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Client Privacy Notice

RQM+ is committed to processing your data securely and transparently. This privacy notice sets out the types of data that we collect and hold on you as a client or potential client of the company. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

RQM+ is aware of its obligations to residents and citizens of the EU under the General Data Protection Regulation (GDPR), of the UK under the Data Protection Act (UKDPA), of the USA under a variety of legislation and acts that include data protection requirements - specifically including the California Consumer Privacy Act (CCPA), of Switzerland under the Data Protection Act (DPA) and the Data Protection Ordinance (DPO), and the data protection requirements of residents and citizens of other countries, This privacy notice complies with the requirements of GDPR, UKDPA, CCPA, DPA and DPO and is applicable globally but may be supplemented by additional information on our privacy practices that may be provided as required by applicable laws and regulations via notices provided at the time of data collection. Together, these are referred to as “Data Protection Legislation”.

This notice applies to individuals who are:

  • Clients - individuals who represent (or represented) a company who RQM+ has or had a binding contract with to deliver services
  • Potential Clients - individuals who represent (or represented) a company who RQM+ has or is currently discussing potential opportunities or contracts with for the delivery of services. Also individuals who represent (or represented) a company who RQM+ is developing a relationship with in regards to business development

DATA CONTROLLER DETAILS

The Company is a data controller, meaning that it determines the processes to be used when using your personal data. The company has appointed Data Protection Officers who are responsible for ensuring your data is stored and processed in accordance with this privacy notice. Data Protection Officers can be contacted at dpo@rqmplus.com 

DATA PROTECTION PRINCIPLES

In relation to your personal data, we will:

  • process it fairly, lawfully and in a clear, transparent way
  • collect your data only for reasons that we find proper for the course of your relationship with RQM+ in ways that have been explained to you
  • only use it in the way that we have told you about
  • ensure it is correct and up to date
  • keep your data for only as long as we need it
  • process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.

TYPES OF DATA WE PROCESS

We may hold many types of data about you, including:

  • your personal details including your name, address, e-mail address, phone numbers
  • job title and job descriptions
  • job responsibilities
  • employer (and previous employers if known)
  • who you report to
  • your location
  • country that you reside in
  • information accessed and downloaded from company websites
  • events attended and met with RQM+ representatives
  • records of your contact with RQM+
  • marketing material and campaigns that you have shown an interest in.

We do not request, hold or process special categories of data (such health, sexual orientation, race, ethnic origin, political opinion, religion, trade union membership and genetic and biometric data) or criminal conviction data for clients or potential clients.

HOW WE COLLECT YOUR DATA

We collect data about you in a variety of ways and we would normally collect the data from you directly. This will usually start when you contact us or talk to us about a business need you or your company has, but can also be when you have provided your details to access and download information from our website or shown an interest in specific topics of a marketing campaign. Further information may be collected directly from you as our relationship and correspondence increases.

In addition, data about you may be obtained from other sources including from your colleagues as the person to speak to regarding a business opportunity or need, from publicly available sources or third parties such as LinkedIn and Zoominfo. Where this is the case, data that we hold will be limited in nature.

WHY WE PROCESS YOUR DATA

The laws on data protection allows us to process your data. Data Protection Legislation allows us to process your data for certain reasons which are detailed below:

  • where we have your consent to do so
  • in order to perform the contracts that we are party to
  • in order for us to carry out our legitimate interests
  • in order to carry out legally required duties
  • to protect your interests and
  • where something is done in the public interest.

All of the processing carried out by us falls into one or more of the permitted reasons. Generally, we will rely on performance of contracts and legitimate interest to process your data.

We need to collect your data so that we can perform and meet our obligations under the contracts we are part to for delivering agreed services.

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:

  • discuss and secure future business opportunities
  • business pipelining
  • making decisions regarding marketing activities
  • analyse the effectiveness of marketing activities
  • market intelligence including analysing the needs and potential need within the life science industry
  • maintaining effective correspondence and relationships
  • ensuring effective business administration
  • business forecasting including business planning and growth & restructuring exercises
  • achieving legal compliance and dealing with legal claims made against us
  • preventing fraud
  • ensuring our administrative and IT systems are secure and robust against unauthorised access.

With your consent, we collect your personal data to be able to include you on regular company e-mails and marketing correspondence (see separate Contact Privacy Notice).

IF YOU DO NOT PROVIDE YOUR DATA TO US

One of the reasons for processing your data is to allow us to carry out our deliverables in line with our contractual obligations. If you do not provide us with the data needed to do this, we will be unable to perform those duties e.g. carry out an audit, attend site, provide consultancy, supply labour. Likewise, we may be unable to provide or agree contracts with you.

