1.1 Solutions for Public Health (SPH), which is part of NHS Arden and Greater East Midlands Commissioning Support Unit (Arden & GEM CSU), is committed to safeguarding the privacy of visitors to the SPH website, in accordance with Data Protection Regulations.
1.2 This policy applies where SPH is acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 This policy does not cover all websites that can be linked to from our website, so you should always be aware when moving to another website and read the privacy statement on that website.
1.5 In this policy, “we”, “us” and “our” refer to Solutions for Public Health (SPH)
How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal basis of the processing.
2.2 We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and our own webserver log files. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and providing backups.
2.3 We may process information contained in any enquiry you submit to us via email, telephone, post or our website regarding SPH, its products and/or services, its partnership and associate opportunities (“enquiry data“). The enquiry data may be processed for the purposes of responding to your enquiry about SPH, offering, marketing and selling relevant products/services to you, and notifying you of suitable partnering and associate opportunities at SPH. The legal basis for this processing is consent.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications, newsletters and/or bulletins about SPH. The legal basis for this processing is consent.
2.5 We may process information contained in or relating to any communication that you send to us using the website contact page (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact page. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for processing correspondence data from our website contact page where you have ticked the Consent box is consent. For all other forms of correspondence the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
Providing your personal data to others
3.1 We may disclose name or email address information to our suppliers or subcontractors insofar as reasonably necessary for fulfilling your request to us or the technical investigation of issues relating to our website.
Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 We will hold your personal data on our systems for as long as you use the service you have requested, and remove it in the event that the purpose has been met or when you no longer wish to continue your subscription to SPH communications.
Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse, alteration of or unauthorised access to your personal data.
5.2 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, or from our webserver to our outgoing mail server will be protected using encryption technology.
5.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
6.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data by written notice to us by email and post as published on the SPH website.
7.1 Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies.
7.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
7.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
(a) Google uses the _gid cookie to distinguish users on our website
(b) Google uses the _ga cookie so that its Google Analytics service can collect information about how visitors navigate and use our website which we use to help improve our website.
(c) Google uses the _gat cookie to manage how often data is sent to Google Analytics.
8.2 In order to provide interesting content on our website we may use ‘plug ins’ or embedded media, for example, YouTube videos, links to share content with popular social media sites such as LinkedIn and Twitter. The suppliers of these services may also set cookies, known as ‘third-party’ cookies’ on your device when you visit the pages of our website where we have used this type of content. Third party cookies are delivered on behalf of their respective organisations and are beyond the control of SPH.
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You should however be able to obtain up-to-date information about blocking and deleting cookies via the ‘Help’ function within your browser.
Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to restrict or block cookies on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you may not be able to use all the features on our website.
10.1 This website is owned and operated by SPH.
10.2 Our business address is 1 Wootton Edge Barns, Holly Bank, Wootton-by-Woodstock, Oxfordshire, OX20 1AE.
10.3 You can contact us:
(a) using our website contact form;
(b) by email, using the email address published on our website from time to time;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by post, to the postal address given in 10.2 above.