Infonetica – General Privacy Policy

About this policy

This policy describes how we use your personal data when we act as a datacontroller for the purposes of the UK GDPR and the Data Protection Act 2018(the “Act”). This policy applies when we provide services directly to you orwhen you use any of our websites (see list below).

If you interact with any services that we provide to other organisations(our “Customer(s)”), such as registering as a user or administrator of theservice, we act as a data processor only for the purposes of the Act. For moreinformation on how we utilise personal data when acting as a data processor,please use the following links:

Ethics RM Privacy Policy - http://infonetica.net/ethics-rm-privacy-policy/

ReDA Privacy Policy - http://infonetica.net/reda-privacy-policy/

Tissue Auditor Privacy Policy - http://infonetica.net/tissue-auditor-privacy-policy/

Infonetica’s websites are: http://infonetica.net,https://www.whitehalltraining.com, http://www.gcptraining.org.uk,http://www.onlinegcp.com, http://www.onlinegcp.org, http://www.onlinegcp.de,http://www.onlinegcp.es, http://www.onlinegcp.nl, http://www.onlinegcp.pl,http://www.onlinegcp.be, http://www.onlinegcp.us or http://www.pharmatraining.co.uk.

We have provided this policy to ensure that you understand what personaldata we may collect and hold about you, what we may use it for and how we keepit safe. You have legal rights to access the personal data that we hold aboutyou and to control how we use it which are also explained.

You can read, print and save this whole policy or click on the links belowto see specific information about:

1. Who we are and how you can contact us

We are Infonetica Ltd (company number 04503405, registered address – TheLower Ground Floor Office, The Civic Centre, High Street, Esher, Surrey, KT109SD).

You can contact us in writing at the above address or by emailingenquiries@www.infonetica.net. If you would like to speak to us please call uson 0208 334 6900.

Please refer to the sections on Your rights to knowwhat personal data we hold and to control how we use it and How to make a complaintfor further contact information.

2. What personal data we collect about you

We collect:

personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website, purchase and/or complete one of our training courses, post on social media sites that we run, or contact us in connection with services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, job title, employer, address, e-mail address and phone number.
personal data that we receive from third parties. We may be provided with your personal data by yourself, your employer or your client. The personal data provided may include your name, email address and job title. We may also receive personal data in terms of feedback from service providers, such as courier companies that we use in the execution of our business.
personal data about your use of our website. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or 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), and any phone number used to call our customer service number. For more information on this, please see our cookie policy (http://infonetica.net/cookie-policy/).

3. What we use your personal data for

We use your personal data in the following ways:

personal data that you provide to us isused to:

process and respond to any enquiry you make
provide you with the information and services that you, your employer or your client requests from us
send you a certificate by email on completion of a training course
alert you when your training or other services are due to expire
provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
manage and administer our business
review and improve our services
to give access to our products and services

personal data that we receive from third parties iscombined with the personal data that you provide to us and used for thepurposes described above. personal data aboutyour use of our website is used to:

administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
to allow you to participate in interactive features of our services, when you choose to do so
as part of our efforts to keep our site safe and secure
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
to make suggestions and recommendations to you and other users of our site about services that may interest you or them.

4. Cookies

Our website uses cookies to distinguish you from other users of our website.This helps us to provide you with a good experience when you browse our websiteand also allows us to improve our website. For detailed information on thecookies we use and the purposes for which we use them see our cookiepolicy (http://infonetica.net/cookie-policy/).

5. When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personaldata, this does not necessarily mean that we are required to ask for yourconsent before we can use it. In the day to day running of our business we mayuse your personal data without asking for your consent because:

we are entering into and carrying out our obligations under a contract with you
we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and to provide and / or improve our services to you, your employer or your client) and our doing so will not interfere with your privacy rights.