SHARING YOUR DATA

Your data will be shared with colleagues within RQM+ where it is necessary for them to undertake their duties. This includes, for example, Business Development who maintain contact and build relationships with you, Client Services and Clinical Services Management to work alongside you by managing projects and RQM+ resources working on your projects, RQM+ management and administration to oversee sales, contracts, invoicing and company operations, Resource Management, Corporate Recruiters, Resourcing and Business Development to discuss your resource needs and liaise with you on submitted candidates.

We share your data with third parties in order to obtain legal support and business advice and when applicable, to obtain quotations on your behalf, work with third parties as required in Statements of Work.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.

RQM+ does not and will not sell your data or any personal data to any third party for any reason.

As a globally operating organisation RQM+ may be required to transfer personal data to countries between the USA, EEA, UK and also outside of those countries/jurisdictions. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by Data Protection Legislation:

  • Using IT systems with data security assurance to access data from overseas
  • Using encryption if sending high risk data by email
  • Data protection training for overseas data processors
  • Procedures for storing and processing data to Data Protection Legislation requirements

PROTECTING YOUR DATA

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. E.g., backing up our servers, firewalls, access control for personal information, using password protected documents and encryption when transferring sensitive data, hard drive encryption on all laptops, ensuring our IT systems that process personal information are secure to Data Protection Legislation standards.

Where we share your data with third party suppliers, we ensure that the contracts between RQM+ and the third-party provider that your data will be held securely and in line with Data Protection Legislation requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. Where needed, a separate Non-Disclosure Agreement (NDA) is also signed.

HOW LONG WE KEEP YOUR DATA FOR

In line with data protection principles, we only keep your data for as long as we need it for. As a consulting company, we build long term relationships with individuals and companies. The history and the contact we have with you is an important factor in the relationships that we build for business development purposes. In the niche market of life science regulatory and quality compliance, individual standards, rules and regulations change from every three to four years with more substantial changes occurring every 10-15 years. Thus, it is possible that a client or potential client may only require our services on an infrequent basis.

For Clients, we will hold data in order to perform the contracts that we are party to. We hold data to continue our relationship with you by understanding services we have delivered to you, potential services we have discussed with you and as a legitimate business interest to identify future opportunities to work with you again. We will retain data for 10 years after the last item of work in a SOW has been delivered and invoiced and/or the last opportunity for work was closed.

For Potential Clients, we hold data to continue our relationship with you by understanding services we have previously discussed with you and as a legitimate business interest to identify opportunities to work with you in the future. We will retain data for 10 years after the last item of work in a SOW has been delivered and invoiced and/or the last opportunity for work was closed.

We also hold data for individuals who do not wish to hear from us and individuals we may not wish to do business with. We have a legitimate business interest in holding this data to ensure that our employees do not contact those individuals inadvertently.

AUTOMATED DECISION MAKING

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

YOUR RIGHTS IN RELATION TO YOUR DATA

Data Protection Legislation gives citizens and residents in certain jurisdictions rights in relation to the data we hold. Although these rights may not be rights to citizens and residents in other countries and jurisdictions where Data Protection Legislation is limited, RQM+ extend these privileges to all. These are:

  • the right to be informed. This means that we must inform you what data we hold, how we use your data, data that may be disclosed and this is the purpose of this privacy notice
  • the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request or if California, a Consumer request
  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it. Under certain circumstances we may not be able to delete your data and where this is the case, we will confirm the reasons to you
  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
  • the right to portability. You may transfer the data that we hold on you for your own purposes
  • the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
  • the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
  • You will not be discriminated against if you exercise any of your rights as detailed above including:
    • Denying services to you
    • Charging you a different price for services, including granting discounts or other benefits or imposing penalties
    • Providing you with a different level of service
    • Suggesting that you may receive a different rate or level of service

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact the Data Protection Officers listed above.

MAKING A COMPLAINT

If you think your data protection rights have been breached in any way by us, you should contact our Data Protection Officer at dpo@rqmplus.com. If you think your data protection rights under GDPR or UKDPA have been breached in any way by us, you are able to make a complaint to a supervisory authority. In the UK, the supervisory authority is the Information Commissioner (ICO) – ico@org.uk 

ABOUT RQM+

RQM+ as referred to in this document includes the following companies:

  • RQM+ Corporation
  • Regulatory and Quality Solutions, doing business as RQM+ R&Q
  • Regulatory and Quality Solutions West, doing business as RQM+ West
  • Maetrics LLC, doing business as RQM+ Maetrics
  • Maetrics Limited, trading as RQM+
  • Maetrics GmbH, trading as RQM+
  • RQM+ (Germany) GmbH, trading as RQM+

                                                                                                                                                               Updated December 2023

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