INTELLICENTRICS UK LTD – PRIVACY POLICY

Introduction

Welcome to the IntelliCentrics UK Ltd’s privacy policy.

IntelliCentrics UK Ltd (“IntelliCentrics”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our SEC3URE online service (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

SEC3URE is an online service that allows SEC3URE’s members to be credentialed for purposes of providing them with access to healthcare providers’ hospitals in the course of discharging their role as Healthcare Industry Representatives, and allows SEC3URE’s healthcare provider members to screen and track members who access their hospitals in the course of discharging their role.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. [IMPORTANT INFORMATION AND WHO WE ARE]
  2. [THE DATA WE COLLECT ABOUT YOU]
  3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
  4. [HOW WE USE YOUR PERSONAL DATA]
  5. [DISCLOSURES OF YOUR PERSONAL DATA]
  6. [INTERNATIONAL TRANSFERS]
  7. [DATA SECURITY]
  8. [DATA RETENTION]
  9. [YOUR LEGAL RIGHTS]
  10. [GLOSSARY]

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how IntelliCentrics collects and processes your personal data through your use of SEC3URE, including any data you may provide through our website when you sign up to our newsletter or submit an enquiry.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

IntelliCentrics is made up of different legal entities. SEC3URE is the trading name of IntelliCentrics. This privacy policy is issued on behalf of the IntelliCentrics Group so when we mention "IntelliCentrics", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the IntelliCentrics Group responsible for processing your data.

IntelliCentrics (which is a subsidiary of IntelliCentrics Group) is the controller and responsible for the SEC3URE online service.

We have appointed a Data privacy officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data privacy officer in the following ways:

Full name of legal entity: IntelliCentrics UK Limited

Email address: info@intellicentrics.com

Postal address: Regent House, Heaton Lane, Stockport, SK4 1BS

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 us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in July 2019.

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.

Third-party links

This website 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 policy of every website you visit.

Please be aware that, whenever you voluntarily post public information to your profile or to the profile of others, that information can be accessed by healthcare provider members and other members only.

2. THE DATA WE 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 we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier (your SEC3URE ID), marital status, title, date of birth, name of employer, job title, professional qualifications, customer comments, a photograph and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Transaction Data includes internet protocol (IP) address, profile information, 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 this website.
  • Technical Data includes internet protocol (IP) address, profile information, 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 this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Special Categories of Personal Data includes information about your vaccination records.
  • Criminal Conviction Data which is limited to the DBS certificate only.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may only use Criminal Conviction Data where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations, you have uploaded the certificate to SEC3URE. provided your explicit consent to our processing such Data and provided we do so in line with this notice.

We will only collect Criminal Conviction Data if it is appropriate given the nature of the role. Where appropriate, we will collect Criminal Conviction Data if necessary, in the form of a DBS check. We will use Criminal Conviction data in the following ways only:

  • To inform the healthcare provider member to which you are allocated to of your compliance or non-compliance with the healthcare provider member’s Visitor Access Policy (as they are legally obliged to satisfy themselves visitors to their premises are DBS checked).

No personal data, Special Categories of Personal Data, or Criminal Conviction Data is shared with the healthcare provider member. The healthcare provider member is just notified of compliance/non-compliance.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

If you fail to provide personal data

You can change the personal data displayed on your profile at any time by contacting us.

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, or decline to give consent to such processing, we may not be able to perform the contract we have or are trying to enter into with you (for example, 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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.
    • apply for registration, or for a Global Passport with SEC3URE;
    • create an account on our website;
    • subscribe to our service;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will 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 Cookie Policy for further details.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU; and
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based inside the EU.

4. 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 we need to perform the contract we are about to enter into or have entered into with you.

  • 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 you have explicitly consented to us using your Special Categories of Personal Data and/or Criminal Conviction Data during the course of our relationship with you.

