Academic Health Solutions is a boutique consulting firm, supporting academic institutions and their healthcare partners and commissioners of their services. We need to obtain, process and store certain personal data and sensitive personal data in order to fulfil its purpose. We are committed to keeping your personal data safe and secure in accordance with our legal obligations and as of the 25th May 2018 under the provisions of the EU General Data Protection Regulation (GDPR), Academic Health Solutions has a legal duty to ensure that this personal information is collected and used fairly, stored safely and not disclosed to any other person or organisation unlawfully. The purpose of the Regulation is ‘to protect the fundamental rights and freedoms of natural persons, in particular their right to privacy’ and in doing so it also provides Data Subjects increased protection through express new rights.
This Statement is provided by Academic Health Solutions Ltd (“Academic Health Solutions”, “we”, “our” or “us”), and is addressed to individuals outside our organisation with whom we interact, including (but not limited to) Clients, Affiliated Providers and visitors to our website (together, “you”). Defined terms used in this Statement are explained further in Section 3 below.
For the purposes of this Statement, Academic Health Solutions is the Controller and our contact details are provided in Section 14 below.
This Statement may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in applicable law. We encourage you to read this Statement carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Statement. Any significant changes will be made clear at the top of this page.
- ‘Affiliated Providers’ means companies with shared purpose and ethos that we also may collaborate with.
- ‘Client’ means a client of Academic Health Solutions.
- ‘Controller’ means the entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- ‘Data Protection Authority’ means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- ‘Data Subjects’ means individuals about whom Personal Data or Sensitive Personal Data is processed.
- ‘Personal Data’ means information that is about any individual, or from which any individual is identifiable. Examples of Personal Data that we may process are provided in Section 4) below.
- ‘Personnel’ means any current, former or prospective employee, consultant, temporary worker, intern, other non-permanent employee, contractor, secondee or other staff.
- ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- ‘Processor’ means any person or entity that processes Personal Data on behalf of the Controller (other than employees of the Controller).
- ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
- ‘Source’ means any person that provides any view or opinion regarding the qualities of any stakeholder, for any purpose.
4) Collection of your information
What do we collect?
In general, you can use this website without giving us any information. If you are one of our anonymous visitors, please bear in mind that we may still record:
i. the areas of the website that you visit; and
ii. information about your computer, such as which browser you are using, your network location, the type of connection you are using (e.g. broadband, ADSL, etc).
We do this by using cookies - although the information we gather through our cookies remains anonymous, so we cannot tell who you are.
If you communicate with us via email, depending on the nature of your enquiry/request, we may add you to our contact database.
What do we do with the information we collect?
The main reason we use this information is to provide you our website, products and services (whether available online or offline). We also use the information for:
i. internal record keeping;
ii. answering your queries;
iii. market research; and
iv. optimising our website.
5) Processing your Personal Data
Collection of Personal Data
We may collect personal data about you, such as your name, address and contact details. Examples of sources from which we may collect personal data include the following:
- We may obtain your personal data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
- We may collect personal data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
- We may receive your personal data from third parties who provide it to us (e.g., past employers; referees; and law enforcement agencies).
- We may, with your prior express written consent, conduct background checks in accordance with the protections provided by applicable law.
- We may collect or obtain personal data when you visit the Academic Health Solutions website or use any features or resources available on or through our website. When you visit our website, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our website and other technical communications information), some of which may constitute personal data.
Creation of Personal Data
We may also create personal data about you, such as records of contact with you. This personal data helps us to conduct our operations and manage our workforce.
Personal Data you provide about others
In some circumstances, you may provide us with personal data about others. Whenever you provide any such personal data, we rely on you to ensure that you have a lawful basis for providing such personal data to us, and that you have complied with applicable law and with the terms of this Statement. If you are unable to do so, please refrain from providing the personal data of third parties to us.
Relevant Personal Data
The categories of personal data about you that we may process include:
- Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; marital status; job title; employer entity; department; salary and compensation details; passport number (where applicable); visa number (where applicable); and work authorisation number (where applicable).
- Contact details: home address; work address; home telephone number; work telephone number; work mobile number; personal mobile telephone number; personal email address; work email address; and social media profile details.
- Employment records: dates and details of current and former positions held; details of current and former employers; dates of employment; job titles; job locations; subject matter experience; and details of any employment disciplinary issues or incidents.
- Details of referees: details of referees you may provide, including the relationship that you may have with each such referee, and the duration for which you have known each such referee.
- Background checks: details revealed by background checks conducted in accordance with applicable law and subject to your prior express written consent, including details of past employments, details of residence, credit reference information, and criminal record checks.
Lawful basis for Processing Personal Data
In Processing your personal data in connection with the purposes set out in this Statement, we may rely on one or more of the following legal bases:
- We have obtained your prior express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- The processing is necessary in connection with any contract that you may enter into with us;
- The processing is required by applicable law;
- The processing is necessary to protect the vital interests of any individual; or
- We have a legitimate interest in carrying out the processing, which is not overridden by your interests, fundamental rights, or freedoms. Where we rely on this legal basis, our legitimate interests are:
- our legitimate interest in the management and operation of our business;
- our legitimate interest in the promotion of our business; and
- our legitimate interest in the provision of services to our Clients.