In exceptional circumstances we may wish to use your personal data for adifferent purpose which may require your consent. In these circumstances wewill contact you to explain how we wish to use your data and to ask for yourconsent. You are not required to give consent just because we ask for it. Ifyou do give consent you can change your mind and withdraw it at a later date.

Please refer to the section on How we use your personal data formarketing to read about marketing consents.

6. Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personaldata but please note that if you elect not to provide us with your personaldata we may be unable to provide our services to you.

7. Your rights to know what personal data we hold and to controlhow we use it

You have a legal right to know what personal data we hold about you – thisis called the right of subject access. You can exercise this right by sendingus a written request at any time. Please mark your letter “Subject AccessRequest” and send it to us by post or email using the details in the Who we areand how you can contact us section.

You also have rights to:

prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
have inaccurate personal data corrected, blocked or erased
object to decisions being made about you by automated means
object to our using your personal data in ways that are likely to cause you damage or distress
restrict our use of your personal data
require that we delete your personal data
require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the InformationCommissioner’s Office website at ww.ico.org.uk.

8. Automated decision making and profiling

We undertake automated decision making for the following purposes:

where it is required for the delivery of our goods or services
to alert trainees that their certificates are about to expire
as part of our other product or service offerings.

You are entitled to ask that we do not make automated decisions about you oruse your personal data for profiling purposes. Please refer to the sectionon Your rights to know what personal data we hold and to control how weuse it for details on how to exercise your rights.

9. When we will share your personal data with others

We share your data with the following people in the day to day running ofour business:

other businesses that are part of the Infonetica group
if you have been enrolled in a training course by your employer or client, they are able to access your training records, including exam questions and your responses, in order to monitor performance and identify gaps in knowledge which may need addressing
any business partners, suppliers and sub-contractors we work with to provide you with services that you have, or your employer or client has, requested from us
advertisers and advertising networks, such as email service providers
analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also share your personal information with third parties on a one-offbasis, for example, if:

we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
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 and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

10. How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. Thesecurity measures we take include:

only storing your personal data on our secure servers
ensuring that our staff receive regular data security awareness training
keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
destroying any records of credit card numbers as soon as they are entered into (and encrypted by) our secure finance software
maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
enforcing a strict policy on the use of mobile devices and out of office working

Please remember that you are responsible for keeping your passwords secure.If we have given you (or you have chosen) a password which enables you toaccess certain parts of our websites, you are responsible for keeping thispassword confidential. Please do not to share your passwords with anyone.

Unfortunately, sending information via the internet is not completelysecure. Although we will do our best to protect your personal data, we cannotguarantee the security of personal data sent to our websites; you send uspersonal data at your own risk. Once we have received your personal data, wewill use strict procedures and security features (some of which are describedabove) to try to prevent unauthorised access.

11. How we use your personal data for marketing

We will add your details to our marketing database if:

you make an enquiry about our services
you provide your details and indicate that you are happy to receive marketing communications when signing up for a product demonstration
you buy our services
you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services
you have registered an account on our website and have indicated during the sign-up process that you are happy to receive marketing communications.

We may send you marketing communications by email, telephone, text message,post or social media.

You can ask us to only send you marketing communications by particularmethods (for example, you may be happy to receive emails from us but nottelephone calls), or you may ask us not to send you any marketingcommunications at all.

We may ask you to indicate your marketing preferences when you firstregister an account on any of our websites. You can check and update yourcurrent marketing preferences at any time by emailing us at enquiries@www.infonetica.net orby telephoning +44 (0) 208 334 6900.

We never share your personal data with third parties for marketing purposes.

12. When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destinationoutside the United Kingdom and/or the European Economic Area (“EEA”) by us orby our sub-contractors. Where we, or our sub-contractors, use IT systems orsoftware that is provided by non-UK companies, your personal data may be storedon the servers of these non-UK companies outside the UK and/or EEA. We willtake all steps reasonably necessary to ensure that your data is treatedsecurely and in accordance with this privacy policy.

