Purpose of this policy
This policy describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR) 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Clarity Informatics Limited (“we”, “us”, “our” and “ours”) is a provider of knowledge, software, and services in the healthcare sector. We are registered in England and Wales under company number: 04133376 and our registered office is at Deltic House, Kingfisher Way, Wallsend, Newcastle upon Tyne, NE28 9NX.
How we may collect your personal information
We may collect and process information that you provide by filling in forms on our website. This includes information provided at the time of registering to use our site or subscribing to any of our services (“Registration Data”), and material contributed through any interactive service (“User Generated Content”).
If you contact us, we may keep a record of that correspondence.
The kind of information we hold about you
The information we hold about you may include the following:
- your personal details (such as your name and/or address);
- details of contact we have had with you when providing you with a quote for our products or services;
- details of any products or services you have received from us;
- information about any complaints and enquiries you make to us;
- tracking cookie data (please see our cookies policy).
How we use information we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you and to comply with our legal obligations.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
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.
Situations in which we will use your personal information
We may use your information in order to:
- carry out our obligations arising from any agreements entered into between you OR your employer and us (for example, for the provision of our products and services);
- provide you with information related to products or services that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our products or services.
In some circumstances we may anonymize or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal information without your knowledge or consent, in accordance with this policy, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing what retention period is appropriate for your personal data, we take into consideration:
- the purposes for which we originally collected the personal data;
- the lawful grounds on which we based our processing;
- the types of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal information where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
We do not share your information with third parties, save as set out below.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
Sharing of information within TeamNet
TeamNet can be used by our TeamNet customers (who are the data controllers) to share personally identifiable information where a member of staff works in more than one organisation. This includes individual staff records which contain absences, training and immunisation records and DBS checks. The reason for this is to allow individuals who may be working across several sites to ensure that their relevant employment details are available to their employer in those sites.
Each employee who works across different organisations should be made aware that this information will be visible to the primary contact and HR manager at all organisations where they have been added as a TeamNet user.
TeamNet users should always ensure they have the appropriate consents from data subjects whose personal data is being shared using TeamNet. This is a very important user responsibility.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We will not transfer the personal information we collect about you outside of the EU.
We have put in place commercially reasonable and appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Right of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to exercise any of the above rights, please email email@example.com.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email firstname.lastname@example.org .
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this policy
This policy was last updated on 17th April 2020.
If you have any questions regarding this policy or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer: email@example.com .
You also have the right to make a complaint to the Information Commissioner’s Office (ICO: https://ico.org.uk), the UK supervisory authority for data protection issues, at any time.