Definitions: SciMed Consulting Ltd. is referred to as the ‘Company’.
1.The Data Protection Impact Assessment undertaken on THURSDAY 24th MAY 2018 confirms the following:
- Client data is held securely in LessAnnoying CRM. Currently only 3 people have access to this data; Sarah Howells, Director; Nita Mistry, Project Manager, subcontractor; Christina Kubu, Administration + Operations, subcontractor.
- Data has been collated and consolidated from the Company’s Directors’ address books.
- Where new data is added, these details either come from LinkedIn which is a consensual information vehicle or direct from an individual giving implied consent to continued liaison.
- The data is never transferred out of the Company nor ever shared with any third party.
- Where an individual changes role or responsibilities which is deemed as no longer relevant, contact is deactivated.
- New contacts are primarily sourced via LinkedIn which, as a networking platform, members will reasonably expect to receive communications from other members.
2. SciMed Consulting has appointed a Data Protection Officer, confirmed as Donna Pallister, Director of SciMed Consulting Ltd.
3. Legitimate Interest Assessment:
- Communication with our contacts in the current database is to share the benefits of working with SciMed Consulting Ltd.
- Liaison is with contacts who work specifically in the pharmaceuticals and healthcare arena.
- SciMed Consulting Ltd. offers to help companies train their medical personnel to enhance product knowledge, a vital role in ensuring products are sold safely.
- The information sent on initial contact cannot be deemed as private or personally sensitive in any way. In no way do we collect any data that can be deemed as ‘special category data’ ie. allowing you to infer someone’s religion, ethnicity or details about their health.
- The emails sent are targetted at individuals who have a specific job role and in specific therapy areas.
- We explain clearly in the email why we are contacting individuals and additionally offer the opportunity to opt out from any further contact.
- The impact of these introductory emails is minimal and any objections will be logged.
4. On a B2B basis, as the PECR allows marketing to be sent to existing customers without asking for their consent, SciMed Consulting Ltd. ensures that:
- The email address and other contact details were collected during the sale of goods or services;
- SciMed Consulting Ltd. is clearly identified in each communication;
- The marketing communications is about similar goods or services to those previously communicated;
- The option to unsubscribe/opt out of further communications is offered in each email;
- SciMed Consulting Ltd. does not use any lists acquired from third parties.
- There is no ‘high risk’ processing that is undertaken by SciMed Consulting Ltd.
- On the topic of subject access requests and the right to erasure / decline further communications from SciMed Consulting Ltd, the Company undertakes to;
- Respond to any individual’s demand to see the data currently held in the CRM;
- Remove their contact data on request, with no further questions asked.