Privacy and GDPR policy

Background

SurePulse Medical Ltd 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 all of our staff, supplier, healthcare professional and customer personal data and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information about us

SurePulse Medical Ltd.

Private Limited Company [registered in England under company number 08112962].

Registered address: St Thomas House, Mansfield Road, Derby. DE1 3TN.

Main trading address: Medicity, D6 Thane Road, Nottingham, NG90 6BH.

VAT number: GB196 0252 05.

SurePulse Medical Ltd is registered with the Information Commissioner’s Office (ICO) – Reference ZA845036

For purposes of GDPR, the “data controller” is SurePulse Medical Ltd and Dr James Carpenter is the “Data Protection Officer.”

2. What does this notice cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) 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.

The personal data that we use is set out in Part 5, below.

4. What are my rights?

Under the GDPR, you have the following rights, 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, but you can always contact us to find out more or to ask any questions using the details in Part 11.
• The right to access the personal data we hold about you. Part 10 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• 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.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

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 (www.ico.org.uk)

5. What personal data do you collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business, Organisation or Institution name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• Information about communications between us;
• Information about commercial transactions between us including orders and delivery address(es)

We do not collect information from third-party organisations.

6. How do you use my personal data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Payroll, Expenses, Pension and Private Health administration
• Communicating with you. This may include responding to emails or calls from you.
• Supplying products and/or services to you or on your behalf. Your personal details are required in order for us to enter into a contract with you.
• Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us with your request to unsubscribe as set out in Part 11)

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with clinical research updates, information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How long will you keep my personal data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Staff personal data: We will retain your personal information for a number of purposes, as necessary to allow us to carry out our business. Your information will be kept for up to 7 years on our main systems after which time it will be deleted. Any retention of personal data will be done in compliance with legal and regulatory obligations and with industry standards. These data retention periods are subject to change without further notice as a result of changes to associated law or regulations. If you have any questions in relation to the retention of your personal data, please contact us using the details in Part 11.
• Suppliers: We will retain business and/or personal data in line with business needs. If you have any questions in relation to the retention of your personal data, please contact us using the details in Part 11.

Customers and Healthcare Professionals: The professional data that you have provided, and that we have collected from you, might include name, title, speciality, main hospitals, institutions, places of work, addresses, contact details, including work telephone numbers and work email addresses. We will also retain records of email and/or verbal communications between both parties. Any private contact details (eg private mobile phone or email addresses) will only be held with express permission. We will retain business and/or personal data in line with business and/or information exchange needs and will never forward such personal data to any third party without your express permission (subject to Part 9 below). If you have any questions in relation to the retention of your personal data, please contact us using the details in Part 11.

8. How and where do you store or transfer my personal data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.

Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield, and this is what we insist that any relevant suppliers register with. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission.

9. Do you share my personal data?

We share staff personal data with third parties for the provision of payroll, expenses, pension and private health provision. We may need to share relevant contact information with distributors or delivery companies in order to fulfil our contractual obligations in respect of product delivery and life-cycle management.  We will not share any of your personal data with any third parties for any other purposes, subject to one important exception.

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.

10. 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 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use on the company website. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

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 aim to respond to your subject access request within 2 weeks (and, in any case, not more than one month) of receiving it. Normally, we aim to provide a complete 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 that we receive your request. You will be kept fully informed of our progress.

11. 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@surepulsemedical.com.

Telephone number: 0333 5 771133.

Postal Address: SurePulse Medical Ltd. Medicity, D6 Thane Road, Nottingham, NG90 6BH.

12. 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 made available on the company website (www.surepulsemedical.com)