Infonetica Ltd is based in the UK and also has offices in Australia who haveaccess to your personal data.

13. How long we keep your personal data

We only keep your personal data for as long as we actually need it. Inpractice, this means we keep some data for up to 6 years after the end of thecontract with you, or with our customers, unless for legal or contractualreasons, it needs to be retained for longer.

In practice, this means that we will usually keep:

your name and contact details for 6 years after we stop providing our services to you or to our customers who have bought services from us
a record of the services, including a copy of your full customer file, we provide to you or our customer for 6 years after we stop providing our services
complaint records for 6 years
contracts for 6 years (after the contract end date)

14. How you can make a complaint

If you are unhappy with the way we have used your personal data pleasecontact us to discuss this using the email address enquiries@www.infonetica.net orby telephoning +44 (0) 208 334 6900.

You are also entitled to make a complaint to the Information Commissioner’sOffice which you can do by visiting www.ico.org.uk. Whilst you are not requiredto do so, we encourage you to contact us directly to discuss any concerns thatyou may have and to allow us an opportunity to address these before you contactthe Information Commissioner’s Office.

15. How we keep this policy up to date

We will review and update this policy from time to time. This may be toreflect a change in the services we offer or to our internal procedures or itmay be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version ofthis policy on our websites, or you can contact us by email onenquiries@www.infonetica.net or by telephone on +44 (0) 208 334 6900 to ask usto send you the latest version of our policy.

Each time we update our policy we will update the policy version numbershown at the end of the policy and the date on which that version of the policycame into force.

This is policy version 0.0.5 which came into effect on 10^thFebruary 2022.

Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website.This helps us to provide you with a good experience when you browse our websiteand also allows us to improve our site.

This Cookie Policy should be read in conjunction with our General PrivacyPolicy (http://infonetica.net/general-privacy-policy/).

A cookie is a small file of letters and numbers that we store on yourbrowser or the hard drive of your computer if you agree. Cookies containinformation that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

For Infonetica.net: you can find moreinformation about the individual cookies we use and the purposes for which weuse them in the table below:

Cookie

Name

Purpose

More information

Google Analytics

_ga _git _gad

These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

Read Google’s overview of privacy and safeguarding data

For our training-related websites: you can findmore information about the individual cookies we use and the purposes for whichwe use them in the table below.

Our training-related websites are: https://www.whitehalltraining.com,http://www.gcptraining.org.uk, http://www.onlinegcp.com,http://www.onlinegcp.org, http://www.onlinegcp.de, http://www.onlinegcp.es,http://www.onlinegcp.nl, http://www.onlinegcp.pl, http://www.onlinegcp.be,http://www.onlinegcp.us or http://www.pharmatraining.co.uk.

Cookie

Name

Purpose

More information

Anonymous Session

.ASPXANONYMOUS

This cookie helps maintain your visit to our website anonymously (before you may log in to a secure area).

General cookie information

Anti-forgery Token

__RequestVerificationToken_Lw__

Cookie used to prevent cross site request forgery.

General cookie information

Google Analytics

_utma

Stores the amount of visits (for each visitor), the time of the first visit, the previous visit, and the current visit

Google Analytics information

_utmb _utmc

Used to check approximately how fast a website visitor leaves: when a visit starts, and approximately ends (‘c’ expires quickly).

_utmt

Used to throttle request rate.

_utmz

Records whether the visitor came from a search engine (and if so, the search keyword used), a link, or from no previous page (e.g. a bookmark).

Google Analytics

_ga _gid

Read Google’s overview of privacy and safeguarding data

Session ID

ASP.NET_SessionId

General purpose platform session cookie. Used to maintain an anonymised user session by the server. This cookie helps keep your browsing session private. Deleted once browser closed.

General cookie information

Currency

currencyData

Determines currency based on country IP address location – only holds currency value, e.g. GBP. Deleted once browser closed.

