This website is provided by Oxbridge Solutions Limited, registered in England and Wales under company number 2592842 at Ground Floor, 108 Cannon Street, London, EC4N 6EU, UK, and we are the data controller in respect of your personal information.

We take very seriously the privacy of our website users and the security of their personal information.

This Privacy Policy does not form part of any contract to provide services, and stands alone in setting out the principles governing our use of personal information which you give or we obtain about you, in accordance with the General Data Protection Regulation (“the GDPR”) and Data Protection Act 2018 (“DPA 2018”). It should, however, be read alongside our Terms and Conditions because together these set out the terms of our relationship with you. We ask you to read this Privacy Policy carefully, so that you understand how and why we are using your personal information as well as your rights under the data protection legislation.

We may change our Privacy Policy from time to time. Therefore, we ask you to check this Privacy Policy occasionally to ensure that you are aware of the most recent version which will apply each time you access this website.

DESCRIPTION OF THE INFORMATION WE COLLECT

Personal Information

The GDPR and DPA 2018 regulate the processing, or use, of personal data which is any information from which an individual can be identified, whether directly or indirectly. This does not include anonymous data, i.e. information from which it is not possible to identify any individual.

There are also further classes of personal data to which the data protection legislation affords a higher level of protection, known as ‘special category data’. This includes information relating to an individual’s health, racial or ethnic origin, sexual orientation and criminal convictions. However, we do not process any special category data.

We will collect personally identifiable information about you from your interactions with us, such as filling in a registration form or otherwise contacting us. The information we collect about you may include:

• your name;
• e-mail address;
• postal address, including country of residence;
• GMC number; and
• other information which you voluntarily submit.

If you contact us, we may keep a record of that correspondence.

We may also collect information about how you in particular use this website through the use of cookies (see below). This information helps us to personalise your experience by tailoring the content you see, and optimising your enjoyment of the website. We will also use it to generate anonymised statistical data about how the website is used, particularly in relation to the access of particular resources. We may share that anonymised data with third parties. We may also generate anonymised statistical information, as summarised further below, by reference to information you have stored in your account, such as notes on our content to be used for CPD purposes, as well as any CPD reports exported from your account. Any reporting of such information would be on an anonymised basis, only.

We may also obtain information about your opinions if, for example, you send us feedback, or ask us questions.

We may also, occasionally, receive information about you from other sources (such as third parties or associated sites) which we will add to the information which we already hold about you in order to help us improve and personalise our service to you.

We use Google Analytics tracking to track user activity. The data we collect about users in Google Analytics can be connected to other data we have about the end user, as per the measurement policy supplied by Google. We will not upload any data that allows Google to personally identify an individual (such as certain names, Social Security Numbers, email addresses, or any similar data), or data that permanently identifies a particular device (such as a unique device identifier if such an identifier cannot be reset).

Use of Cookies

In common with many organisations we monitor the use of this website by collecting aggregate information through the use of cookies. No personally identifiable data are collected in this process. Typically, we collect information about the number of visitors to the website, to each web page and the originating domain name of the visitor’s Internet Service Provider. This information helps us to improve our site and to deliver a more personalised service and may be shared with third parties.

A cookie is a small file which is placed on your computer’s hard drive. The file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Some of our advertising banners may send a cookie to your hard disk (whether or not you click the banner). If you subsequently visit the advertised website, we will know that you have seen our banner. This allows us to keep track of the success rates of such banners.

The majority of web browsers accept cookies, but you can usually change the web browser’s settings to refuse new cookies, disable existing ones or simply let you know when new ones are sent to your hard disk. However, please be aware that, if you refuse or disable cookies, some of the website’s functionality may be lost. To learn more about how to refuse or disable cookies please visit “aboutcookies.org”.

HOW WE USE YOUR INFORMATION

We may use your personal information to:

(a) verify your healthcare professional status;

(b) provide you with information, products or services that you have requested from us;

(c) carry out our obligations arising from any contracts entered into between you and us;

(d) monitor and track behavioural patterns in respect of your interaction with website promotional content, to better understand trends and attitudes towards particular drugs or treatments; and/or

(e) create statistical, anonymised data about access to and use of our services.

