27 August 2020
RPS respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how the Royal Pharmaceutical Society (trading as Pharmaceutical Press) collect and process your personal data through your use of this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. By visiting www.bnf.org (including the BNF and the BNF for Children app) and www.formularycomplete.com you are accepting and consenting to the practices described in this policy.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
These Websites (www.bnf.org and www.formularycomplete.com along with the applications for the BNf and the BNF for Children) are operated by the Royal Pharmaceutical Society of Great Britain incorporated by Royal Charter in England and Wales under company number RC00079 and having its principal business address at 66-68 East Smithfield, London E1W 1AW (‘we’ and ‘our’) who also trade as Pharmaceutical Press.
For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation 2016, we are the “data controller” (i.e. the company who is responsible for, and controls the processing of, your personal data).
66-68 East Smithfield, London, E1W 1AW
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THIS POLICY
This version was last updated in February 2020 and historic versions can be obtained by contacting us.
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 your relationship with us.
THIRD PARTY LINKS
This website 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 our website, we encourage you to read the privacy notice of every website you visit.
2. COLLECTION OF PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
|Category|| Types of data |
|Identity Data||includes first name , maiden name, last name, username or similar identifier, marital status, title, date of birth and gender,||2 years after your last purchase or access to the Website|
|Contact Data||includes your email address and billing address, delivery address, and telephone numbers.||2 years after your last purchase or access to the Website|
|Profile Data||includes your username and password, purchases or orders made by you for any products, your interests, preferences, feedback and survey responses.||2 years after your last purchase or access to the Website|
|Demographic Data||job title and place of work, sector of operation, job level and function||2 years after your last purchase or access to the Website|
|Financial Data||includes any payment information and financial details you provide in order to use the Website.||6 years after the transaction|
|Usage Data||information about how you use our website, products and services||2 years after your last purchase or access to the Website|
|Marketing and Communications Data||Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.||2 years after your last engagement with our marketing and communications.|
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
|Category of Data||Collection Method|
|Identity, Contact, Profile, Demographic and Financial Data||You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; register for and create an account on our website; email us to discuss account management and services; sign up for an event run by us or our affiliates; subscribe to our service or publications; engage with interactive features of our website, including groups and networks; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback report a problem with our site including sending emails via the Zendesk support platform.|
|Contact, Financial and Transaction Data||Third party providers of technical, payment and delivery services such as WorldPay|
|Technical Data||Third parties such as Analytics providers such as Google Analytics, based in the US. Search information providers such as Google, based in the US. Zendesk who provide our website troubleshooting services.|
|Marketing and Communications Data||Direct interactions when you tick boxes to opt in or opt out of marketing (through your account or by visiting the Website) and communications from us or unsubscribe to any of our communications.|
4. USING YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than
- Sending email communications and newsletters about latest new drugs and significant changes, insights and new products and services;
You have the right to withdraw consent to marketing at any time by clicking on links provided in our marketing emails and amending your preferences.
- PURPOSES OF USE OF PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new registered user||(a) Identity |
|Performance of a contract with you|
|To process and deliver your orders on this website, for events and products, including: |
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Direct Debit credit reference checking. This information will be processed by Worldpay for e-commerce purposes
|(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) Asking you to leave a review or take a survey including sending an email asking you to rate your experience of using our products and services
(c) providing you with information for and asking for feedback about an event you registered for on our site
|(a) Identity |
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity |
(e) Marketing and Communications
(f) Special Category
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business and to monitor equal opportunities)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and to ensure that content from our site is presented in the most effective manner on your computer||(a) Identity |
|(a) 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) |
(b) Necessary to comply with a legal obligation
|To deliver relevantwebsite content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you) |
(e) Marketing and Communications (f) Technical
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical |
|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 make suggestions and recommendations to you about goods or services that may be of interest to you ||(a) Identity |
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can also subscribe to receive newsletters, which will keep you informed, by e-mail, of the latest new drugs and significant changes, insights and products and services offered by Pharmaceutical Press. This can include: Newsletters about MedicinesComplete, the BNF and Pharmaceutical Press, MedicinesComplete Monthly, Medicines Information Products and Services, Research and Events emails.
You can change your marketing preferences by following the links on email communications from us, which will take you to our marketing preference centre.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Demographic, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if:
- you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing; and
- You have subscribed to our marketing email newsletters in the past; and
- You opt in to receive the latest new drugs and significant changes, insights and product/services information from us.
We use a marketing tool called Pardot, provided by Salesforce, that allows us to automatically select relevant emails for you based on your sector and job function or based on your activities on our website or subscription status.
You may also be presented with Pharmaceutical Press marketing communications through third party platforms that we work with such as Twitter and LinkedIn. You can change your advertising preferences on those platforms through your user account with those platforms.
We will get your express opt-in consent before we share your personal data with any company outside the Royal Pharmaceutical Society group of companies for marketing purposes.
SOCIAL MEDIA PLATFORMS
We may work with other data controllers such as Twitter and LinkedIn to provide you with targeted advertising about RPS whilst on those platforms. You can change your advertising preferences on these platforms through your account settings.
You can ask us to stop sending you marketing messages at any time by following the links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase including registration for our applications, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- This will include sharing data with the Royal Pharmaceutical Society and the Pharmaceutical Press.
- Worldpay assist in the processing of Financial Information for the purposes of delivering e-commerce services.
- External Third Parties as set out in the Glossary.
- 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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the External Third Parties listed in the Glossary (Paragraph 11) This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. SECURITY MEASURES
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.
Where you have access to a secure area of the Website you are responsible for keeping your login details and password(s) confidential and protected. We ask you not to share your password with anyone. You can change your password at any time by logging in. We accept no responsibility or liability if a third party obtains and uses your ID or password. You must tell us immediately if you believe someone may have access to or use of this information.
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.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below paragraph 10 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). 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 which 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 on 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 which 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.
If you wish to exercise any of the rights set out above, please contact our data protection officer at firstname.lastname@example.org or using the contact details set out at the beginning of this policy.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Amazon Web Services, based in Ireland and the US, who provide website hosting and advertising services.
- Chrysalis, based in the UK, who provide market research services.
- Firebase who provide tools for tracking analytics, reporting and fixing app crashes, creating marketing and product experiment.
- GoogleAnalytics who provide anonymised website usage data analytics.
- GoogleAds, based in the US, who provide website advertising services (currently based on content rather than personal use).
- Hedgehog Lab who provide BNF app support and product development services.
- Highwire who provide login and access servicesusing SAMS SIGMA technologies
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances
- Instapage, based in the US, who provide website management services to allow us to build landing pages for the Website.
- LinkedIn, based in the US, we upload data to LinkedIn to allow us to target advertising that is relevant to you
- MDL MacMillan based in England and India, who provide institutional and organisational subscription services to us
- MPS Ltd based in India, who provide business services including processing of invoices and credit management
- RedHat Inc, based in the US, who provide API services which connect into the MedicinesComplete system
- Redwing who provide IT, system administration and customer mailing services using CampaignMonitor.
- Rollbar, based in the US, who provide real-time error tracking and debugging tools.
- Salesforce, based in the US,who provide CRM, document signing and storage services and who provide Pardot which assists with marketing services including emailing and website analytics.
- Survey Monkey for research purposes
- Twitter, based in the US, we upload data to Twitter to allow us to target advertising that is relevant to you
- Usabilla who provide customer feedback survey services
- WordPress who provide CMS, blogging and web platform services
- Zendesk, based in the US, who provide support and workflow services.
- WorldPay, based in the US, who provide payment processing services.