Custom cookie

Please note that third parties (including, for example, advertising networksand providers of external services like web traffic analysis services) may alsouse cookies, over which we have no control. These cookies are likely to beanalytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows youto refuse the setting of all or some cookies. However, if you use your browsersettings to block all cookies (including essential cookies) you may not be ableto access all or parts of our site.

Except for essential cookies, all cookies will expire after 2 Years.

How do I change my cookie settings?

Most web browsers allow some control of most cookies through the browsersettings. To find out more about cookies, including how to see what cookieshave been set, visit http://www.aboutcookies.orgor www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

To find information relating to other browsers, visit the browserdeveloper’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

If you wish to change your cookie choices after making your initial choicewhen accessing one of our websites, please contact by writing to us atInfonetica, The Lower Ground Floor Office, The Civic Centre, High Street,Esher, Surrey, KT10 9SD, or by emailing enquiries@www.infonetica.net.

ReDA privacy policy

In providing the Research Database Application (also known as ReDA) service,Infonetica Ltd (“Infonetica”) holds the personal information of registered ReDAusers.

As such, Infonetica is a data processor for the purposes of the UK GDPR andthe Data Protection Act 1998 (“the Act”) and subject to certain obligationswith respect to the processing of that personal information. This privacypolicy sets out the basis on which Infonetica holds personal data in relationto the provision of the ReDA service. Our Customer is the data controller.

For any services which we might provide for for which we act as a datacontroller, please see our General Privacy Policy (http://infonetica.net/general-privacy-policy/).

Who we are and how you can contact us

We are Infonetica Ltd (company number 04503405, registered address – TheLower Ground Floor Office, The Civic Centre, High Street, Esher, Surrey, KT109SD).

You can contact us in writing at the above address, by emailing enquiries@www.infonetica.net,or by phone on 0208 334 6900.

ReDA

ReDA is a software application, owned and operated by Infonetica.Organisations wishing to use the ReDA service (“Customers”) are required toregister with Infonetica. Once registered, ReDA accounts are created forindividuals within or affiliated to the Customer.

Registered Users

When an ReDA account is created, the registered user is required to providea small amount of personal data either:

directly via the Customer’s ReDA access webpage which is provided by Infonetica;
to the systems administrator of the Customer, who will create the ReDA account and transmit the relevant personal information to Infonetica.

This personal data is held by Infonetica in a database on servers located atInfonetica’s principal place of business and at least one other location withinthe United Kingdom. The personal data held includes name, organisationalidentifier, department, email address, username, role and other informationwhich Infonetica requires to provide the ReDA service. No data that is notnecessary to provide the ReDA service is stored in the database.

Personal information about an account is available to the relevant ReDAsystems administrators via the ReDA Administration Interface. This informationis used by the administrator to identify and contact the individual and togenerate statistics about usage of ReDA accounts. ReDA system administratorsare appointed by Infonetica and the Customer in a joint approval process, andare subject to terms and conditions which include a requirement to meetappropriate privacy legislation. These are ruled under a separate contract butare summarised as follows:

Administrators must take reasonable steps to:

Ensure that access to a resource is only given to individuals who are authorised to access that resource under the terms of the licence for the resource;
Terminate ReDA access promptly when appropriate;
Keep ReDA usernames, passwords, and other personal information confidential;
Ensure that information concerning ReDA account holders is accurate; and
Investigate cases of suspected abuse or inappropriate content.

Individual Users must:

Keep their account confidential and not permit any third party to use it;
Use their account only for the purpose for which it was issued by the Customer;
Accept the terms of this ReDA Privacy Policy.

The two lists above are not descriptions of the all the obligations ofAdministrators and Users but are the core of the obligations related topersonal privacy.

ReDA Administrators

Each ReDA administrator is required to provide Infonetica with the followingpersonal data:

Name
E-mail address
Telephone numbers (working and non-working hours where the customer is seeking this level of service).

