Last reviewed May 2022
1. Introduction
2. License to use website
3. Acceptable Use
4. User Content
5. No Warranties
6. Links to Other Websites and Third Party Content
7. Limitations of Liability
8. Exceptions
9. Reasonableness
10. Indemnity
11. Breaches of these terms of use
12. Variation
13. Assignment
14. Severability
15. Which country's laws apply to any disputes?
16. Entire Agreement
Last reviewed May 2022
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Pi Healthcare Limited collects and processes your personal data, however you provide it to us. This notice also sets out how we deal with the personal data of third party stakeholders and key opinion leaders (“Third Party Personal Data”) that we may provide to our clients as part of our services.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Controller
Pi Healthcare Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Email address: privacy@pi-healthcare.com
Postal address: Wells Road Business Centre, Ilkley, West Yorkshire LS29 9JB
We also operate the website at www.pi-healthcare.com.
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 notice and your duty to inform us of changes
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 reserve the right to make changes to this privacy notice at any time.
2. The personal data we collect
Your Personal Data
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 follows:
Transaction Data includes details of services you have purchased or otherwise received from us.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Please also note that we do not knowingly collect data relating to children.
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 you or to provide you with services you have requested, and you fail to provide that data when requested, we may not be able to perform the contract we have or to provide you with the services you have requested from us. In this case, we may have to cancel the contract in question that you have with us but we will notify you if this is the case at the time.
Third Party Personal Data
Third Party Personal Data we collect includes Contact Data and Identity Data as described above (but in this context including job title/role, photographs (published by the data subject or on his/her behalf), and details of professional engagements and affiliations).
3. How do we collect personal data?
Your Personal Data
We use different methods to collect data from and about you including through:
Third Party Personal Data
We only collect Third Party Personal Data from publicly available sources on the internet. Generally, this data is made available on the internet by the data subjects (i.e. the individuals) themselves, or by organisations with which they are involved (including their employer) on their behalf, in order to promote their clinical expertise. We collect this data from the internet (or ask third parties (who may be located outside of the European Economic Area) to do so on our behalf), consider it, and provide our clients with our advice upon it.
4. How we use personal data
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:
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.
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.
Third Party Personal Data
We process the Third Party Personal Data that we collect on the lawful basis that it is necessary for our legitimate business interests. Our processing of Third Party Personal Data is fundamental to the services that we provide. Furthermore, we believe that the Third Party Personal Data we provide to our clients is also necessary for our clients’ own legitimate business interests in identifying the relevant stakeholders and key opinion leaders (“KOLs”) with whom they need to engage to develop their own products and services. Those KOLs make information about their clinical excellence publicly available in order that (amongst other reasons) those in the pharmaceutical and other clinical industries (including our clients) can identify them as KOLs and can engage with them.
Marketing
If we send you marketing communications, you can ask us to stop sending them at any time by following the opt-out links on any marketing communication sent to you or by contacting us at any time.
Where you opt out of receiving these marketing communications, this will not apply to personal data that we process and use on a different lawful basis.
We will not share your personal data with any third party for marketing purposes.
Our Website - Cookies
We use cookies on our website and on our online subscription portal, but they do not collect personal data. 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 our website may become inaccessible or not function properly.
Our Website - Third-party links
Our 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 notice of every website you visit.
Suppliers
If you are a supplier to us, you will be asked to supply certain personal data to us and we will process that personal data for the purposes of the contract that you and we enter into for the supply of your products/services.
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 personal data
Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
Third Party Personal Data
We share Third Party Personal Data with our clients (acting as joint controllers), for the purposes of providing our services to them. This data is provided in a number of different forms including through a secure online subscription portal. We may also provide Third Party Personal Data to those third parties mentioned above.
6. International transfers
Third Party Personal Data
We share Third Party Personal Data with our clients for the purpose of providing our services to them. Occasionally this may involve a transfer of that personal data outside the European Economic Area (EEA). Whenever we transfer personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring that safeguards are implemented, for example (in respect of US-based clients) by checking that the recipients of such personal data are part of the EU/US Privacy Shield (which requires them to provide similar protection to personal data shared between the Europe and the US).