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data (other than Special Categories of Personal Data and Criminal Conviction Data) although we will get your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing, or to us processing your Special Categories of Data or Criminal Conviction Data at any time by contacting us at info@intellicentrics.com

Purposes for which we will 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 data Lawful basis for processing including basis of legitimate interest
  1. To register you as a new user and create your profile
  2. To authenticate you as a member
  3. To send your employer notifications relating to the services provided by us
  1. Identity
  2. Contact
  3. Special Categories of Personal Data
  1. Performance of a contract with you
  2. Explicit consent
To process and deliver our service, including:
  1. Displaying your personal information to SEC3URE’s healthcare provider members
  2. To facilitate interaction between and among Healthcare Industry Representative members and healthcare provider members on the SEC3URE web site
  3. To contact a Healthcare Industry Representative’s manager in respect of any member performance issues
  4. To ensure Healthcare Industry Representative members compliance with the healthcare provider member’s Visitor Access Policy in accordance with their legal obligations
  5. To facilitate searching and communication for and reviewing the profile members on the SEC3URE web site
  6. Manage payments, fees and charges
  7. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  6. Special Categories of Personal Data
  7. Criminal Conviction Data
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us) sent
  3. Necessary for the legitimate interests of our healthcare provider members to identify the Healthcare Industry Representative members and make informed decisions regarding their business partners, to manage the relationship with a Healthcare Industry Representative
  4. Explicit consent
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Notifying you when your account is due to expire via text message
  3. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated, to study how customers use our services, to ensure members can re-new their accounts before expiration)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  1. To make suggestions and recommendations to you about services that may be of interest to you
  2. (b) To send you member updates, newsletters or other news relating to our services
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
Necessary for our legitimate interests (to develop our services and grow our business)
Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Account notifications

We may use the mobile telephone number you have provided on your account to notify you that your account is due to expire in advance, or there has been a change in your account status.

Opting out

You can ask us or third parties to stop sending you marketing messages (including updates or notifications) at any time by contacting us at info@intellicentrics.com.

The subject line in any such email should read as follows: Do not send me any further notification emails. All notification emails and other SEC3URE communications will include the foregoing instructions for opting-out of those communications in the future.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

SEC3URE uses cookies to store the preferences and record the session information of visitors to its website for purposes of ensuring that visitors are not repeatedly offered the same advertisements and customising newsletter, advertising and web page content based on browser type and user profile information. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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 policy.

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.

6. INTERNATIONAL TRANSFERS

We may share your personal data within the IntelliCentrics Group when you consent to us doing so in applying and registering for a Global Passport with IntelliCentrics. This will involve transferring your data outside the European Economic Area (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:

  • When the transfer is necessary for us to perform our contract with you when you apply for a Global Passport. Such personal data is limited to your Identity and Contact Data.
  • 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.

7. 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 (such as SEC3URE‘s customer service personnel and technical staff). They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

SEC3URE member accounts are secured by member-created passwords. SEC3URE takes precautions to ensure that member account information is kept private. We have also 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. Please note however that SEC3URE cannot guarantee the security of member account information. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of member information at any time. For additional information about the security measures that SEC3URE uses, please contact SEC3URE.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your account data for a period of 6 years, other personal data will be retained 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 by contacting us. In some circumstances you can ask us to delete your data: see 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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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 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.

Time limit to respond

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.

10. GLOSSARY

LAWFUL BASIS

Explicit consent means a very clear and specific statement of consent. Explicit consent must be expressly confirmed in words, rather than by any other positive action. Once we have obtained your express consent, it means that we can process your Special Categories of Data that you choose to share with us. You can withdraw your consent at any time to us processing your Special Categories of Data by contacting us.

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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the IntelliCentrics Group and who are based in USA and Canada (as explained in Section 6) and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Healthcare Industry Representative members.
  • Healthcare provider members.
  • Service providers based in the UK who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
  • Legal authorities to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by SEC3URE, or as and when required by law.
YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that 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.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object 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, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • 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.
  • Request 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 us 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 it 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 use it.
  • Request the transfer of your personal data to you or to 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.
  • Withdraw consent at any time 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.