Infonetica will hold this personal information on the ReDA database and useit to contact system administrators in relation to the ReDA accounts for whichthey are responsible.

Customers must also input into the ReDA system at least 2 of the followingidentifiers:

A contact name
A telephone number
An e-mail address or URL to enable registered users to contact their ReDA administrator with ReDA -related enquiries.

The above information supplied appears on the ReDA website for registeredusers to see.

Infonetica will retain the personal data of systems administrators whilstthey remain the nominated ReDA administrator for the Customer, and will deletesuch personal data when the account is deleted.

Account Deletion

Infonetica will keep the personal data of registered users whilst theyremain registered users. Such information is deleted when the account isdeleted by the system administrator, or 6 years after the contract with ourCustomer has ended, whichever is the later.

Following account deletion, ReDA will still hold statistical informationabout the account. However, this information is linked only to the usernameand/or a Persistent ID. Such a link does not allow access to any personalinformation about the individual.

Business Transfer

If Infonetica or the ReDA service is sold or integrated with anotherbusiness, details within ReDA of all registered users would be passed on to thenew owners of the business.

Cookies

A “cookie” is a text-only string of information that a web site transfers tothe cookie file of the browser on a computer’s hard disk so that the web sitecan record and read a small amount of information.

ReDA either uses or may in the future use the following two types of cookie:

Session Cookies which remain in the cookie file of a computer system for a maximum of eight hours after they were initially created or are automatically removed if the browser session is terminated before the eight hour period has elapsed. These cookies contain the ReDA username and an ReDA token and are used to facilitate the ReDA single sign on service, enabling access to all of the ReDA registered resources which a user is entitled to access using a ReDA account.
Persistent Cookies which remain in the cookie file of the browser until they are deleted or if earlier, eighteen (18) months from their creation. At the time of writing this type of cookie is not used by ReDA but Infonetica foresee situations where it may be required in the future.

Users can set their browser to warn them before accepting cookies and refusethe cookie when the browser alerts the user to its presence.

Refusal/Deletion of Cookies

A user may refuse cookies by adjusting the appropriate setting in theirbrowser, but they will not be able to use all the facilities of ReDA. The usercan easily delete any cookies that have been installed in the cookie folder oftheir browser. Users should consult the documentation for their choice ofbrowser on how to manage cookies.

Access to your personal information

Registered users can view the personal information held about them bylogging in to ReDA with their username and password. Users are responsible formaintaining their own information, but this can also be updated and monitoredby an administrator.

Scope of this privacy policy and updates

This privacy policy applies only to the use of your personal information byInfonetica in connection with the ReDA service. The use of personal data orinformation by the Customer or any resource provider is governed by their ownprivacy policies. Infonetica are unable to accept responsibility for the use ofany of personal information by the Customer or any resource provider.

Infonetica may update this privacy policy from time to time. Any changesshall be notified by posting on the ReDA website or a location as chosen by theCustomer. Regularly reviewing this information ensures the user is always awareof the personal data Infonetica has access to and how it is used.

Security of your personal information

Infonetica is required to take appropriate technical and organisationalmeasures to secure personal data. In order to comply with this requirement, theservers containing personal data are located in secure data centre locationswith physical access limited to authorised staff. All data transmissions to andfrom the ReDA database are encrypted. Furthermore, password information sent toReDA is hashed (a form of one-way encryption that produces a result from whichit is computationally infeasible to deduce the original text) before it isstored in the ReDA database. The data is processed automatically byInfonetica’s systems without any human intervention. Only in the event of atechnical problem will any Infonetica staff become involved.

All Infonetica’s staff are instructed in the importance of and adherence tothe principles and requirements of the Act and Infonetica itself endeavours toensure they comply with the terms of this privacy policy. The personal datawhich Infonetica holds is never modified or disclosed to a third party otherthan as described in this policy. Infonetica continually monitors measureswhich seek to ensure the security and confidentiality of the information thatInfonetica collects and its proper use.

