Background
Gatehouse ICS Ltd 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 all of our customers, contacts, associates and employees 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.
Please read this privacy notice carefully and ensure that you understand it. Your acceptance of the use of Cookies when you visit https://www.gatehouse-ics.com/ (“Our Site”) is deemed to occur when you have selected your preferred Cookie options that are presented to you via our Cookie pop-up.
1. Information About Us
Gatehouse ICS Ltd.
Private Limited Company registered in England under company number 11835207
Registered address: 35 Cwmamman Road, Garnant, SA18 1NH, United Kingdom
Main trading address: 35 Cwmamman Road, Garnant, SA18 1NH, United Kingdom
VAT number: 289750251
Data Protection Lead: Christie Harper
- Email address: christie.harper@gatehouse-ics.com
- Telephone number: +44 0 1269 240100
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
These are the data subjects this privacy notice covers:
| Data Subject | Description |
|---|---|
| Applicant | A person who has applied for a role at Gatehouse ICS Ltd. |
| Employee | A person who is or has been employed at Gatehouse ICS Ltd. |
| Customer | A person representing a business that is a client/customer of Gatehouse ICS Ltd. |
| Market Research Particiapant | A person who has provided insights on a project. |
| Potential Customer | A person representing a business that is a potential client/customer of either Gatehouse ICS Ltd or one of its Customers. |
| Potential Market Research Participant | A person who could potentially provide insights on a project. |
| Supplier | A person representing a business that supplies products or services to Gatehouse ICS Ltd. |
| Website Visitor | A person who visits the Gatehouse ICS Ltd website. |
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “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 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.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we always work to uphold are:
- The right to be informed about our collection and use of your personal data. This Privacy Notice 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 details in Part 12.
- The right to access the personal data we hold about you. Part 10 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. Please contact us using the details in Part 12 to find out more.
- 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 details in Part 12 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 is 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.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
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 details in Part 12.
5. What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table:
| Ref | Data Collected | Data Subject | How We Collect the Data |
|---|---|---|---|
| A | Name information including title | Employee Applicant Customer Supplier |
Data subject |
| B | Identity information including date of birth and gender | Employee | Data subject |
| C | Home address information | Employee Applicant Market Research Participant |
Data subject |
| D | Contact information including work address, phone number, email address | Employee Applicant Customer Supplier |
Data subject |
| E | Business information including business name, profession, job title | Employee Applicant Customer Supplier |
Data subject |
| F | Payment information including bank account details, tax details | Employee Market Research Participant Supplier |
Data subject |
| G | National Insurance (or equivalent) details | Employee Applicant Market Research Participant |
Data subject |
| H | Pension information | Employee | Data subject |
| I | Profile information including qualifications employment history, annual leave, sickness absence, performance information | Employee Applicant |
Data subject |
| J | Next of kin and health information | Employee | Data subject |
| K | Log-in details of business-related apps/programmes, services and software | Market Research Participant Potential Customer Potential MR Participant |
Data subject |
| L | Identity information including name, title) | Market Research Participant Potential Customer Potential MR Participant |
|
| M | Contact information including country of work | Market Research Participant Potential Customer Potential MR Participant |
|
| N | Contact information outside of LinkedIn (e.g. email address or phone numbers) | Market Research Participant Potential Customer Potential MR Participant |
Data Subject (via LinkedIn, Survey Monkey, email or website) |
| O | Business information including business name, profession, job title, prior roles | Market Research Participant Potential Customer Potential MR Participant |
|
| P | Technical information including Google Analytics Client ID, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website | Website Visitor | Access and use of our website |
6. 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 use your personal data, and our lawful bases for doing so:
| Data Collected | How we will use your data and our lawful basis for doing so |
|---|---|
| A | Personnel records, to recruit staff, to pay and contract with employees, customers and suppliers. In a restricted access SharePoint folder, in our finance software (Xero) or our project management/CRM (CMAP). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent (Applicant only) Article 6(1)(b) - contract |
| B | Personnel records and to recruit staff. In a restricted access SharePoint folder, in our finance software (Xero) and our project management/CRM (CMAP). Article 6(1)(a) - consent Article 6(1)(c) - legal obligation (Health & Safety) |
| C | Personnel records and to contract with employees and market research participants. In a restricted access SharePoint folder and in our finance software (Xero). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent Article 6(1)(b) - contract |
| D | Personnel records, to recruit staff and to pay and contract with employees, customers and suppliers. In a restricted access SharePoint folder, in our finance software (Xero) or our project management/CRM (CMAP). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent Article 6(1)(b) - contract |
| E | Personnel records, to recruit and develop staff, to pay and contract with employees, customers and suppliers. In a restricted access SharePoint folder, in our finance software (Xero) or our project management/CRM (CMAP). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent Article 6(1)(b) - contract |
| F | Personnel records, to pay and contract with employees, suppliers and market research participants. In a restricted access SharePoint folder, in our finance software (Xero). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent Article 6(1)(b) - contract |
| G | Personnel records, to recruit staff, to pay employees, and to report on French market research participants. In a restricted access SharePoint folder, in our finance software (Xero). DocuSign (electronic signatures) is used for contracts. Article 6(1)(a) - consent Article 6(1)(b) - contract |
| H | Personnel records. In a restricted access SharePoint folder and in our finance software (Xero). Article 6(1)(a) - consent Article 6(1)(b) - contract |
