GDPR Privacy Policy

Sigma Pharmaceuticals Plc, company number 01561802 and registered office at First Floor Roxburghe House, 273-287 Regent Street, London, W1B 2HA and its associated companies understands how important your personal information is to you and we wish to be transparent on how we use your personal data in this privacy policy.  This privacy notice is in compliance with General Data Protection Regulations coming into force on 25 May 2018.  In the course of our business dealings with you, we collect information about you when you communicate with us in person via our representatives, by phone, by letter, via our website or any other means.

1                 What is the purpose of this document?

1.1             This Privacy Notice describes how we collect and use your personal information during and after your business relationship with us.  We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you.

1.2             This notice applies to prospective, current and former customers and suppliers. Please note that we have a separate Recruitment, Staff and Contractors Privacy Notice which is available to all our prospective and current employees, workers, agency workers, consultants, directors, members, agency staff, temporary staff, work experience and volunteers and others collectively referred to as ‘Staff’.

1.3             It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

1.4             We reserve the right to update this privacy notice at any time, and we will make a new privacy notice available to you on this website or by request when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

1.5             We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at HD House, Imperial Way, Watford, Hertfordshire, United Kingdom, WD24 4LQ or by email: dpo@sigmaplc.com

2                 How do we collect information about you?

2.1             We will collect data regarding you or your organisation, however there may be instances where we may collect personal information direct from you when you apply to open an account either as a customer or a supplier with us, and in the course of this service-related activities throughout the period of this business relationship and beyond where required by law, as set out in more detail, below.

2.2             We also collect information about supplier and customers from third parties, such as credit reference agencies or other background check agencies, Company House, as well as online information regarding you and the company you represent. All new accounts are subject to  status and satisfactory credit assessment; in order to progress with your application we will make a search with a credit reference agency when required.

2.3             Occasionally, we may collect information about you from public sources, including social media sites such as Linked-in, Twitter, Instagram if we deem it necessary in order to conduct business with you.

What information do we hold?

2.4             Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  There are special categories of more sensitive personal data which require a higher level of protection.

2.5             We will collect, store and use the following categories of personal information about you:

2.5.1        Your name, date of birth and your home address for accounts relating to sole traders and ordinary partnership

2.5.2        Your contact details ( eg email address, phone number, your mobile numbers where you have provided this to us instead of your business mobile number).

2.5.3        Your bank details and trade and credit references

2.5.4        Your photographs or video or visual recording taken at trade shows or when visiting our site.

2.5.5        CCTV footage when visiting our premises ( for more details please click here to view ‘Our CCTV Policy’.

2.5.6        In some instances we may request personal information which is deemed to be sensitive personal data (or special category data) such as dietary restrictions/requirements for the purposes of organising catering for meetings and certain events organised by us or for us. Inadvertently this information may identify your religious beliefs or medical conditions. This information may be shared with third parties such as our caterers to enable us to cater for you (see 5 below).

2.5.7        Third parties may share personal information about you and your family where consent has been obtained ( and parental consent for children under the age of 16)- for example Citibond sharing information such as travel, dietary requirements and accommodation arrangements. Under these circumstances Sigma Pharmaceuticals PLC, depending on the route of booking, can jointly be a Data Controller or a Data Processor. Your rights under this policy are not affected by this and you may withdraw your consent at any time (Paragraph 11).

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3.1             If you fail to provide certain information when requested, we may not be able to carry out the business transactions and perform our contract with you (such as selling or buying goods from you), or we may be prevented from complying with our legal obligations such as with HMRC, MHRA, HM Customs and Excise.

3.2             It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us. Please inform the DPO of any such changes in writing.

4                 How we will use information about you

4.1             We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

4.1.1        Where we need to perform the contract we have entered into with you, including processing and storing your orders ( for customers) or our purchase orders (for suppliers).

4.1.2        Where we need to comply with a legal obligation.

4.1.3        Where it is necessary for our legitimate interests (or those of a third party) and your interests and your fundamental rights do not override those interests. From time to time we may send you information that may be of interest to you to improve our business relationships such as special offers and information on Sigma conferences and other sponsored activities. Examples include AMEX, CITIBOND, CHARITY EVENTS and GOLF DAY. Please let us know if you wish to be excluded from such correspondence.

4.2             We may also use your personal information in the following situations, which are likely to be rare:

4.2.1        Where we need to protect your interests (or someone else’s interests).

4.2.2        Where it is needed in the public interest.

4.2.3        In exceptional circumstances with your consent.

4.3             Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.  Where we rely on legitimate interests these legitimate interests are:

4.3.1        To ensure the smooth running of our business relationship with you.

4.3.2        To allow us to process your enquiries and commercial transactions with us.

4.3.3        Managing our contractual relationship with you  and to allow you to manage your relationship with us.

4.4             We use your personal information as follows:

4.4.1        We may use your name, contact or email address to contact you as part of dealing with business matters such as ordering, customer service matters, product quality complaints, feedback and other business related communications.