Queries or complaints

Users should contact the Customer in the first instance with any enquiries(since the Customer is the data controller for the purposes of the Act).

Any questions or enquiries about this privacy policy or Infonetica’scompliance with the Act should be addressed in the first instance to:Infonetica, The Lower Ground Floor Office, The Civic Centre, High Street,Esher, Surrey KT10 9SD, or by emailing enquiries@www.infonetica.net or bytelephoning +44 (0) 208 334 6900.

Disclaimer

This document is designed as a brief on the underlying principles priva

Ethics RM privacy policy

In providing its Ethics Review Manager service (also referred to as EthicsRM and/or ERM) to its customers, Infonetica Ltd (“Infonetica”) holds thepersonal information of registered Ethics RM users.

For any services which we might provide for which we act as a datacontroller, please see our General Privacy Policy (http://infonetica.net/general-privacy-policy/).

Who we are and how you can contact us

We are Infonetica Ltd (company number 04503405, registered address – TheLower Ground Floor Office, The Civic Centre, High Street, Esher, Surrey, KT109SD).

You can contact us in writing at the above address, by emailing enquiries@www.infonetica.net,or by phone on 0208 334 6900.

Ethics RM

Ethics Review Manager (also known as Ethics RM and/or ERM) is a softwareapplication that is owned and operated by Infonetica. Organisations wishing touse the Ethics RM service (“Customers”) are required to register withInfonetica. Once registered, Ethics RM accounts are created for individualswithin or affiliated to the Customer.

Registered Users

When an Ethics RM account is created, the registered user is required toprovide a small amount of personal data either:

directly via the Customer’s Ethics RM access webpage which is provided by Infonetica;
to the systems administrator of the Customer, who will create the Ethics RM account and transmit the relevant personal information to Infonetica.

This personal data is held by Infonetica in a database on servers located atInfonetica’s principal place of business and at least one other location withinthe United Kingdom. The personal data held includes name, organisationalidentifier, department, email address, username, role and other informationwhich Infonetica requires to provide the Ethics RM service. No data that is notnecessary to provide the Ethics RM service is stored in the database.

Personal information about an account is available to the relevant Ethics RMsystems administrators via the Ethics RM Administration Interface. Thisinformation is used by the administrator to identify and contact the individualand to generate statistics about usage of Ethics RM accounts. Ethics RM systemadministrators are appointed by Infonetica and the Customer in a joint approvalprocess, and are subject to terms and conditions which include a requirement tomeet appropriate privacy legislation. These are ruled under a separate contractbut are summarised as follows:

Administrators must take reasonable steps to:

Ensure that access to a resource is only given to individuals who are authorised to access that resource under the terms of the licence for the resource;
Terminate Ethics RM access promptly when appropriate;
Keep Ethics RM usernames, passwords, and other personal information confidential;
Ensure that information concerning Ethics RM account holders is accurate; and
Investigate cases of suspected abuse or inappropriate content.

Individual Users must:

Keep their account confidential and not permit any third party to use it;
Use their account only for the purpose for which it was issued by the Customer;
Accept the terms of this Ethics RM Privacy Policy.

The two lists above are not descriptions of the all the obligations ofAdministrators and Users but are the core of the obligations related topersonal privacy.

Ethics RM Administrators

Each Ethics RM administrator is required to provide Infonetica with thefollowing personal data:

Name
E-mail address
Telephone numbers (working and non-working hours where the customer is seeking this level of service).

Infonetica will hold this personal information on the Ethics RM database anduse it to contact system administrators in relation to the Ethics RM accountsfor which they are responsible.

Customers must also input at least two of the following identifiers into theEthics RM application:

A contact name
A telephone number
An e-mail address or URL to enable registered users to contact their Ethics RM administrator with Ethics RM-related enquiries.

The above information supplied appears on the Ethics RM website forregistered users to see.

