Privacy Policy

INTRODUCTION

This privacy notice applies to your use of PRMA Consulting’s websites and applications, including: www.prmaconsulting.com; PRMA Healthcheck®; PRMA Navigator®; PRMA Tracker®; and PRMA Access Accelerator® (the “PRMA Digital Services”).

 

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

There is a separate privacy notice for users of PRMA Access Accelerator® who are ‘trusted payers’ which is available <here>.

Who we are and how to contact us

If you have any questions about this privacy notice or our privacy practices, please contact our Data Protection Officer at: Linea House 2nd Floor, Harvest Crescent, Ancells Business Park, Fleet, Hampshire, England, GU51 2UZ; or privacy@prmaconsulting.com

Third party links

The PRMA Digital Services 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. When you leave the PRMA Digital Services, we encourage you to read the privacy notice of every website you visit.

 

Communication, engagement and actions taken through external social media platforms that we participate on are subject to their terms and conditions as well as the privacy policies held with each social media platform respectively.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as set out in this section. 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 our relationship with you.

 

Contact Data: If you have a user account for a PRMA Digital Service you (or our client for whom you are using the PRMA Digital Service) will provide us with the following details: name, job title, work address and work email address.

 

Account Data: We may also allocate to you or ask you to choose a username for the account and keep an encrypted record of your account password.

 

Technical Data: certain technical information is transmitted automatically from your browser to our servers, such as: internet protocol (IP) address, your login data, crash logs, date and time of the request, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the PRMA Digital Services.

 

Usage Data: your browser also transmits to our servers, or we may use cookies to collect, information about how you use the PRMA Digital Service, such as: number of page views, the search queries you make on the PRMA Digital Service, which activities and features are used, interactions between you and other users, and other actions on the PRMA Digital Service. For more information about the cookies we use, please read our <Cookies Policy>

 

Work Product Data: this is the content you input and create when you use the PRMA Digital Services, which is not related to you but which is attached to your account, such as product information and reports.We may use your data to create aggregated data. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific feature of a PRMA Digital Service. This data is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine it with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy notice.

 

Where we need to collect personal data by law, or under the terms of a contract we have with you (or with our client for whom you are using the PRMA Digital Service) and you fail to provide thatdata when requested, we may not be able to perform the contract (for example, we may not be able to provide you with certain PRMA Digital Services) but we will notify you if this is the case at the time.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

 

Where you have consented before the processing by signifying your agreement by a statement or clear opt-in. You can withdraw your consent at any time by contacting us at privacy@prmaconsulting.com.

 

Where it is necessary for the performance of a contract we are about to enter or have entered with you.

 

Where we need to comply with a legal or regulatory obligation that we are subject to.

 

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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@prmaconsulting.com

 

Purpose/activity
Type of data
Lawful basis for processing
To provide the PRMA Digital Services. For example, if you use any of the applications in the PRMA Digital Service catalogue (i.e. PRMA Healthcheck®, PRMA Navigator®, PRMA Tracker®, PRMA Access Accelerator®), we process the information you provide to support your business’s objectives such as supporting HTA and P&R submissions, understanding the competitive landscape, and obtaining expert advice on a variety of topics.
Contact Data
Account Data
Technical Data
Usage Data
Work Product Data
Necessary for our legitimate interests (to provide the PRMA Digital Services which we have licensed to our client and which they have asked you (as a member of their staff) to use for the operation of their business).
To set up your user account for the PRMA Digital Services.
Contact Data
Account Data
Necessary for our legitimate interests (to provide the PRMA Digital Services which we have licensed to our client and which they have asked you (as a member of their staff) to use for the operation of their business).
To manage our relationship with you. For example, we may contact you to inform you of changes to our products or our terms and conditions; or to let you know when updates are available.
Contact Data
Account Data
Usage Data
Necessary for our legitimate interests:

– to provide the PRMA Digital Services which we have licensed to our client and which they have asked you (as a member of their staff) to use for the operation of their business; and

– to keep records updated and to assess how customers use the PRMA Digital Services.

Necessary to comply with legal obligations (to inform you of any EUROPE changes to our terms and conditions).

To ask you to leave a review or take a survey.
Contact Data

Account Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To develop and improve our products. For example, we may use error reports to improve security or analyse Usage Data to decide on what functions, features, and new products we should develop.
Contact Data

Account Data

Technical Data

Usage Data

Work Product Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and the PRMA Digital Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Contact Data

Account Data

Technical Data

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you.
Contact Data

Account Data

Technical Data

Usage Data

Work Product Data

Necessary for our legitimate interest to make our content more relevant and more effective and to ensure that our content is personal and engaging.
To deliver online advertising to you promoting our products/services which are similar or complimentary to the PRMA Digital Services you are using.
Contact Data

Account Data

Technical Data

Usage Data

Work Product Data

 

Necessary for our legitimate interests (to market and promote our products and services).
To use data analytics to improve our products/services, marketing, customer relationships and experiences.
Account Data

Technical Data

Usage Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To send you emails and texts promoting our products/services which are similar to the PRMA Digital Services
Contact Data

Usage Data

Necessary for our legitimate interests (to market and promote our products and services) provided that you can opt-out when we first collect your Contact Data and each time we send you a marketing message.

If you object to us using your personal data for these purposes, including direct marketing, please send an email to us using the following email address: privacy@prmaconsulting.com.

Disclosures of your personal data

We may share your data with:

 

Our client on whose behalf you are using the PRMA Digital Services, acting as a controller, for the purposes of them: (a) using the PRMA Digital Services in the operation of their business; and (b) managing and adminstering the use of their authorised users of the PRMA Digital Services.

 

IT service providers, acting as processors, based in the United Kingdom, who provide hosting, software maintenance and IT support services.

 

Analytics provider, acting as processors based in United States, who help us to compile and analyse Technical Data and Usage Data to improve our products and services. You can find out more about these providers in our Cookie policy.

 

Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

 

Tax authorities, regulators and other authorities acting as controllers, based in the United Kingdom, who require reporting of processing activities in certain circumstances.

 

New owners. 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 notice

 

International transfers

 

When we transfer data to another country which is not in the United Kingdom or the European Economic Area, we will use at least one of the following safeguards and you can contact us if you want to know more about the specific mechanism we’ve used:

  • 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.
  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • We may transfer data to the United States if the recipient is part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.

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

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 have rights under data protection laws in relation to your personal data.

 

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request

 

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 your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your 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 the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

You also have the right to ask us not to continue to process your personal data for marketing purposes. You can also ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. 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.

You can exercise any of these rights at any time by contacting us at
privacy@prmaconsulting.com.

Last reviewed: 23rd May 2018