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OPEN Health Communications LLP (whose registered address is at C/O Corporation Service Company (UK) Limited, 25 Canada Square, 37th Floor, Canary Wharf, London E14 5LQ, United Kingdom and registered number OC360224) together with its subsidiary entities (details available here) operate in the healthcare and digital sector providing communications, market access, consultancy, public relations, meetings and events, medical education, data analytics, and health economic modelling services.
OPEN Health also conducts data processing activities on behalf of its clients who will be the data controller for such activities. Where OPEN Health is a data processor, we may only process personal data in accordance with the controller’s documented instructions as set out in a data processing agreement or contractual arrangements. We may only transfer personal data out of the EEA and appoint sub-processors as permitted by the data processing agreement. OPEN Health is also given data sets for the purposes of research in a pseudonymised format which means the data subject will not be identifiable to OPEN Health because we have no access to the code that will re-identify the data.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO; the UK regulator for data protection issues; www.ico.org.uk) if you are based in the UK. If you are based in Europe, you have the right to make a complaint at any time to the Dutch DPA, who we have nominated as our lead data-protection authority (https://autoriteitpersoonsgegevens.nl). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the Dutch DPA, so please contact us directly at firstname.lastname@example.org in the first instance.
We keep our privacy notice under regular review. This version was last updated on 22.03.2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We use different methods to collect data from and about you, which may not always be collected directly from you, including through:
Direct interactions. You may give us your identity data, contact data, and financial data by filling in forms or by corresponding with us by post, telephone, email, or otherwise. This includes personal data you provide when you do any of the following:
Third parties or publicly available sources. We may receive personal data about you indirectly, from various third parties and publicly available sources including those below:
Major Incidents and Health Emergencies As part of research studies conducted by OPEN Health on behalf of clients we collect from or are given pseudonymised patient data by a Healthcare Provider Organisations. In these cases the data is not collected directly from the patient (Data Subject). OPEN Health does not hold the re-identification criteria or “key” to this personal data. Therefore OPEN Health is unable to confirm to any data subject whether they hold their personal data or from which Healthcare Provider Organisation from which it came.
Healthcare Provider Organisations. As part of research studies conducted by OPEN Health on behalf of clients we collect from or are given pseudonymised patient data by a Healthcare Provider Organisations. In these cases the data is not collected directly from the patient (Data Subject). OPEN Health does not hold the re-identification criteria or “key” to this personal data. Therefore OPEN Health is unable to confirm to any data subject whether they hold their personal data or from which Healthcare Provider Organisation from which it came.
Therefore, without the ability to re-identify the data subject OPEN Health is unable to provide a data protection notice directly to any of the data subjects held in these pseudonymised patient records and, as required by GDPR Article 14 OPEN Health shall take appropriate measures to protect the data subject’s rights and freedoms in respect to the data it holds. In these cases the original data protection notice issued to the data subject by the data controller will apply.
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:
Personal data means data which relate to a living individual who can be identified from those data, or from those data and other information which is in our possession, or is likely to come into our possession, and includes any expression of opinion about an individual and any indication of our intentions or the intentions of any other person in respect of the individual.
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped examples of these together as follows:
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We have set out below 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 details below.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
You are a specialist and/or medical expert including healthcare professionals, healthcare advisors and opinion leaders in the healthcare sector (as well as devices and diagnostic), and research investigators.
To create and manage our relationship with you, including researching your credentials as a specialist in your area of expertise and making payments to you.
For 7 years following the end of our relationship with you unless we agree a different timeframe under contract with our client(s).
You are a site, partner or data collector working on behalf of a client or organisation.
To create and manage our relationship with you including:
For 8 years following the research project end.
You are a client or potential client (or an employee of the same).
For 6 years following the termination of our contract(s) with you unless otherwise specified in our contract(s) with you.
You are a supplier or potential supplier (or an employee of the same).
To create and manage our relationship with you including:
You are a journalist or freelancer working with us.
To create and manage our relationship with you including making payments and researching your credentials.
For the period of our agreement plus up to 7 years unless specified differently in our contracts.
