LEGAL

OPEN MEDICAL PRIVACY POLICY

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us.

We are Open Medical Limited, a medical software development company registered in England under company number 08620208. Our Data Protection Officer may be contacted by email at dpo@openmedical.co.uk or by telephone on +44 (0)20 3457 2955.

This privacy notice covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our Data Protection policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. A copy is available on request from our Data Protection Officer.

We undertake to preserve the confidentiality of all information you provide to us. Our policy complies with the Data Protection Act 2018 (the Act) and the UK General Data Protection Regulation (UK GDPR).

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

YOUR RIGHTS

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold as set out in more detail below:

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 through our Data Protection Officer whose details are given above
The right to access the personal data we hold about you

The right to have your personal data rectified
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 hold
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 withdraw consent
The right to data portability - 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

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

Data we process

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided at some time.
Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
Technical data includes your internet protocol (IP) address, 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.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service, or use aggregated anonymised data for research purposes.

However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

By limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and by ensuring that they are subject to duties of confidentiality; and
By implementing policies and procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

A copy of our Information Governance pack containing these policies and procedures may be requested from our Data Protection Officer.

Special personal information

Special personal information is data 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. We may collect special personal information about you only if there is a lawful basis on which to do so.

If you do not provide personal information we need

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 that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

verify your identity for security purposes
sell products to you
provide you with our services
provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@openmedical.co.uk. However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

record-keeping for the proper and necessary administration of Open Medical Ltd
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage risk
protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at ig@openmedical.co.uk.

Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate. Free speech is a fundamental right, so we have to make a judgement as to whose right will be obstructed: yours, or that of the person who posted the content that offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to one year in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment.

Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our service. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you. The information is not used for any other purpose. We undertake to preserve the confidentiality of the information and of the terms of our relationship. We expect any affiliate or partner to agree to reciprocate this policy.

Information we collect through automated systems

Cookies

Our website does not track visitor cookies. Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the pages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed in to our website.

Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.

Third party advertising on our website

Third parties do not advertise on our website.

Control over your information

Subject Access Request

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”. Please contact our Data Protection Officer who will provide you with our Subject Access Request Policy which will explain how to proceed.

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.

Removal of your information

If you wish us to remove personally identifiable information from our website, you should contact us to make your request. This may limit the service we can provide to you.

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.

Encryption of data

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain

If you are not happy with our privacy policy or if you have any complaint, then you should tell us via email or website contact. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

to provide you with the services you have requested
to comply with other law, including for the period demanded by our tax authorities
to support a claim or defence in court

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you. However, ultimately it is your choice as to whether you wish to use our website.

Review of this privacy policy

We may update 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. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions regarding our privacy policy, please contact us.

Last updated on 1/9/2021

LEGAL OPEN MEDICAL PRIVACY POLICY