Privacy Policy
It is important that you read this privacy policy together with any other privacy policy or fair processing policy that groupH 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.
This privacy policy was last updated in November 2021.
Important information and who we are
GROUPH LIMITED (company no: 05412677) is the controller and responsible for your personal data (collectively referred to as groupH, “we”, “us” or “our” in this privacy policy).
This privacy policy aims to give you information on how groupH collects and processes your personal data:
- Through your use of the groupH website, including any data you may provide through this website when you contact us;
- When we obtain your details from any third party to contact you to participate or contribute to any research we think you may be suitable for;
- When you contact us generally and in respect of our research.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy; their contact details are provided below:
Data Privacy Manager: Anju Patel
Email address: anju.patel@grouph.com
Telephone number: 0208 785 4510
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.
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.
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.
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 and Contact Data includes first name, maiden name, last name, title, address email address and telephone numbers.
- Financial Data includes bank account and payment card details where we make payment to you.
- Professional Data includes employment information (if relevant), qualifications, professional specialisation, research focus and all information included in you curriculum vitae (CV).
- Research Data includes information about any research you assist us with or any other professional advice you provide to us.
- Technical Data includes internet protocol (IP) address, 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. Information about how you use our website
- Marketing and Communications Data includes your preferences in receiving marketing from us 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. 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 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.
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, 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 (for example, for you to participate in our research).
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data, Financial Data, Professional Data and Research Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- participate in our research;
- assist groupH in any other way in carrying out its research or such a similar purpose;
- create an account on our website;
- subscribe to our publications;
- request marketing to be sent to you;
- 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, server logs and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU;
- Identity and Contact Data and Professional Data from publicly available sources such as Linkedin, PubMed, Expertscape, ClinicalTrials.gov or any other similar medical professionals website.
- Identity and Contact Data and Professional Data from medical associations or a particular disease association, editorial boards of industry journals, other professionals at industry conferences or other similar industry specific groups.
- Identity and Contact Data and Professional Data from recruitment agents who recommend you to us to assist with our research or for such a similar purpose.
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 (Contract).
- 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 (Legitimate Interest).
- Where we need to comply with a legal obligation (Legal Obligation).
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
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.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To confirm that you are participating in our research or assisting us in any other way with our research or for a similar purpose |
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To pay you:
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To manage our relationship with you |
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data and to deliver relevant website content) |
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To use data analytics to improve our website, marketing, relationships and experiences |
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Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To contact you in the future about other research or similar which you might be interested in taking part in |
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Necessary for our legitimate interests (to improve our research and grow our business) |
Cookies
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 our Cookie Policy.
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 Purposes for which we will use your personal data above.
- Internal Third Parties:
- Our associates who work with groupH.
- External Third Parties:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- 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.
International transfers
We do not generally transfer your personal data outside the European Economic Area (EEA).
However, some of our external third parties and other companies who we may have affiliations with or work with for research purposes, may be based outside the EEA so their processing of your personal data may involve a transfer of data outside the 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:
- 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.
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.
Data retention
How long will you use my personal data for?
We will only retain your personal data 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.
Your legal rights
Under certain circumstances, you may be able to exercise the rights under data protection laws in relation to your personal data as set out below:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- 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.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in some circumstances.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us.
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.
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.
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.