| I | Personnel records, to recruit and develop staff and to pay and contract with employees. In a restricted access SharePoint folder, in our finance software (Xero) or our project management/CRM (CMAP). Article 6(1)(a) - consent Article 6(1)(b) - contract |
| J | In case of health emergencies. In a restricted access SharePoint folder, or our project management/CRM (CMAP). Article 6(1)(c) – legal obligation (Health & Safety) |
| K | With consent, for conducting reasonable business activities. In a restricted access SharePoint folder. Article 6(1)(a) - consent |
| L | Asking for consent to connect and discuss on LinkedIn. The data subject has the right to reject the LinkedIn connection request and communication is made through LinkedIn on the basis of consented communication for this purpose. A contact can also be identified via public domain internet searching: Organisation websites, membership lists of committees and organisations. Contact details can be submitted on Survey Monkey. If request to connect is rejected or denied or un-responded the information will be deleted from our records after the specified time. If connection and communication is accepted, we will gain consent for keeping or passing on any information. Via any method, if kept and it contains contact information e.g. email address, it will be stored in a restricted access SharePoint folder, or our project management/CRM (CMAP). Article 6(1)(f) - legitimate interest |
| M | |
| N | |
| O | |
| P | To understand a user journey on our website consent to cookies is requested on the website. Article 6(1)(a) - 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 via LinkedIn or by email or telephone if you have provided these to us. 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. We will always obtain your express opt-in consent before sharing your contact details with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and 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 details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. 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 the following periods:
| Data Collected | Data Subject | How long we will keep your data |
|---|---|---|
| A | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| Customer Supplier | 6 years post contract end | |
| B | Employee | 6 years post employment end |
| C | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| MR Participant | 6 years post contract end | |
| D | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| Customer Supplier | 6 years post contract end | |
| E | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| Customer Supplier | 6 years post contract end | |
| F | Employee | 6 years post employment end |
| MR Participant Supplier | 6 years post contract end | |
| G | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| MR Participant | 6 years post contract end | |
| H | Employee | 6 years post employment end |
| I | Employee | 6 years post employment end |
| Applicant | 6 months post interview for unsuccessful applicants | |
| J | Employee | 1 year post employment end |
| K | Employee | 1 month post employment end |
| Customer | Immediately at contract end | |
| L | MR Participant Potential Customer Potential MR Participant |
If connection request not accepted on LinkedIn or direct email we will retain this information to prevent future targeting for 6 months or through the length of a contract and 3 months after the end of the contract (if we are reaching out on behalf of a customer). If contact details are provided, we keep these on file indefinitely with annual checks to see if retention is reasonable. If connected via Survey Monkey, we will keep contact details for the life of the project and will be deleted 3 months after. |
| M | ||
| N | ||
| O | ||
| P | Website Visitor | 14 months post website use |
8. How and Where Do You Store or Transfer My Personal Data?
We will store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
We may store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
We may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We may share your data with external third parties, as detailed below in Part 9, that are based outside of the EEA. The following safeguards are applied to such transfers:
We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.
Where we transfer your data to a third party based in the US, such as Xero, the data is protected through standard contractual clauses. Prior to 2020 the EU-US Privacy Shield was in operation and in 2022 a new Trans-Atlantic Data Privacy Framework has been agreed. This requires that data protection standards are at similar levels to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 12 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
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, agents, contractors, and other third parties 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;
- obtaining informed consent when we are communicating any information provided by you within the LinkedIn platform to parties outside the platform or when we hold such data on file (restricted access SharePoint).
9. Do You Share My Personal Data?
We may share your personal data with other companies as shown below.
| Recipient | Activity Carried Out | Sector | Location |
|---|---|---|---|
| We work on behalf of companies (e.g. consultancies to pharma) who may wish to partner with, collaborate with, sell services to or ask the advice of professionals meeting certain criteria. | We identify these individuals through LinkedIn, correspond with consent via LinkedIn and pass their details on if provided and if consent is given to do so. | Life Sciences / Pharmaceuticals | Global |
| Transparence Sante | Legal requirement to report all payments for market research involvement of doctors and pharmacists carried out in France who are actively employed by a French healthcare organisation. | Government | France |
| Xero: Accounting Software | Provision of accounting/payroll software | Financial / Information Technology | United States |
| CMAP: Project Management and CRM software | Project details and contact details | Professional Services | United Kingdom |
| DocuSign | Electronic signatures and information gathering for contracts with Employees, Suppliers and Market Research Participants | Information Technology | Europe |
| Microsoft Office 365 (SharePoint) | Email, File storage | Information Technology | United Kingdom |
| Survey Monkey | Online Surveys | Information Technology | Europe / United States |
If any of your personal data is shared with 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 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
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 it, 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.
10. 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”.
Contact details for subject access requests are shown in Part 12.
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 20 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.
11. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site. In addition, Our Site uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site.
12. 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 Christie Harper):
- Email address: christie.harper@gatehouse-ics.com
- Telephone number: +44 0 1269 240100
13. 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 the website and by email. This Privacy Notice was last updated on 20/11/2023.