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Pinnacle Systems Management Limited ("Pinnacle") understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, pharmoutcomes.org or outcomes4health.org ("our site") 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.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Means an account required to access and/or use certain areas and features of our site
Means a small text file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of our site. Details of the Cookies used by our site are set out in Part 14
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
2. Information About Us
Our site is owned and operated by Pinnacle Systems Management Limited ("Pinnacle"), a Limited Company registered in England under company number 09286851.
Registered address: Fulford Grange, Micklefield Lane, Rawdon, Leeds, England, LS19 6BA.
Main trading address: 86-88 High Street, Newport, Isle of Wight PO30 1BH.
VAT number: 927 1492 14.
Data Protection Officer: Ian McKie.
Email address: firstname.lastname@example.org.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, 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.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. If you feel information we hold about you is incorrect, please contact us using the details in Part 15.
- 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 have. If you want to exercise this right, please contact us.
- The right to restrict (i.e. prevent) the processing of your personal data. This right will apply to any data we might have already collected from you. If you want to restrict the use of this data as described in this policy, please contact us.
- The right to object to us using your personal data for a particular purpose or purposes. We only use your personal data for the purposes described in this document and as required by law.
- 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 is processed using automated means. You can ask us for a copy of the 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.
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 us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office.
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.
6. What Data Do We Collect?
- Email address;
- Telephone number;
- Business name;
- Job title;
- Contract payment information;
- IP address;
- Web browser type and version;
- Operating system;
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. We collect data necessary for:
- our performance of a contract with you,
- because you have consented to our use of your personal data,
- or because it is in our legitimate business interests to use it.
Your personal data may be used for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to our site;
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have chosen to receive. You may unsubscribe or opt-out at any time by updating your preferences in your user account.
With your permission and/or where permitted by law, we may also use your personal data to contact you with information and news on our 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 GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
8. 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 as long as required to fulfil our legal requirements dependent on your use of the system.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the "EEA"). This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including maintaining the following security standards:
- NHS Information Governance Toolkit at Level 3
- Cyber Essentials PLUS
- System Infrastructure Management accredited to ISO27001:2017
10. Do You Share My Personal Data?
We share your personal data with Emis Health Limited (EMIS). EMIS is part of the same group as Pinnacle.
We may also share information with our hosting partners and accountants as follows:
- PharmOutcomes/Outcomes4Health is held on a secure server infrastructure hosted entirely within the UK by Memset Ltd, Building 87, Dunsfold Park, Stovolds Hill, Cranleigh, GU6 8TB and Unit 2, Smallmead Road, Reading, RG2 0QS.
- TC Accountants 023 Limited is a limited company registered in England and Wales with company number 11257300 and whose registered office is at 3 Acorn Business Centre Northarbour Road, Cosham, Portsmouth, PO6 3TH.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
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.
11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and/or at the point of providing your details and by managing your Account).
12. Can I Withhold Information?
You may access certain areas of our site without providing any personal data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
13. 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 should be made in writing and sent to the email or postal addresses shown in Part 15. 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 14 days and, in any case, 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.
15. 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:
Email address: email@example.com
Postal Address: Pinnacle Systems Management Ltd, 86-88 High Street, Newport, PO30 1BH.
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.