Privacy Notice
Health Spaces Privacy Notice (‘notice’)
Welcome to Health Spaces Privacy Notice
We know you value your privacy. When you make an enquiry, give us feedback, apply for a job, view or download a webinar, view or subscribe for our magazine or visit our website to learn more about us, you should be confident that we are only keeping the data we need to keep about you and only using that data in ways you agree to.
About Health Spaces Ltd.
Health Spaces Limited is a company registered in England and Wales under the company number 13305967. Our registered office is at Ashurst House, Bakewell Road, Orton Southgate, Peterborough, PE2 6YS
About This Notice
This notice describes how and why we collect the personal data of:
· Website visitors
· Candidates, Freelancers, Agency Workers, Consultants
· Business customers or prospects
· Webinar and Learning Hub users
· Fortis Magazine recipients and subscribers (digital and print copies)
It describes our privacy commitment and explains how we comply with data protection law.
We will alert you to important changes to our privacy notice by posting them here or contacting you directly where appropriate. For more information please contact info@health-spaces.com
FORTIS, FORTIS events and FORTIS magazine are owned and managed by Health Spaces Limited. The FORTIS data privacy policy contains more detailed information about our data processing and you should read that in conjunction with this privacy notice: FORTIS policy.
Our Privacy Commitment
We are committed to protecting the privacy and security of your personal data, only processing what’s necessary, and ensuring we strike the right balance between our business objectives and your privacy. We want to ensure you understand your rights and our responsibilities. We process your personal data:
· Lawfully: Only if we can justify it on one of the GDPR’s Lawful Bases (see Lawful Bases table below).
· Fairly and transparently: we strike the right balance between our interests and yours and we tell you what we do with your personal data.
· For a specific purpose: we won’t use your personal data for another incompatible purpose unless the law permits or requires us to.
· Using the least amount reasonably necessary.
· Ensuring it is accurate, complete and up-to-date.
· For a limited time: Only for as long as reasonably necessary, and then we either destroy it or de-identify it so it can’t be linked back to you.
· Securely: managing our people and designing our processes and technology to ensure end-to-end confidentiality, integrity and availability.
· With your rights in mind: We make it easy for you to exercise your rights (see table below).
· Within the UK/EEA: we don’t transfer your personal data outside the EEA except as permitted under Data Protection Law. We use appropriate safeguards to ensure consistent protection by third parties who support our work. Find out more in the Your Data At-a-Glance table below.
Lawful Bases Table
Lawful Basis & What this means
Consent: You have given us permission, which you can withdraw at any time. We need your Explicit Consent to process sensitive data like health-related data (Special Data) or to transfer your Personal Data outside the EEA where we don’t have another basis for doing so, or for any Automated Decision Making (‘ADM’) that has significant legal or other effects unless an exception applies.
Legitimate interests: To help fulfil a legitimate business objective after confirming we have only used what is reasonably necessary and proportionate to meet that objective and struck the right balance between our interests and yours.
Contractual necessity: To enter into or fulfil our contract, including to generate a quote.
Legal obligation: To comply with the law (e.g. tax reporting).
Vital interests: In rare instances where one of the others don’t apply but we need your personal data to protect your vital interests or those of another person. Highly unlikely.
Your Data Rights
You have various rights with respect to your personal data:
Right & What this means
Access: Receive a copy of the personal data we hold about you and confirm we’re lawfully processing it by making a Data Subject Access Request (DSAR). It’s free of charge unless your request is clearly unfounded or excessive.
Rectification: Ask us to update, complete or correct your personal data at any time if you detect an inaccuracy. In fact, we encourage you to do so.
Portability: Get any personal data you’ve given us in electronic form on the basis of Consent (or Contractual Necessity) in a common machine-readable format. We can also transfer it to a third party if you ask.
Erasure: Ask us to delete or remove personal data where there is no good reason or Lawful Basis for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to Objection. We are allowed to refuse in certain circumstances. Find out more, here.
Objection: Object to any processing we do based on Legitimate Interests. You also have the right to object where we are processing your personal data in certain circumstances.
Automated processing: Not to be subject to ADM that has significant legal or other affects.
Restriction: Suspend the processing of some of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
Withdrawal of consent: Withdraw consent at any time and we will stop processing it unless we have another legitimate basis for doing so in law. Where we rely on your consent we also explain how you can easily withdraw it.
We will need to confirm your identity and your right to access the information or exercise any of your other rights. This is to prevent personal data being disclosed to anyone who has no right to receive it. You can find out more about your rights by visiting the Information Commissioner’s Office website.
