At MedSource, we are fully committed to protecting and respecting your privacy.
Please read this Privacy Notice, together with any other privacy notice that we may provide to you, as it contains important information about how we collect, manage, use and protect your personal data. This Privacy Notice may also be used in conjunction with other privacy notices that we may provide you with in certain situations. This privacy notice explains what personal data we collect from you and how we use it, and is intended to give you confidence in the privacy and security of your Personal Information when accessing the available pages on the MedSource website.
We may change this Privacy Notice from time to time. Please check this policy frequently to ensure you are aware of the most recent version and the date that it was last updated.
This policy was last updated in June, 2018.
If you have any questions regarding this policy or about our privacy practices, please contact us on the below details:
- E-mail: email@example.com
- Post: MedSource, Ford 8, Hoults Yard, Walker Road, Newcastle Upon Tyne, NE6 2HL, UK and marking your query for the attention of The Data Protection Officer.
Who are we?
The MedSource Group is made up of different legal entities, details of which can be found on our website, and which may be updated from time to time. When we say ‘MedSource’, ‘we’ or ‘us’ in this policy, we are referring to the relevant company in the MedSource Group responsible for processing your personal data.
MedSource is a “data controller” of the personal data that we hold about you. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
What information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. Personal information does not include information that is anonymized such that an individual cannot be identified.
We may collect, use, store and transfer different kinds of personal data about you.
We have grouped together the types of information that we may collect from you as follows:
- Identity Data including name, gender, date of birth, marital status, family members, occupation, professional registration number (if you are a health care professional);
- Contact Data including home address, business address, email address, phone numbers;
- Financial Data including bank account details;
- Transaction Data including details about payments to and from you;
- Technical Data including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Usage Data including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us;
- Communications Data including your preferences in receiving communications from us;
- Profile Data including your username and password, preferences, feedback and survey responses.
MedSource may collect data from vendors, contractors, employees and job applicants/candidates, clients, health care professionals (site staff and principal investigators) or patients (although information should be anonymized).
How do we collect your information?
- Information you give us. You may give us such information directly by registering with us, by participating in a clinical trial, completing forms, corresponding or speaking with us by phone, email, letter or otherwise, submitting a query, providing us with feedback about a product, visiting our website, requesting that we provide you with services / communications, or when we appoint you as a service provider.
- Information we collect about you. When you visit our website and receive e-mails from us we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this by using cookies.
- Information provided by cookies.
- Cookies are small files saved to the user’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows our website, through its server, to provide users with a tailored experience.
- If you wish to prevent the use and saving of cookies from this website on to your computer’s hard drive you should take necessary steps within web browser’s security settings to block all cookies from our website.
- Other cookies may be stored on your hard drive by external vendors when our website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer.
- If you would like further information about cookies and how they are used, you can visit http://www.allaboutcookies.org/.
- When we e-mail you, such e-mails may contain tracking facilities. Activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but is not restricted to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.
- Information we receive about you from other sources. We may receive information about you if you use any of the other websites we operate or the other services that we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We may receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.
We may take information from publically available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database or any professional registration database.
We may receive information about you if you apply for a vacancy at MedSource.
How we might use your information?
We use information held about you in the following ways:
- To manage and administer our relationship with you
- To conduct and support on clinical trials
- To carry out our obligations arising from any contracts entered into between you and us
- To respond to your requests
- To provide you with information about our activities or tailored information about a programme that you have signed up to
- To improve our level of service
- To notify you about changes to our service and notify you of new services
- To seek your views on our services
- To consider your application for employment
- For administrative and quality assurance purposes
- To ensure that content from our website is presented in the most effective manner for you and for your computer
- For the purposes of the establishment, exercise or defence of legal claims.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Communications with you
We may text or e-mail you to provide you with information about our activities and services supplied by us. You can un-subscribe at any time through an automated system. This process is detailed at the footer of each email. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will be detailed instead.
We may occasionally, with your consent, call you to provide you with information about our activities or provide you with information about products and services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting us at any time on the details set out in the ‘Contact Us’ section of this notice.
We may also communicate with your through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our services, products and other activities and those of other carefully selected organisations. You have the right to contact us at any time and opt-out of receiving postal communications.
What is our legal basis for using your information?
There are a number of lawful reasons for us to process your personal data.
One of these is called ‘legitimate interest’ and means that we can process your personal data if (i) we have a genuine and legitimate reason; and (ii) are not harming any of your rights and interests.
Our aim is to deliver and support the delivery of high-quality clinical trials.
We will use your personal data in order to help us achieve this goal and to give you the most appropriate information and services and to provide you with the best experience when dealing with us.
Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
Other legal bases that we will rely on include the following:
- If you purchase a product or service from us, we may process your personal data in order to fulfil our contract with you.
- If we are providing you with e-mail communications, we will only do so with your consent, unless you have purchased services from us, in which case we may rely on our legitimate interests to contact you further. You can ask us not to send such e-mail communications with you at any time by using the details below in the ‘Contact Us’ section.
- Where we are required to comply with our legal obligations, or to establish and defend our legal rights, or to prevent and detect crimes such as fraud.
How long will we hold your information for?
We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements.
By law, we are required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will 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 are processing your personal data and whether we can achieve those purposes through other means.
Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for.
We review our retention periods for personal data on a regular basis.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
Who we might share your information with?
We will NOT sell your personal data to any third parties.
We may share your personal information with any member of our group where we have a legal basis for doing so.
We may share your information with selected third parties including agents, contractors or partners of MedSource in connection with services that these individuals or entities perform for, or with MedSource. These agents, contractors or partners are restricted from using this information in any way other that to provide services for MedSource, or service for the collaboration in which they and MedSource are engaged.
International transfers of personal data
As MedSource is an international enterprise that consists of numerous entities worldwide, the data that we collect from you may be transferred to, and stored at, a destination outside the European Union (“EU”) for the purposes described in this policy. It may also be processed by staff operating outside the EU who work for us or for one of our suppliers.
Data may be transferred to and hosted by a third-party IT service provider in the countries outside of the EU for the purposes of carrying out normal business practices. We may also share your data with other selected unaffiliated service providers or consultants acting on our behalf, such as external marketing agencies, speciality advisory services or lawyers.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with your or if you wish to participate in a programme and you fail to provide that data when requested, we may not be able to perform the contract we have with you or permit you to participate in the programme. If this is the case, we will notify you at the time.
You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you exercise any of these rights we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.
You also have the right to lodge a complaint with the local data protection regulator in your country. In the UK, this is the Information Commissioner’s Office. If you have concerns about how we use your personal information you can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/.
Your rights include:
- Transparency over how we use you data and to make a subject access request (right of access);
- A right to have your personal data updated and corrected (right of correction/rectifcation) ;
- A right to ask us to delete your information (right to be forgotten);
- A right to ask us to stop processing your information (right to restriction);
- A right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object);
- A right to receive a copy of your information, or have this sent to a third party (right to data portability); and
- A right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation).
If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr).
How you can access and update your information?
We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important that the personal information we hold about you is accurate and current.
Security precautions in place to protect against the loss, misuse or alteration of your information
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Details of these measures can be obtained on request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our security measures are regularly reviewed.
If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at:
- E-mail: firstname.lastname@example.org
- Post: MedSource, Ford 8, Hoults Yard, Walker Road, Newcastle Upon Tyne, NE6 2HL, UK and marking your query for the attention of The Data Protection Officer