4.4.2        There may be instances such as, when dealing with customer service matters or product quality complaints, we may share your personal information with third parties such as suppliers and manufacturers in order that such matters get resolved with the minimum possible delay.

4.4.3        As a business to business organisation  we use the Business Data for: business management and planning, including accounting and auditing;

4.5             We monitor and process the content of your private communications made to us using our IT and communication systems in order to ensure that we deal with such communications in accordance to your request such as processing your orders, deal with your queries and concerns. We have the technology to record and monitor your calls to Sigma, and we may use this information to improve our customer service to you or deal with any dispute that may arise due to your call to us.

4.6             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.

4.7             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. However, where consent is the only ground we have to process your personal data we will seek this from you.

5                 How we use particularly sensitive personal information

5.1             Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

5.1.1        In limited circumstances, with your explicit written consent.

5.1.2        Where we need to carry out our legal obligations and in line with our data protection policy.

5.1.3        Where it is needed in the public interest.

5.2             Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

5.3             We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of contract law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

5.4             We will use your particularly sensitive personal information in the following ways:

5.4.1        In the course of our legitimate interests where we feel we need to adapt communications channels that will enable us to conduct our business with you.

5.4.2        To meet our legal obligation with regard to various legislations such as disability discrimination act.

5.4.3        To enrich your customer and supplier experience with us ( for example as described in paragraph 2.5.6 above).

6                 Information about credit

6.1             We may only use information relating to credit references where the law allows us to do so, or where such processing is necessary for our legitimate and legal interests such Quality and Regulatory purposes. Less commonly, we also have a legal duty to share this information with regulatory bodies such as the MHRA in relation to our duties to carry out due diligence checks for GDP compliance and supplier and customer verification checks.

6.2             Your information may need to be shared with third parties and regulatory bodies during and for the purposes of audits such as GDP/GMP audits and accounting and financial audits.

7                 Data sharing

7.1             We may have to share your data with third parties, including any other entities in our group, third-party service providers who provide services to us and other third parties who use your information, as data controller, for their own purposes.

7.2             We will share your personal information with third parties where required by law, where it is necessary to administer the business relationship with you or where we have another legitimate interest in doing so.

 

7.3             Where we share information with other data controllers, they are responsible to you for their use of your information and compliance with the law. We may share information with other data controllers as follows:

7.3.1        HMRC

7.3.2        MHRA

7.3.3        Custom and Excise

7.3.4        Credit  Reference Agencies

7.3.5        Our suppliers ( customers data)

7.3.6        Other third parties to whom we outsource our services such as courier and delivery services.

7.4             All our third-party service providers are required to take appropriate security measures to protect your personal information in line with GDPR. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

7.5             We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.

8                 Transferring information outside the EU

8.1             Most of the personal information we collect we host on servers located within the European Economic Area (EEA). We do not transfer information outside the EEA during the normal course of our business. There may be instances as part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside of the EEA as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud”.  It may also be processed by staff operating outside the EEA, who work for one of our suppliers, e.g. our website server host, or work for us when temporarily outside of the EEA.

9                 Data security

9.1             We have put in place measures to protect the security of your information. Details of these measures are available upon request.

9.2             Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure and in line with GDPR requirements and legislation.

9.3             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 to those employees, agents, contractors and other third parties who as business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality and conform to GDPR requirements and legislation.

9.4             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.

10              How long will we use your information for?

10.1          We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

10.2          To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10.3          Once you are no longer a customer or a supplier we will retain and securely destroy your personal information in accordance with our Data Retention Policy. In some cases, and only when it is absolutely necessary, we may retain your personal information following termination of our business and contractual relationship.

10.4          In some circumstances 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.

10.5          Where a minimum retention period is required by law (such as retaining records for HMRC purposes) we comply with that minimum period plus up to 3 months to allow time for us to anonymise or delete information in accordance with our internal data management processes.

10.6          Copies of all electronic data created on our systems is retained our back up service provider for 10 years.

11              Your rights in connection with personal information

11.1          Under certain circumstances, by law you have the right to:

11.1.1     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.

11.1.2     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.

11.1.3     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 (see below).

11.1.4     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.

11.1.5     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.

11.1.6     Request the transfer of your personal information to another party.

11.1.7     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. 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 are required to continue to process your information in accordance with another lawful basis which has been notified to you.

11.2          To exercise any of the above rights, please contact the DPO in writing or by email- details to be found in paragraph 1.5 above.

11.3          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.

11.4          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.

If you have any questions about this privacy notice, please contact the DPO.

Version 1: May 2018