Your Personal Data
Our service providers (for example Zero, a provider of our cloud-based accounting platform) may transfer personal data outside the EEA. Where they do so, they will ensure that personal data is adequately protected by only transferring personal data to countries that have been identified as having adequate protection for EEA personal data, or by only transferring personal data where approved transfer mechanisms having been put in place to protect the personal data (such as approved Standard Contract Clauses or EU/US Privacy Shield certification).
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
8. Data retention
How long will you use my personal data for?
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.
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 requirements.
Please note that by law we have to keep basic information about our clients (including certain Contact, Identity and Transaction Data) for 7 years after they cease being clients, for tax purposes. This includes subscribers to our online subscription portal.
We retain Third Party Personal Data for up to 2 years after the end of our project/engagement with the relevant client, or at the end of the relevant client’s subscription to our online subscription portal (for whom we originally collected that Third Party Personal Data).
We keep personal data relating to our suppliers for longer, as it is in both our interests and theirs that they remain on our system and potentially available for work from us.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may 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 see the further information towards the bottom of this privacy policy. If you wish to exercise any of these rights, please contact our data privacy manager.
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 may 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 may 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
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service. 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 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.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
Last reviewed May 2022
1. Policy Statement
1.1 Pi Healthcare is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual acting on Pi Healthcare’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.
1.2 We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
1.3 The purpose of this policy statement is to:
a) set out our responsibilities, and of those working or providing services for us, (which for the purpose of the Bribery Act includes service providers of Pi Healthcare), in observing and upholding our position on bribery and corruption;
b) provide information and guidance as to how we expect those working for us to conduct themselves and how to recognise and deal with bribery and corruption issues; and
c) how to raise concerns with us including any breaches of this policy statement
1.4 Pi Healthcare’s Management Committee are committed to implementing and enforcing effective systems throughout Pi Healthcare.
2. What is bribery?
A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can be in the context of giving or receiving. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity. In addition, offering a bribe to a foreign public official to induce that public official to obtain or retain
business or an advantage in the conduct of business (and that is not permitted by local laws), will also be an offence.
3. Responsibilities
The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control.
4. Gifts and Hospitality
4.1 Pi Healthcare permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from third parties that is undertaken:
a) for the purpose of establishing and maintaining good business relationships
b) to improve the image and reputation of Pi Healthcare
c) to present Pi Healthcare’s goods/services effectively
Provided that it is: a) in good faith b) not offered, promised or accepted to secure an advantage for its employees or associated persons or to influence the impartiality of the recipient
4.2 The giving of gifts by Pi Healthcare employees with an approximate value of £50 or higher (or the local equivalent outside the UK) is prohibited unless they have been given prior approval by their Head of Department. With regard to our employees receiving gifts, unless approval has been provided by the appropriate Head of Department, gifts that exceed a £50 threshold must be declined and will be recorded. Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash must be immediately reported to the relevant Pi Healthcare Management Committee member. The giving or receiving of promotional material is not considered a gift.
4.3 The giving and receiving of corporate entertainment and hospitality for our employees should not exceed an approximate value of £50 per head (or the local equivalent outside the UK) without prior approval by a Pi Healthcare Management Committee member where possible and reasonable to do so in the circumstances.
4.4 The test to be applied is whether in all the circumstances, the gift, entertainment or hospitality is reasonable and justifiable. We expect the intention behind the gift to always be considered.
5. What is not acceptable?
There are many scenarios where there will be a breach of the Bribery Act 2010, however below are some non-exhaustive scenarios as to we think is not acceptable for employees or service providers of Pi Healthcare to do, namely:
a) give, promise to give, or offer, a payment, gift or hospitality to a third party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
c) give, offer or promise to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
d) request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
e) accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by Pi Healthcare in return ;
f) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; and
g) engage in any activity that might lead to a breach of this policy
6. Facilitation payments and kickbacks
6.1 We and our service providers should not make, and should not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK. Kickbacks are typically payments made in return for a business favour or advantage. We expect all employees and service providers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
6.2 If you are asked to make a payment on behalf of Pi Healthcare, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.
6.3 Any transactions in contracts and documentation must be recorded so that there is never any attempt to hide the way a contract will work.
7. Record Keeping
7.1 We and our service providers are expected to keep financial records and have appropriate internal controls in place which will evidence the business reason for giving and/or receiving payments from/to third parties.
8. Raising Concerns
8.1 If you believe this policy has been breached, or suspect it may have been breached, in any way please contact Pi Healthcare (privacy@pi-healthcare.com)
