Privacy Policy

Source Market Access Limited t/a Source Health Economics (“we”, “us”, “our”) 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 we connect with when doing business.

Please read this privacy notice carefully and ensure that you understand it.

Information about us

Source Market Access Limited t/a Source Health Economics is registered in England under company number 10284529. Registered address: Source Health Economics is a Data Controller (ICO reference number ZB400451)

What does this policy cover?

This Privacy Policy applies to our use of your personal data where not covered by a specific privacy notice. You will be issued with a separate and specific privacy notice when you become an employee with us.

What is personal data?

‘Personal data’ is defined by the General Data Protection Regulation (EU Regulation 2016/679; 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 be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the contact details provided at the end of this policy
  • 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

Further information about your rights can be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the contact details provided at the end of this policy.

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?

The initial personal data we collect about you may be through our website, https://source-he.com/get-in-touch/ (“Our Site”) when you complete our web form. Subsequently, additional personal data may be collected via other channels. Regardless of how we collect personal data, we will only collect it and use it in the ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Data subjects and data collected

How we collect the data

Job Applicant Information:

  • Personal contact details, such as name, title, addresses, telephone numbers, and personal email addresses
  • Recruitment information (including copies of references, interview notes and opinions taken during and following interviews, your CV, personal statement, and other information included in a CV or cover letter or as part of the application process including applications for alternative roles whilst employed)
  • Right to work documentation, which may include a copy of your driving licence, other photographic ID such as a passport, birth certificate, resident permit or a copy of a visa. The exact documentation that we require is based on government guidance and will depend upon your individual circumstances. We will provide you with details should this be relevant to you
  • A copy of your signature incorporated in copies of documents you sign during the recruitment process
  • Copies of presentations and any other materials you prepare as part of the application process

We typically collect personal information about you through the application and recruitment process, either directly from you or sometimes from a recruitment agency, background check provider, or other sources available, including the internet.

 

We may sometimes collect additional information from third parties including former employers, former professional institutions you have attended, or other background check agencies.

 

External Talent of Interest

  • Contact details
  • Contact history
  • Current position
  • Career interests and goals

Directly from you after we connect with you via professional social media platforms such as LinkedIn, and you express an interest in hearing about job opportunities at Source Health Economics 

Potential External Expert Information:

  • Contact details, such as full name, email address and phone number
  • Basic data on your role, such as country, employer, job title/respondent type, sub-type, and specialty
  • Correspondence history & outcome of contact

You are identified online e.g. via LinkedIn or key word searches using internet search engines such as Google

You are recommended by another individual who has been approached to participate in one of our projects

 

Prospective Client/Collaborator Information:

  • Contact/profile information, including:
  • Name
  • Email address
  • Telephone number
  • Job title
  • Company
  • LinkedIn URL
  • Areas of interest (therapy area, market access services)
  • Your position in the structure of your organisation
  • Company history
  • Correspondence
  • Consent to receive information, news and/or events

When you:

  • Speak with us at a trade show/networking event, or
  • Make an enquiry to one of our email addresses, via a procurement platform, via Our Site or social media channels, or
  • Connect with us on social media, or
  • Are referred to us by one of your colleagues to participate in an existing project or discuss a new opportunity

Target Client Information:

  • Contact/profile information, including:
  • Name
  • Email address
  • Job title
  • Company
  • LinkedIn URL
  • Your position in the structure of your organisation

When we conduct our strategic account management activities and identify you via online sources as working for one of our client companies in a role that may commission, approve, or be involved in services we provide

Client Information:

As per prospective client, and in addition:

  • Invoice details, bank account details, accounting records
  • Feedback in relation to projects commissioned with us and proposals we have submitted
  • Signed contracts or equivalent

When you request a proposal or purchase our 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 provide, services to us.

Website Users

We will only obtain and store your personal data when you complete a web-form on Our Site, and at this point you will be designated as one of the Data Subjects above

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.

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 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.

When making a decision about your recruitment or appointment.

To determine the terms on which you work for us.
  • To facilitate effective personal contact
  • To respond to an enquiry you have made of us
  • To understand your interest in one or more of our services
  • To understand your interest in job opportunities
  • To invite you to participate in a project as an external expert
  • To analyse and improve our services and communications and to monitor compliance with our policies and standards
  • 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 accounting records, compliance checks

For purposes required by law.

 

Checking you are legally entitled to work in the UK.

 
  • To send you a paper, report or other thought piece you have requested
  • To communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services, events, and initiatives

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 or post with information, news, and details of 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 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 only use your personal data for the purpose(s) for which they were originally collected, unless we reasonably believe that another purpose is compatible with that or those original purpose(s), and we 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 that allows us to do so.

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 they were 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 they are kept):

Data Subject

How long we keep it (by type of data)

Job Applicant Information

Personal data related to unsuccessful applications will be retained for 6 months, from the end of the calendar month in which the last interview/contact took place

 

External Talent of Interest

Either you will become a Job Applicant, or your personal data will be retained for 12 months, from the end of the calendar month in which we last had direct contact with you

Potential External Expert Information

Up to 90 days after the project that you were invited to participate in completes, unless you give us your consent to store your data for longer

Prospective Client/Collaborator information

Contact/Profile Information: 

3 years from the January following the last contact from one of our team

Or, 3 years from the January following when you became known to us via one of your colleagues

 

Consent to receive information, news and/or events: until consent withdrawn or contact/profile information deleted

Target Client Information

Contact/Profile Information:

 Information is regularly re-verified and out of date information is not retained

Client Information

Financial records: 6 years after the end of the financial year in which the transaction took place

 

Signed contracts: 6 years after the termination or expiry of the contract/engagement, or other period defined in the contract

 

Project files: for as long as agreed within the project contract or Master Services Agreement

 

Contact/Profile Information: 10 years from the January following the closure of a project with you or the submission of an unsuccessful proposal to you, unless you are designated a Prospective Client at that point in time

 

Feedback: 2 years from collection of the data

Client Respondent Information

Contact File: Refer to Prospective Client

 

Attributable Primary Data: Up to 90 days after the project completes, unless attributable data were provided in project deliverables, and then these are retained for as long as agreed in the contractual terms for the project

Supplier Information, including Contractors:

Financial records: 6 years after the end of the financial year in which the transaction took place

 

Signed contracts and assessment forms: 6 years after the termination or expiry of the contract/engagement, or other period defined by the contract

 

Contact information: up to 6 years from the end of the financial year in which the contract/last engagement ended

How and where do you store or transfer my personal data?

We will store your personal data within the UK.

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 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

Do you share my personal data?

We may sometimes contract with the following third parties to supply certain services. These third parties are listed in the table below:

Recipient

Activity carried out

Accountants

(data processor)

Annual financial accounts

Accounting Software

(data processor)

Administer payment of invoices and raising of invoices

Business Management Software

(data processor)

Customer relationship management and project management

Communication System
(data processor)

Send / receive electronic communications; make / receive web-calls

Information Storage System

(data processor)

Hosting of digital business and project files

Survey Tool
(data processor)

Collect feedback on our services 

Website Design & Hosting
(data processor)

Website hosting, design and support including collection of enquiries via web-forms

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 we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used those data, as specified in this Privacy Policy.

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 those personal data and for a copy of them (where any such personal data are 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 1 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 3 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 protected]
Postal address: Source Health Economics, 226 Banbury Road, Summertown, OX2 7BY

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 our website. This Privacy Notice was last updated on 4th October 2022.