PRQR PRIVACY POLICY

This Privacy Policy has been put in place because you are either a client of PRQR Ltd, a former client of PRQR Ltd, a potential client of PRQR Ltd or have made an enquiry to or shown an interest in PRQR Ltd.
 

PRQR Ltd is committed to processing your data securely and transparently. This privacy policy sets out the types of data that we collect and hold on you (as defined under "Clients" or "Potential Clients" below). It also sets out how we use that information, how long we keep it for and other relevant information about your data.

PRQR Ltd is aware of its obligations to residents and citizens of the EU and UK under the General Data Protection Regulation (GDPR) and this privacy policy complies with the requirements of GDPR.

This notice applies to individuals who are:

  • Clients – individuals who represent (or represented) a company whom PRQR Ltd has or had a contract with to deliver services

  • Potential Clients – individuals who represent (or represented) a company whom PRQR Ltd has or is currently discussing potential opportunities or contracts with for the delivery of services. Also individuals who represent (or represented) a company who have made an enquiry to or shown an interest in PRQR Ltd and with whom PRQR Ltd is developing a relationship with in regards to business development.

 

 

Data controller details

PRQR Ltd is a data controller, meaning that it determines the processes to be used when using your personal data. PRQR Ltd has appointed Data Protection Officers who are responsible for ensuring your data is stored and processed in accordance with this privacy policy. Data Protection Officers can be contacted using info@prqr.co.uk

 

 

Data protection principles

In relation to your personal data, we will:

  • process it fairly, lawfully and in a clear, transparent way

  • collect your data only for reasons that we find proper for the course of your relationship with PRQR Ltd in ways that have been explained to you

  • only use it in the way that we have told you about

  • ensure it is correct and up to date

  • keep your data for only as long as we need it

  • process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.

 

 

Types of data we process

We may hold many types of data about you, including:

  • your personal details including your name, address, e-mail address, phone numbers

  • job title and job descriptions

  • job responsibilities

  • employer (and previous employers if known)

  • who you report to

  • your location

  • country that you reside in

  • information accessed and downloaded from company websites

  • information accessed and downloaded from third party websites

  • events attended and met with PRQR Ltd representatives, including in-person and virtual

  • records of your contact with PRQR Ltd

  • marketing material and marketing campaigns that you have shown an interest in.

We do not request, hold or process special categories of data (such health, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership and genetic and biometric data) or criminal conviction data for clients or potential clients.

 

 

How we collect your data

We would normally collect the data from you directly but we may collect data about you in a variety of ways. This will usually start when you contact us or talk to us about a business need you or your company has, but can also be when you have provided your details to access and download information from our website or shown an interest in specific topics of a marketing campaign. Further information may be collected directly from you as our relationship and correspondence increases.

In addition, data about you may be obtained from other sources including from your colleagues as the person to speak to regarding a business opportunity or need, from publicly available sources or third parties such as LinkedIn. Where this is the case, data that we hold will be limited in nature.

 

 

Why we process your data

The law on data protection allows us to process your data. For those in the EU and UK, GDPR allows us to process your data for certain reasons which are detailed below. The same reasons are applicable globally:

  • where we have your consent to do so

  • in order to perform the contracts that we are party to

  • in order for us to carry out our legitimate interests

  • in order to carry out legally required duties

  • to protect your interests and

  • where something is done in the public interest.

All of the processing carried out by us falls into one or more of the permitted reasons. Generally, we will rely on performance of contracts and legitimate interest to process your data.

We need to collect your data so that we can perform and meet our obligations under the contracts we are part to for delivering agreed services.

We also collect data so that we can carry out activities which are in the legitimate interests of PRQR Ltd. We have set these out below:

  • discuss future business opportunities

  • business planning

  • making decisions regarding marketing activities

  • market intelligence including analysing the needs and potential need within the medical devices and IVD industry

  • maintaining effective correspondence and relationships

  • ensuring effective business administration

  • achieving legal compliance and dealing with legal claims made against us

  • preventing fraud

  • ensuring our administrative and IT systems are secure and robust against unauthorised access.

 

With your consent, we collect your personal data to be able to include you on periodic company e-mails and marketing correspondence.

 

 

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out our consultancy provision in line with our contractual obligations. If you do not provide us with the data needed to do this, we will be unable to perform those duties. Similarly, we may be unable to provide or agree contracts with you.

 

 

Sharing your data

Your data will be shared with our employees within PRQR Ltd where it is necessary for them to undertake their duties and also with relevant agents and representatives on a need to know basis. This includes, for example, people working on PRQR sales, PRQR Ltd resources working on your projects, management and administration personnel.

We share your data with third parties in order to obtain legal support and business advice and when applicable, to obtain quotations on your behalf.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.

 

 

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. E.g. live cloud storage, firewalls, access control for personal information, using password protected documents and sharing systems, hard drive encryption on laptops, anti-virus and anti-malware software.

Where we share your data with third party suppliers, we ensure that the contracts between PRQR Ltd and the third party provider that your data will be held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. Where needed, a separate Non Disclosure Agreement (NDA) is also signed.

 

 

How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it for. As a consulting company, we build long term relationships with individuals and companies. The history and the contact we have with you is an important factor in the relationships that we build for business development purposes. In the ever evolving and niche market of medical device and IVD quality and regulatory consulting, individual standards, rules, directives and regulations change relatively frequently with infrequent major changes over a longer period. Therefore it is possible that a client or potential client may only require our services on an infrequent basis.

For Clients, we will hold data in order to perform our contracts for you. We hold data to continue our relationship with you by understanding services we have delivered to you, potential services we have discussed with you and as a legitimate business interest to identify future opportunities to work with you again. For residents and citizens of the EU and UK, under GDPR, we will retain data for 10 years after the last item of work in a SOW has been delivered and invoiced and/or the last opportunity for work was closed. For those who are not in the EU or UK, your data will be held for the same period of time.

For Potential Clients, we hold data to continue our relationship with you by understanding services we have previously discussed with you and as a legitimate business interest to identify opportunities to work with you in the future. For residents and citizens of the EU and UK, under GDPR, we will retain data for 10 years after the last item of work in a SOW has been delivered and invoiced and/or the last opportunity for work was closed. For those who are not in the EU or UK, your data will be held for the same period of time.

We also hold data for individuals who do not wish to hear from us and individuals we may not wish to do business with. We have a legitimate business interest in holding this data to ensure that our employees, agents and representatives do not contact those individuals inadvertently.

 

Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

 

Your rights in relation to your data

GDPR gives EU and UK citizens and residents certain rights in relation to the data we hold. Although not a right for non-EU and UK citizens and residents, we normally extend these privileges to all. These are:

  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy policy.

  • the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.

  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it

  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.

  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.

  • the right to portability. You may transfer the data that we hold on you for your own purposes.

  • the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.

  • the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact the Data Protection Officers listed above.

 

 

Making a complaint

If you think your data protection rights under GDPR have been breached in any way by us, you are able to make a complaint to a supervisory authority in the EU. In the UK, the supervisory authority is the Information Commissioner (ICO):ico@org.uk.