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We will only use your personal data in accordance with the data protection legislation, which says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

In order to ensure that your personal data is used lawfully, we must ensure that we have a lawful condition for processing under Article 6 of the GDPR. With the exception of the specific scenarios outlined below, we process your personal data on the basis of Articles 6(1)(b), which relates to processing necessary for the performance of a contract with you, and/or 6(1)(f) which allows us to process personal data where necessary to do so in the pursuit of legitimate interests. In this particular instance, those interests relate to our broader business activities which are not strictly necessary to perform your individual contract. Article 6(1)(f) requires us to ensure that the legitimate interest(s) we rely upon in order to process your personal data are not outweighed by your rights and freedoms, which we have done by inviting you to provide your personal information on a voluntary basis and also by taking only the minimum amount of such information necessary.

In very specific scenarios, we will only process your personal data in circumstances where you have positively indicated your consent for us to do so. This is particularly where we want to provide you with promotional materials. Upon using the site, you may be invited to consent for us to send you our podcast newsletter, which contains details of new GPnotebook Podcast features and content as well as, potentially, promotional materials from third-party pharmaceutical companies. In addition, or as an alternative, you may be invited to consent to specifically receive third-party promotional materials, which we send on our clients’ behalf. Please note that we do not pass your personal information onto third parties for marketing purposes. You should also note that even if you do not consent to receipt of promotional materials then we will still provide you with essential updates about GPnotebook.

WHO WE SHARE YOUR INFORMATION WITH

We will keep your information confidential. We will not pass your information to anyone else unless required to do so by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so, except for (a) successors in title to our business; or (b) when required by law. Companies and individuals who provide services and functions on our behalf may also use and store your personal information. However, they may not use your personal information for any other purpose. As set out above, we may provide business partners with statistical data which provides an aggregated overview of the manner in which services and adverts are used but, critically, you will not be identifiable from that information and accordingly it will not comprise your personal data.

As set out above, we do not provide your personal information to any third parties for marketing purposes, as we will send out promotional materials on their behalf where you have consented to us doing so.

We may pass limited personal information onto third party business partners, where it is necessary to do so for the purposes of pharmaceutical marketing compliance. This is in circumstances where we are providing a product or service, such as a webcast funded by a pharmaceutical company, as they need to specifically understand which individuals have accessed the product or service from a marketing compliance perspective. We will not, however, provide them with your email address or phone number for such purposes.

OPTING OUT OF FURTHER COMMUNICATIONS FROM US

If we have specified (in a data collection notice on this website) that we will contact you with information about our products, services, or those of other companies and you wish to opt out of receiving such information, then you can do so by sending an e-mail to support@gpnotebook.co.uk. You should clearly state on all communications: your name, username (if any), registration details (if any) and the name of this website. You may also edit your contact preferences on your profile page.

HOW WE PROTECT YOUR INFORMATION

If we collect any information relating to you, we will store it on a secure server. We have in place security policies which are intended to ensure, as far as possible, the security and integrity of all our information, including your personal information. However, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.

CHILDREN

Our website is directed at an adult audience of healthcare professionals. We do not knowingly collect information from or about children.

IMPROPER CONDUCT

We may use the information we gather and/or receive about you to investigate and help prevent unlawful activity or activity that threatens our network or otherwise jeopardises the provision of this website and we may disclose such information to third parties (such as the police) for these purposes.

DATA RETENTION

We are required to ensure that we do not continue to retain your data for longer than is necessary by reference to the purpose for which it was collected. We will keep your personal information for no longer than is necessary to administer the business relationship between us, and/or by reference to relevant legal and regulatory retention periods.

INTERNATIONAL DATA TRANSFERS

Our services are available to users outside the UK, but the personal information provided to us is processed on UK based servers and not transferred by us outside the UK.

YOUR RIGHTS

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, and as set out in further detail in our general privacy notice, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• 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.
• 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 review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing as set out below.

No fee usually required

You will not usually 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.

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 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.

If you would like to exercise any of your rights then you can do so by contacting us at support@gpnotebook.co.uk or by post to:

The Data Controller
Dr Damian C. Crowther
18 Ross Street
Cambridge
CB1 3BX
UK

Please state your name, username (if any), registration details (if any) and the name of this website clearly on all communications.

Right to complain to the Information Commissioner’s Office

You can complain to the Information Commissioner’s Office (ICO) if you are unhappy with the way we have dealt with a request from you to exercise any of your rights or if you think we have not complied with our legal obligations. Whilst you do not have to do so, we would appreciate first making us aware of the issue and giving us an opportunity to respond and to address it before contacting the ICO.

Making a complaint will not affect any other legal rights or remedies that you have. More information can be found on the ICO website: https://ico.org.uk/ and the Information Commissioner’s Office can be contacted by post, phone, fax or email as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 9 (if you prefer to use a national rate number)
Fax: 01625 524 510
Email: casework@ico.org.uk