Infonetica will retain the personal data of systems administrators whilstthey remain the nominated Ethics RM administrator for the Customer, and willdelete such personal data when the account is deleted.

Account Deletion

Following account deletion, Ethics RM will still hold statisticalinformation about the account. However, this information is linked only to the usernameand/or a persistent ID. Such a link does not allow access to any personalinformation about the individual.

Business Transfer

If Infonetica or the Ethics RM service is sold or integrated with anotherbusiness, details within Ethics RM of all registered users would be passed onto the new owners of the business.

Cookies

The Ethics RM application either uses or may in the future use the followingtwo types of cookie:

Session Cookies which remain in the cookie file of a computer system for a maximum of eight hours after they were initially created or are automatically removed if the browser session is terminated before the eight-hour period has elapsed. These cookies contain the Ethics RM username and an Ethics RM token and are used to facilitate the Ethics RM single sign on service, enabling access to all of the Ethics RM registered resources which a user is entitled to access using an Ethics RM account.
Persistent Cookies which remain in the cookie file of the browser until they are deleted or if earlier, eighteen (18) months from their creation. At the time of writing this type of cookie is not used by Ethics RM but Infonetica foresee situations where it may be required in the future.

Users can set their browser to warn them before accepting cookies and refusethe cookie when the browser alerts the user to its presence.

Refusal/Deletion of Cookies

A user may refuse cookies by adjusting the appropriate setting in theirbrowser, but they will not be able to use all the facilities of Ethics RM. Theuser can easily delete any cookies that have been installed in the cookiefolder of their browser. Users should consult the documentation for theirchoice of browser on how to manage cookies.

Access to your personal information

Registered users can view the personal information held about them bylogging in to Ethics RM with their username and password. Users are responsiblefor maintaining their own information, but this can also be updated andmonitored by an administrator.

Scope of this privacy policy and updates

This privacy policy applies only to the use of your personal information byInfonetica in connection with the Ethics RM service. The use of personalinformation by the Customer or any resource provider is governed by their ownprivacy policies. Infonetica are unable to accept responsibility for the use ofany of personal data or information by the Customer or any resource provider.

Infonetica may update this privacy policy from time to time. Any changesshall be notified by posting on the Infonetica website or a location as chosenby the Customer. Regularly reviewing this information ensures the user isalways aware of the personal data Infonetica has access to and how it is used.

Security of your personal information

Furthermore, password information sent to Ethics RM is hashed (a form ofone-way encryption that produces a result from which it is computationallyinfeasible to deduce the original text) before it is stored in the Ethics RMdatabase. The data is processed automatically by Infonetica’s systems withoutany human intervention. Only in the event of a technical problem will anyInfonetica staff become involved.

Queries or complaints

Users should contact the Customer in the first instance with any enquiries(since the Customer is the data controller for the purposes of the Act).

Disclaimer

This document is designed as a brief on the underlying principles privacyfor the Ethics RM System. It is possible for our Customers to specify differentcriteria and therefore not everything within this document may be applicable.

Infonetica general privacy policy

About this policy

This policy describes how we use your personal data when we act as a data controllerfor the purposes of the Data Protection Act 2018 (the “Act”). This policyapplies when we provide services directly to you or when you use any of ourwebsites (see list below).

EthicsRM Privacy Policy
ReDA Privacy Policy
TissueAuditor Privacy Policy

Infonetica’s websites are: http://infonetica.net,https://www.whitehalltraining.com, http://www.gcptraining.org.uk,http://www.onlinegcp.com, http://www.onlinegcp.org, http://www.onlinegcp.de, http://www.onlinegcp.es,http://www.onlinegcp.nl, http://www.onlinegcp.pl, http://www.onlinegcp.be,http://www.onlinegcp.us or http://www.pharmatraining.co.uk.

