising or fulfilling the legal rights and responsibilities of PH Medical Communications Ltd.
  • Adherence to rules, guidance and best-practice guidelines issued by governmental and regulatory bodies
  • Compliance with legal and regulatory obligations, requirements and guidance

Legal bases for processing your personal information

PH Medical Communications Ltd. is required under law to ensure it has valid grounds for processing your data. The legal grounds that are most relevant to its use of your personal information are:

  • Legitimate interests
  • Consent
  • Contract

PH Medical Communications Ltd. may also be required to use your personal data to comply with its legal obligations.

Legitimate interests

This legal ground for processing includes, but is not limited to:

  • Working with you to deliver medical communication programmes on behalf of third-party clients and the clients require PH Medical Communications Ltd. to maintain records relating to your participation
  • Following the guidance and recommended best practice of government and regulatory bodies, including the reporting of honoraria, expenses and other benefits received on behalf of third-party client
  • Monitoring and keeping records of communications with you and PH Medical Communications Ltd. staff
  • Management and audit of PH Medical Communications Ltd. business operations
  • To administer good governance requirements of PH Medical Communications Ltd., such as internal reporting and compliance requirements

Contract

This legal ground for processing applies where the information is needed to work with you to deliver medical communication programmes and a Services/Consultancy Agreement has been executed between you and PH Medical Communications Ltd..

Consent

This legal ground for processing applies to, but is not limited to:

  • Some of the research and profiling that PH Medical Communications Ltd. performs for its own purposes or on behalf of its third-party clients
  • Your submission of personal data when registering on websites hosted by PH Medical Communications Ltd. or its suppliers

Withdrawal of your consent

Under circumstances in which PH Medical Communications Ltd. rely on your consent to process your personal data, you have the right to withdraw this at any time by contacting it using the details provided in ‘How to contact PH Medical Communications Ltd.’.

Sharing your personal data

PH Medical Communications Ltd. may share information with the following third parties for the purposes listed above, which include, but are not limited to:

  • Third-party clients of PH Medical Communications Ltd.
  • Suppliers and agents, such as travel agents
  • Regulatory organisations specific to the healthcare industry including, but not limited to, the Association of the British Pharmaceutical Industry (ABPI), the European Federation of Pharmaceutical Industries and Associations (EFPIA) and its other member organisations
  • Business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are a part of providing services or operating the business
  • Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme
  • Other organisations and businesses that provide services to PH Medical Communications Ltd., such as back-up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back-office functions

Data storage and transfer of your personal data

PH Medical Communications Ltd. is based in the UK. Data are stored in the UK and the USA, and may be transferred to other countries outside the European Economic Area. When your data are transferred, PH Medical Communications Ltd. will ensure that appropriate data protection safeguards are in place unless an exceptional circumstance arises.

If you require more information about these safeguards, please contact PH Medical Communications Ltd. at St Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, UK, SG6 1PT.

Retention of your personal data

PH Medical Communications Ltd. will not retain your personal information for longer than necessary and will delete it once it is no longer required for the purposes set out in the Policy. Whilst different periods apply for different types of data, the longest any individual’s personal data will normally be held for is for six years after completion of the last programme in which the individual participated, as required by third-party clients.

Your data protection rights

Presuming that these rights are not overridden by the legal obligations of PH Medical Communications Ltd., or where its legitimate interests are not overridden by your rights and interests as an individual, the following data protection rights apply to the personal data that PH Medical Communications Ltd. stores:

  • Right to be informed: you have the right to be told how your personal information is/will be used. This policy is intended to be a clear and transparent description of how your personal data may be used
  • Right of access: you can request a copy of the information held relating to you. PH Medical Communications Ltd. will normally comply with your request within 30 days once satisfied you have rights to view the requested records
  • Right of erasure (right to be forgotten): you have the right to have your personally identifiable data deleted
  • Right of rectification: if you believe the records that PH Medical Communications Ltd. keep are inaccurate, you have the right to ask for these to be updated.

If you wish to exercise any of the above rights, please contact PH Medical Communications Ltd. at St Christopher's House, Ridge Road, Letchworth Garden City, Hertfordshire, UK, SG6 1PT.

Complaints

If you are unhappy about the way your personal data has been processed by PH Medical Communications Ltd., you have the right to lodge a complaint with either PH Medical Communications Ltd. or directly with the ICO (Information Commissioner’s Office in the UK). Further information, including contact details, is available at https://ico.org.uk.