CMM PRIVACY AND COOKIE NOTICE

CareFlow Medicines Management Ltd. (hereafter “CMM”, “we” or “us) take your privacy very seriously and would advise you to read this Privacy Notice closely. This Privacy Notice may change from time to time, so please check it frequently.

This Privacy Notice sets out how your personal data will be processed as controlled by CMM, 1 Aurum Court, Sylvan Way, Basildon, Essex, SS15 6TH.

We only collect basic personal information from visitors to this website through the use of online forms and when you email us. We may also process your personal data as you provide directly to us or as we receive from our trusted partners in the Health Service Industry.

This Privacy and Cookie Notice outlines:

What data we collect

How long we keep it

Where we transfer and store it

Our use of Cookies

Your Individual Rights

Data Security

Modifications and Changes

If you have any queries regarding this policy or the use of your personal information, please contact us at: dpo.intl@wellsky.com

What data we collect

Communications

We use your personal data to improve the user experience of our website and provide a better service. We also use it for staying in touch with you. By contacting us through our website you agree for us to contact you via your email with any information you request.

Additionally, by submitting your email and subscribing on our website you consent for us to send you updates relating to products and services offered by CMM. If you are an existing customer of CMM, we may also contact you in the context of sending you customer newsbites and updates.

We may also collect your personal data if you provide it to us directly, including at any events organised by CMM or our partners.
We will hold the following personal data in the context of such communications:

• Full name.
• Email address.
• Organisation.
• Phone Number.

We will process this data on the basis of your consent in signing up to receiving information about our products and services and/or our legitimate interest in keeping current customers informed of our products and connecting with our business partners. You are able to opt out from emails at any time via the “Unsubscribe” link present at the bottom of every email communication we send. We will contact you in relation to services we feel will be useful for you by email or by phone.

Recruitment/HR

We will also process any data you send us for recruitment purposes, either through our website or in other locations where you see our jobs advertised, in relation to any vacancies that we advertise. We process this with your consent and/or our legitimate interest in talent-pooling our candidates.

This will include:

• Full name
• Email address
• Telephone number
• Employment history
• Sensitive personal data, including racial, ethnic, sexual, religious and/or disability information
• Any other details in your CV

We process this data on the basis of your consent. We may also process additional data later on in the recruitment process, which will be processed on the basis of your consent and/or employment contract, or where we have a legal obligation or it is in the public interest to do so (such as for immigration or diversity monitoring purposes). This will be further detailed in your employment contract.

Healthcare Services

We may also process data of our clients’ patient data in the course of providing IT support for the maintenance of healthcare systems provided by our healthcare clients. This data will include:

• Patient Hospital Number

We will only process this data on the basis of the performance of our contract with the relevant healthcare client. This processing is further governed by the Privacy Notice and/or Privacy Policy of the relevant healthcare client.

How long we keep it

Communications

We will keep your personal data received when you subscribe for updates with us or contact us in the context of products or services, or to become a CMM partner, for two years, after which we will ask you again for consent to continue to receive marketing information from us.

Recruitment/HR

We will keep data you send us in relation to vacancies for the duration of your application and up to six months after in order to offer you new opportunities, unless you opt out of this, or extend this

period with your consent. We will ensure that any sensitive personal data that we collect from you is anonymised after this period. We may also hold personal data for longer periods if your application is successful, which will be further detailed in your employment contract and other relevant policies.

Healthcare

We will hold any patient data that we process on behalf of our healthcare clients for the duration of the task carried out for the healthcare client, after which it will be deleted from all systems we operate. CMM may retain a patient’s hospital ID number if this is needed in relation to the need to log issues related to troubleshooting IT errors faced by Healthcare Client, although this will be converted to an internal ID number where possible, and as soon as possible.

Where we transfer and store it

In addition to on our systems, the information that you provide to us may be stored in secure servers which are operated by trusted providers.

We ensure that all of our providers to take measures that clearly set out their commitment to respecting your Individual Rights, protecting your personal data – including not using it for any purpose other than for the agreed purposes – and their commitments to assisting us to help you exercise your Individual Rights.

Our trusted cloud providers, which we may use to store your personal data, include Salesforce and Jira. Salesforce and Jira use servers based in the United States of America. Salesforce and Jira have certified under the EU-U.S. Privacy Shield certification, which allows us to legally transfer your personal data to them.

You can view Salesforce’s Privacy Policy here and JIRA’s Privacy Policy here.

Our use of Cookies

At CMM, we use cookies to allow us to personalise your visits to this site, keep track of your preferences and learn about the way you use the site.

A cookie is a small text file that is downloaded onto your computer when you visit our website and allows us to recognise you as a user. Typically, these contain two pieces of information: a site name and unique user ID. All information these cookies collect is aggregated and anonymous. Cookies are essential to the effective operation of our website. Cookies make the interaction between you and the website faster and easier. Cookies may also be set by the website you are visiting (first party cookies) or they may be set by other websites who run content on the page you are viewing (third party cookies).

• CMM uses cookies:
• that are strictly necessary to enable you to move around our websites or to provide certain basic features;
• to enhance the functionality of the website by storing your preferences;
• to monitor the popularity of sections of our website;
• to help improve the performance of our website on your device.

We require you to accept or decline certain cookies by accepting or declining our Cookie Consent Notice when first accessing our website. By accepting and using our websites you consent to our use of cookies as updated from time to time and the cookies we use will be stored on your device (unless this functionality is rejected or disabled by your browser). You may access our Cookie Consent Notice to decline cookies at any time subsequently.

Additionally, you may delete and block all cookies from any website, within your web browser settings if necessary. Please be aware that restricting or deleting cookies will impact on the functionality of the site.

Non-Essential Cookies:

A list of the non-essential cookies we use on the website are detailed below:

Google Analytics: 

analytics.js ( ga, _gat), used by Google to generate web analytics and for tracking how you use the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The information generated by the cookie will be forwarded to Google servers in the U.S. for statistical analysis purposes only.

Marketo:

Marketo Munchkin (_mkto_trk): This cookie is set by Marketo. This allows a website to track visitor behaviour on the sites on which the cookie is installed and to link a visitor to the recipient of an email marketing campaign, to measure campaign effectiveness and to gain information about how they are using a website for communication purposes. Tracking is performed anonymously until a user identifies themselves by submitting a form.

We may also record your IP Address for website audience monitoring purposes.

Your Individual Rights

You have several individual rights in relation to your personal data that we collect, which we are committed to respecting. In particular, you have the right to:

• Request a copy of your personal information
• Request any inaccuracies in your personal information be corrected
• You may also ask to object or restrict the processing of your personal data and have your personal information erased, where appropriate.

Additionally, where we collect your personal details for contacting you in relation to our products or services or becoming a CMM partner, you have the right at any time to notify us that you no longer want to receive this information.

If you wish to raise a complaint on how we have handled your personal data, you can contact our office at dpo.intl@wellsky.com and we will investigate the matter.

Opting Out of Cookies

You can choose to accept or opt out of cookies via our Cookie Consent Notice. Please note that if you prefer to block some or all of the cookies CMM uses, you might lose some of our website’s functionality.

Data Security

CMM uses reasonable administrative, technical, personnel and physical measures to safeguard personal information in its possession against loss, theft and unauthorised use or modification. While we strive to protect your personal information, you will understand that we cannot guarantee the security of any information transmitted to us over the internet. Therefore, please do not submit personal information to us online unless you accept the security risks of doing so.

Modifications and Changes

This Privacy Notice was last updated on 15th September 2021. Any changes made to this Privacy Notice will be updated on our website and you will be notified by email if necessary and appropriate.