You are taking part in a survey or formal research project as a research participant.
To facilitate your participation in the survey or formal research project.
As set out in our agreement with you but may include:
For a minimum period of 3 years unless otherwise specified in our agreement with you or specified by law.
You are a company director of our client, supplier, or potential client or supplier.
To create and manage our relationship with you.
Necessary for our legitimate business interests to perform any reasonable compliance checks and anti-bribery and anti-corruption checks as part of supplier due diligence.
You are browsing our website.
Necessary for our legitimate business interests to:
Your IP address is recorded by Google Analytics and stored in our web server logs at Rackspace hosting in the UK
Due to the fact that we cannot identify users by their IP address and for the security and performance of our web services, we keep such data indefinitely.
You register your request for us to send you information.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Marketing and communications
Necessary for our legitimate interests (to send you information requested, study how customers use our products/services, to develop them, to grow our business. and to inform our marketing strategy)
You are a visitor at our local offices and/or sites.
To protect the health and safety of all our staff and visitors.
Temperature (where necessary as set out above in relation to major incidents and health emergencies)
Necessary for our legitimate interests for the protection of public health.
You are a prospective employee seeking employment via prospective email or via an online application process.
To create and manage our relationship with you:
Educational & work history (e.g. within a CV)
6 months if you are unsuccessful in securing a role from the point interest was expressed
You are a patient participating in a non-clinical research study where you may not know your data is being used in this capacity
To conduct analysis and research for the purpose of reporting outcome findings to a healthcare provider organisation
Pseudonymous patient data (non-identifiable to Open Health, e.g. NHS HES Data)
Reports which will not include pseudonymous patient data are provided to:
6 For 8 years following the research project end
The website does not respond to the Do Not Track (DNT) setting configured on the user's web browser.
We will 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 we need to use your personal data for an unrelated purpose, if required, 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.
We may have to share your personal data with the third parties set out below as well as those set out in the table above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law:
By providing us with your personal data you agree that OPEN Health may share personal data, on a confidential basis, to third-party individuals and organisations that assist us, including contractors, financial service providers, web hosts, and others as set out in the table and list above
We may share your personal data within the OPEN Health Group. This may involve transferring your data outside the EEA or the UK.
Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded by implementing at least one of the following safeguards:
OPEN Health Group will implement further supplementary measures where possible and appropriate including technical, organisational, and contractual measures to augment the above-mentioned safeguards.
Post departure of the UK from the European Union, we will continue to take privacy of your data very seriously and manage your data according to the General Data Protection Regulations as they apply in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
We have put in place appropriate safeguards 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. If we share your personal data with our agents, contractors, and other third parties, we require they adhere to our Supplier Privacy and Security Requirements, which are available at www.openhealthgroup.com/legal.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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. We are required by law to keep basic information about our customers (including contact, identity, financial and transaction data) for at least 6 years after they cease being customers for legal and tax-reporting purposes.
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 (a subset of which is set out in the table Purposes for which we will use your personal data above).
In some circumstances we will anonymise your personal data or aggregate it (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.
Under certain circumstances, you have rights under data-protection laws in relation to your personal data. Where we have not collected the data directly from you, you have similar rights which may require you to communicate your request to the data controller from which OPEN Health received the data (OPEN Health would not have the ability to identify you should your data reside within a pseudonymised data set). You have the right to:
Please contact us if you would like to exercise any of these rights. You can do this by sending an email to email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We will not discriminate against you for exercising any of the above rights.
As required under the CCPA we have provided the metrics regarding the consumer rights requests we received from California residents from January 1, 2020 to December 31, 2020 in the following table:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are 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
For Californian residents: We will acknowledge receipt of your request within 10 days and begin the process of verifying your request. Depending upon the sensitivity of the data collected and the nature of your request, we are required to verify your identity by matching at least 2 pieces of personal information or, for more sensitive information, 3 pieces of personal information. If you use an authorized agent, we will require written evidence of the authorization and identity.
For all other residents making a request under GDPR: We try to respond to all legitimate requests within 1 month. Occasionally it may take us longer than 1 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.