· Website Visitors
· Candidates, Freelancers & Agency Workers & Interns
· Webinar Viewers and Participants
· Fortis Magazine & Event Subscribers
· Academic Collaborators, Promoters, Corporate Partners
We want to learn what brings you to our website, what products, services and information interest you and how you engage with our content. We also want to respect your privacy and your choices. We collect what we need to help us get a general understanding of how our visitors engage with our website and to make it a more personalised experience for you.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
· Information you give us. This is information about you that you give us by filling in forms on our site health-spaces.com or by corresponding with us by phone, e-mail or during face-to-face appointments with us. It includes information you provide when you register to our website, subscribe to our newsletter (including our social media LinkedIn newsletters), search for a service, place an order, participate in discussion boards on our website or via a webinar or any other our social medial platforms linked to our brand Health Spaces Ltd and website, enter a competition, promotion or survey, join live chat with helpdesk support, use diary booking, when you report a problem with our site or when you meet with our staff to report the service problems. The information you give us may include your name, address, e-mail address and phone number, gender, financial and credit card information, job title, work place, personal description, and photograph.
· Information we collect about you from our site. When you visit the site we will automatically collect the following information
o technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
o information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),methods used to browse away from the page, and any phone number used to call our customer service number.
· Information we receive from other sources. This is information we receive about you if you use any of the websites we operate for other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, telemarketing company, mailing companies and courier companies].
· Information we receive from database organisations. This information we receive about you from third party organisations will be stored securely as it is described in this policy. We will notify you when we receive information about you from them and how we intend to use that information.
· We also receive personal information indirectly, from the following sources in the following scenarios:
o Where it is publicly available on the website of the organisation you represent or a professional register and the communication is relevant to the organisation you work for.
o Where it is publicly available – for example LinkedIn in order to communicate with you regarding our services.
o Third parties associated with our websites are as follows:
- Google Analytics
- Meta (Facebook)
- (X) Twitter
HOW WE USE THE INFORMATION
We will always use your personal information lawfully. Most commonly, we will use your personal information in the following circumstances:
· Where we need to perform the contract we have entered into with you (for instance a healthcare design and build service);
· If you are accessing resources from our Learning Hub e.g. a webinar; to send a webinar recording and collect feedback from a webinar that you have registered to; sending out our newsletter if you have subscribed to the mailing list.
· Where we need to comply with a legal obligation.
· 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.
We may also use your personal information in the following situations, which are likely to be rare:
· Where we need to protect your interests (or someone else’s interests).
· Where it is needed in the public interest or for official purposes.
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
· Information you give to us.
We will use this information:
o To carry out our obligations arising from the contract entered into between you and us and to provide you with the information, products and services that you request from us;
o to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
o to provide you, or permit selected third parties to provide you with information about goods or services we feel may interest you.
o If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.
o If you are a new customer, we will contact you by electronic means only if you have requested to be contacted e.g by completing an online form via the website or by you calling Health Spaces directly.
o to notify you about changes to our service;
o to ensure that content from our site is presented in the most effective manner for you and for your computer.
· Information we collect about you.
We will use this information:
o to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
o to provide and improve content on our site to it is presented in the most effective manner for you and for your computer or device;
o to allow you to participate in interactive features of our service, when you choose to do so;
o as part of our efforts to keep our site safe and secure;
o to ensure you are able to access resources via our Learning Hub, ensuring the content is relevant to you and to improve content available;
o to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
o to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
· Information we receive from other sources (described above).
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
· If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.
· Change of purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the UK. If we do, you can expect a similar degree of protection in respect of your personal information.
You agree that we have the right to share your personal information with:
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
· Selected third parties including:
o business partners, suppliers and sub-contractors, but only for the performance of any contract we enter into with you;
o advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Note: We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
o analytics and search engine providers that assist us in the improvement and optimisation of our site;
The following third-party service providers process personal information about you for the following purposes:
· E-shot marketing providers
· Couriers and delivery services
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will also disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
· If the business is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of sale and other agreements; or to protect the rights, property, or safety of Health Spaces, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure server called Insight CRM system. Only selected people within Health Spaces are able to access your information and use for the purposes described above.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
TRANSFERRING INFORMATION OUTSIDE THE UK
Rarely we might need to transfer the personal information we collect about you to countries outside the UK such as USA or the Philippines.
Transfer is necessary in order to perform our contract with you. This includes transfer to organisations engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. There is an adequacy decision by the European Commission in respect of those countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.
If you require further information about these protective measures, you can request it from our data privacy manager.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information stored at our CRM to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
HOW LONG WE RETAIN YOUR PERSONAL DATA
We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. In order to comply with law and to deal with future issues that might arise, we retain all personal data for a period of 10 years from collection. 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.
We may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
YOUR RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
· Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes at any point in the future.
· Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
· Request access to your personal information (commonly known as a “data subject access request“). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing, which is performed safely and no personal information is left (see below).
· Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our privacy data manager in writing.
· No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
· Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
· Issues and complaints
If you are not satisfied with how Health Spaces handles your personal data you can raise a complaint and we will take action to address and resolve the issue. If you are not satisfied you also have a right to contact ICO that has a general duty to investigate complaints from members of the public. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. If you have any questions about this privacy notice or how we handle your personal information, please contact Health Spaces at info@health-spaces.com.
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. You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
Organisation name: Health Spaces Limited
Registration reference: C1191811
CHANGES TO OUR PRIVACY POLICY
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our data privacy manager via getting in contact here.
Updated 15th January 2024.