Processing your Sensitive Personal Data
We do not seek to collect or otherwise process your sensitive personal data, except where:
- The processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- The processing is necessary for the detection or prevention of crime;
- The processing is necessary for the establishment, exercise or defence of legal rights; or
- We have, in accordance with applicable law, obtained your prior explicit consent before processing your sensitive personal data (as above, this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
Purposes for which we may process your Personal Data
The purposes for which we may process personal data, subject to applicable law, include:
- Recruitment activities on behalf of Clients: recruitment operations; providing services to our Clients; record-keeping; and performing background checks.
- Consulting: providing bespoke consulting services to Clients.
- Provision of services to you: providing our website facilities and other services to you; attending meetings with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.
- Our website: operating and managing our website; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our website.
- Newsletters and other marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and possible opportunities in which you may be interested.
- Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.
- Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
- Financial management: sales; finance; corporate audit; and vendor management.
- Surveys: engaging with you for the purposes of obtaining your views on relevant issues and topics.
- Improving our services: identifying issues with existing services; planning improvements to existing services; and creating new services.
- Future planning: succession and organisational planning, including budgeting.
6) Disclosure of Personal Data to third parties
We may disclose your personal data to other entities within our corporate group, for legitimate business purposes (including providing services to you and operating our website), in accordance with applicable law. We may also share aggregate demographic information with our Clients, trusted affiliates and advertisers for the purposes outlined in this Statement. While we make all reasonable efforts to ensure that such information is anonymised, it is possible that small amounts of your personal data may be included.
In addition, we may disclose your personal data to:
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- Our Clients, for the purposes of providing services to those Clients, in accordance with the provisions of this Statement;
- Accountants, auditors, lawyers and other outside professional advisors, subject to binding contractual obligations of confidentiality;
- Third party processors (such as providers of background checking services, IT support providers), located anywhere in the world, subject to the requirements noted below in Section 7;
- Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;
- Any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation); and
- Our website may use third party plugins or content (e.g., Facebook, Twitter, Google+ and LinkedIn). If you choose to interact with any such plugins or content, your Personal Data may be shared with the relevant third party.
If we engage a third party processor to process your personal data, the processor will be subject to binding contractual obligations to: (i) only process the personal data in accordance with our prior written instructions; and (ii) use appropriate measures to protect the confidentiality and security of the personal data.
7) International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your personal data to other members of our corporate group, and to third parties as noted in Section 6 above, in connection with the purposes set out in this Statement. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. In particular, your personal data may be disclosed to other members of our corporate group, to the extent appropriate, in connection with any Client opportunities.
8) Data security
We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.
You are responsible for ensuring that any personal data that you send to us are sent securely.
9) Data accuracy
Your personal data that we process will be kept accurate and, where necessary, kept up to date. We take every reasonable step to ensure that:
- Your personal data that we process are accurate and, where necessary, kept up to date; and
- Any of your personal data that we process that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your personal data.
10) Data minimisation
We take every reasonable step to ensure that your personal data that we process are limited to the personal data reasonably required in connection with the purposes set out in this Statement.
11) Your legal rights
Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:
- The right to request access to, or copies of, your personal data that we process or control;
- The right to request rectification of any inaccuracies in your personal data;
- The right to request, on legitimate grounds:
- erasure of your personal data that we process or control; or
- restriction of processing of your personal data that we process or control;
- The right to object, on legitimate grounds, to the processing of your personal data;
- The right to have your personal data transferred to another controller, to the extent applicable;
- Where we process your personal data on the basis of your consent, the right to withdraw that consent; and
- The right to lodge complaints regarding the processing of your personal data with a Data Protection Authority.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Statement, or about our processing of your personal data, please use the contact details provided in Section 14 below.
13) Your obligations
If, and to the extent that, you are a Source, we rely on you to ensure that you are lawfully able to disclose personal data to us, as set out in this Statement.
14) Contact details
Academic Health Solutions has taken the decision not to appoint a formal Data Protection Officer (DPO), since we do not believe that our data processing is on a "large scale", as specified in Article 37(1) of the General Data Protection Regulation and Section 2.1 of the Guidelines.
Nevertheless, we have designated the Executive Chairman as our Data Compliance Officer (DCO) – the key accountable individual for all data protection issues and queries.
If you have any comments, questions or concerns about any of the information in this Statement, or any other issues relating to the Processing of Personal Data by Academic Health Solutions, please contact:
Data Compliance Officer
Academic Health Solutions
8-10 Great George Street
This website and its content are provided as is and excludes to the fullest extent permitted by applicable law any warranty, express or implied, including, without limitation, any implied warranties of merchantability, satisfactory quality or fitness for a particular purpose.
The functions embodied on, or in the materials of, this website are not warranted to be uninterrupted or without error. You, not Academic Health Solutions assume the entire cost of all necessary servicing, repair or correction due to your use of this website.
We take all reasonable steps to ensure the accuracy, correctness and reliability of the content, but we make no representations or warranties as to the accuracy, correctness or reliability of the content.
This website may contain links to other websites; we are not responsible for any content contained on these websites or any loss suffered by you in relation to your use of such websites. You waive any and all claims against Academic Health Solutions regarding the inclusion of links to other websites or your use of those websites.