Mtech Access Limited understands that your privacy is important to you and that you care about the use of your personal data. We respect and value the privacy of everyone who visits our websites, http://www.connected-insights.com/, https://www.mtechaccess.co.uk/ and http://demo-centre.mtechaccess.co.uk/ (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
Information About Us
Mtech Access is a Limited Company registered in England under company number 09875447. Registered address: Suite 2, 30 Murdock Road, Bicester, Oxfordshire, OX26 4PP. Mtech Access Limited is a Data Controller (ICO registration number ZA716523).
What Does This Policy Cover?
What is Personal Data?
“Personal data” is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data means, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. The section “How Can I Access My Personal Data?” will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us are inaccurate or incomplete. Please contact us using the contact details provided at the end of this policy.
- 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. Please contact us using the contact details provided at the end of this policy to find out more.
- 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. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, 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 are 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.
For more information about our use of your personal data or exercising your rights as outlined above, please contact using the contact details provided at the end of this policy.
It is important that your personal data are kept accurate and up-to-date. If any of the personal data we hold about you change, please keep us informed for as long as we have those data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first using the contact details provided at the end of this policy.
What Data Do You Collect and How?
|Data Collected||How We Collect the Data|
|Job Applicant Information: contact details, employment history, education and job history, interview notes.||When you apply for a vacancy or send a speculative CV to us.|
|Employee Information: application details, right to work in UK, timecards, contract, performance reviews, grievances, disciplinary information (if applicable), PAYE, salary and sick leave.||As part of the application process and then throughout your employment with us.|
|Client Information: contact information (business email address), company address, invoice details, bank account details, company accounts and correspondence.||When you or your company purchase our market access, HEOR or other related services.
When you correspond with us by phone, email or other electronic means, or in writing, or when you provide information directly to us, including in conversation with a member of our staff.
|Supplier Information: contact information (incl. business email address), bank details and purchase orders.||When you or your company offer to provide, or provides, services to us.|
|Business Development Information: business cards, contact information (incl. business email address).||When you attend a trade show, training event/seminar, networking event or you make an enquiry via Our Sites or social media channels, or when you subscribe to our newsletter or NHS whispers service.|
|Technical Information: includes Google Analytics Client ID, 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 Our Sites.||When you or your company access and use Our Sites.|
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:
|How Do We Use Your Data||Lawful Basis|
|· To register you as a client with us
· To provide products and services to you, as agreed by you or your organisation
· To process payments, billing and collection, and
· To process applications for employment.
|To fulfil a contract, or take steps linked to a contract, with you or your organisation.|
|· To facilitate effective personal contact
· For handling administration related to our market access, HEOR and other related services
· To ensure optimum delivery of our market access, HEOR and other related services
· To gather information required to administer and follow-up with delegates registering for one of our seminars, webinars, and training events
· To analyse and improve our services and communications and to monitor compliance with our policies and standards
· To manage access to our premises and for security purposes, and
· To protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities.
|As required by us to conduct our business and pursue our legitimate interests.
|· Maintaining employee and accounting records, compliance checks.||For purposes required by law.|
|· To communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services (including newsletters and other information), events, and initiatives; to send you details of promotional activities.||Consent.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out of receiving marketing materials. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the contact details provided at the end of this privacy notice.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which they were originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long We Keep It|
|Job Applicant Information: contact details, employment history, education, and job history, interview notes.||Minimum 6 months after recruitment campaign. Maximum 12 months unless consent given to retain on file.|
|Employee Information: application details, right to work in UK, timecards, contract, performance reviews, grievances, disciplinary information (if applicable), PAYE, salary and sick leave.||Employee file: 6 years after end of employee contract/termination date.
Right to work: 3 years from employment ceasing.
PAYE records: 6 years
|Client Information: contact information (business email address), company address, invoice details, bank account details, company accounts, and correspondence.||Financial records: 6 years after the end of the financial year.
Project files for as long as agreed within the Master Services Agreement (MSA).
Client contact: duration of client engagement, then 10 years.
|Supplier Information: contact information (incl. business email address), bank details, and purchase orders.||2 years after last purchase order.
Financial records: 6 years after the end of the financial year.
|Business Development Information: business cards, contact information (incl. business email address).||10 years after last contact.|
How and Where Do You Store or Transfer My Personal Data?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data are treated just as safely and securely as they would be within the UK and under the Data Protection Legislation as follows:
- We share your data with external third parties, as detailed in the table below, that are based outside of the EEA. The following safeguards are applied to such transfers:
- We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
- We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.
- Where we transfer your data to a third party based in the US additional steps have been taken to ensure your personal data will be treated as securely and safely as it would be in the UK and under the GDPR. We have signed Data Processing Agreements with our data processors based on model contract clauses provided by the European Commission (also known as ‘standard contract clauses’), which impose suitable data protection standards on a contractual basis.
Please contact us using the contact details provided below for further information about the particular data protection mechanisms used when transferring your personal data to a third country.
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:
- Limiting access to your personal data to those employees, faculty and associates, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- 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.
- Data are encrypted at rest and during transfer. Data are backed up nightly using datto SaaS protection where they are encrypted at rest and during transfer.
- Adhering our Information Systems policies, procedure and processes including, physical security, access control, data classification, and password.
Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain products and services.
|Recipient||Activity Carried Out||Sector||Location|
|Annual financial accounts||Financial||UK|
|Provision of accounting software||Information Technology (software)||USA|
|Event and Marketing Automation Tools
|Provision of marketing automation tools used to communicate with customers and prospective clients.||Information Technology||USA|
|Project Management Software
|CRM and Project Management tool||Information Technology||Australia|
|Website Design & Hosting||Website hosting, design and support||Information Technology||EEA & USA|
|Webinar hosting platform||Information Technology||USA|
If any of your personal data are shared with a third party, as described above, we will take steps to ensure that your personal data are handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
If any personal data are transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data are treated just as safely and securely as that data would be within the UK and under the Data Protection Legislation, as explained above.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
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”.
All subject access requests can be made in writing, either via email or via the postal addresses shown below, or verbally, either in person or on the phone.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of GDPR Lead:
Email address: email@example.com
Postal address: Mtech Access, Suite 2, 30 Murdock Road, Bicester, Oxfordshire, OX26 4PP
Changes to this Privacy Notice
We may change 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.
Any changes will be made available via email. This Privacy Notice was last updated on 19th November 2020.