Consilient Health Limited and its subsidiaries (“We”) are committed to protecting and respecting your privacy.
This policy (together with any other documents referred to in it) sets out the basis on which any personal data (including sensitive personal data) we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the GDPR and Data Protection Act 2018 (the “Act”), Consilient Health Limited of 5th Floor, Beaux Lane House, Mercer Street Lower, Dublin 2 is a data controller.
- INFORMATION WE MAY COLLECT FROM YOU
1.1 We may collect and process the following data about you:
1.1.1 Information you give us. You may give us information about you by filling in order forms, participating in a recruitment process or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our services, place an order, attend one of our events, apply for an open position or when you contact us about one of our products. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, date of birth, gender, and location from where you are calling, current level of remuneration, including benefit entitlements, whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process, information about your entitlement to work in Ireland, the UK and the EU and may also include sensitive personal data such as information about your physical or mental health or condition in the event you are contacting us about one of our products. Healthcare professionals may also provide us with information relating to their specialities and professional affiliations.
1.1.2 Information we receive from other sources. We may receive information about you if you use any of the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, sub-contractors in technical, payment and delivery services, analytics providers, credit reference agencies) and may receive information about you from them. We may also collect personal data about you from third parties, such as references supplied by former employers. We will only seek information from third parties once a job offer to you has been made and will inform you that we are doing so.
- USES MADE OF THE INFORMATION
2.1 We use information held about you in the following ways:
2.1.1 Information you give to us. We will use this information:
(a) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
(b) to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
(c) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form) or contact us on the details provided in the “Your Rights” section below;
(d) to notify you about changes to our services or products;
(e) to validate your ability to access or use certain products, services or information (e.g. some of our products are only suitable for or accessible by individuals meeting certain eligibility or other criteria such as being a licensed healthcare professional or holding a wholesale dealer licence);
(f) to provide customer service and support.
(g) as part of the recruitment evaluation process.
2.1.2 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- WEBSITE USE
3.2 With regard to each of your visits to our site, we may automatically collect and process the following information:
3.2.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
3.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
3.3 We may also receive information about you if you use any of the other websites we operate.
3.4 We will use this information:
3.4.1 to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.4.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
3.4.3 to allow you to participate in interactive features of our service, when you choose to do so;
3.4.4 as part of our efforts to keep our site safe and secure;
3.4.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
3.4.6 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3.5 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
3.6 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- MOBILE APPLICATION SOFTWARE
- DISCLOSURE OF YOUR INFORMATION
6.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Irish Companies Act 1963.
6.2 We may share your information with selected third parties including:
6.2.1 Business partners, service providers, suppliers and sub-contractors for the performance of any contract we enter into with you or them;
6.2.2 In relation to use of our site, analytics and search engine providers that assist us in the improvement and optimisation of our site;
6.2.3 Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
6.3 We may disclose your personal information to third parties:
6.3.1 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
6.3.2 If Consilient Health Limited and/or Consilient Health (UK) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
6.3.3 In order to comply with the industry codes of practice, including the ABPI Code of Practice for the Pharmaceutical Industry and the EFPIA Code. For example, we are required to document and publicly disclose certain transfers of value made to health professionals and healthcare organisations;
- WHERE WE PROCESS YOUR PERSONAL DATA
- YOUR RIGHTS
You have the right to access any personal information that Consilient Health processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
- ACCESS TO INFORMATION
The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR.
Lodging A Complaint
Consilient Health only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
JJ Culhane – Data Protection Officer
Block 2A Richview Office Park
+353 (0)1 2057 760
Helen Dixon – Data Protection Commission
R32 AP23 Co. Laois
+353 57 8684800
+353 (0)761 104 800
IE-EVC-11m | Date of preparation: January 2021