You can read, print and save this whole policy or click on the links belowto see specific information about:

Whowe are and how you can contact us
Whatpersonal data we collect about you
Whatwe use your personal data for Cookies
Cookies
Whenwe need your consent to use your personal data
Personaldata you are legally obliged to provide
Yourrights to know what personal data we hold and to control how we use it
Automateddecision making and profiling
Whenwe will share your personal data with others
Howwe keep your personal data safe
Howwe use your personal data for marketing
Whenwe will send your personal data to other countries
Howlong we keep your personal data
Howyou can make a complaint
Howwe keep this policy up to date

Who we are and how you can contact us

We are Infonetica Ltd (company number 04503405, registered address – TheLower Ground Floor Office, The Civic Centre, High Street, Esher, Surrey, KT109SD).
You can contact us in writing at the above address or by emailingenquiries@www.infonetica.net. If you would like to speak to us please call uson 0208 334 6900.

Please refer to the sections on Your rights to know what personal data wehold and to control how we use it and How to make a complaint for furthercontact information.

What personal data we collect about you

We collect:

personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website, purchase and/or complete one of our training courses, post on social media sites that we run, or contact us in connection with services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, job title, employer, address, e-mail address and phone number.
personal data that we receive from third parties. We may be provided with your personal data by yourself, your employer or your client. The personal data provided may include your name, email address and job title. We may also receive personal data in terms of feedback from service providers, such as courier companies that we use in the execution of our business.
personal data about your use of our website. This is technical information and includes details such as your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or 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), and any phone number used to call our customer service number. For more information on this, please see our cookie policy.

What we use your personal data for

We use your personal data in the following ways:

personal data that you provide to us isused to:

process and respond to any enquiry you make
provide you with the information and services that you, your employer or your client requests from us
send you a certificate by email on completion of a training course
alert you when your training or other services are due to expire
provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
manage and administer our business
review and improve our services
to give access to our products and services

administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device
to allow you to participate in interactive features of our services, when you choose to do so
as part of our efforts to keep our site safe and secure
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
to make suggestions and recommendations to you and other users of our site about services that may interest you or them.

Cookies

When we need your consent to use your personal data

we are entering into and carrying out our obligations under a contract with you
we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and to provide and / or improve our services to you, your employer or your client) and our doing so will not interfere with your privacy rights.

Please refer to the section on Howwe use your personal data for marketing to read about marketingconsents.

Personal data you are legally obliged to provide

Your rights to know what personal data we hold and to controlhow we use it

You also have rights to:

prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
have inaccurate personal data corrected, blocked or erased
object to decisions being made about you by automated means
object to our using your personal data in ways that are likely to cause you damage or distress
restrict our use of your personal data
require that we delete your personal data
require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the InformationCommissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We undertake automated decision making for the following purposes:

where it is required for the delivery of our goods or services
to alert trainees that their certificates are about to expire
as part of our other product or service offerings.

You are entitled to ask that we do not make automated decisions about you oruse your personal data for profiling purposes. Please refer to the sectionon Yourrights to know what personal data we hold and to control how we use it fordetails on how to exercise your rights.

When we will share your personal data with others

We share your data with the following people in the day to day running ofour business:

other businesses that are part of the Infonetica group
if you have been enrolled in a training course by your employer or client, they are able to access your training records, including exam questions and your responses, in order to monitor performance and identify gaps in knowledge which may need addressing
any business partners, suppliers and sub-contractors we work with to provide you with services that you have, or your employer or client has, requested from us
advertisers and advertising networks, such as email service providers
analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also share your personal information with third parties on a one-offbasis, for example, if:

we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
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 and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. Thesecurity measures we take include:

only storing your personal data on our secure servers
ensuring that our staff receive regular data security awareness training
keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
destroying any records of credit card numbers as soon as they are entered into (and encrypted by) our secure finance software
maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
enforcing a strict policy on the use of mobile devices and out of office working

How we use your personal data for marketing

We will add your details to our marketing database if:

you make an enquiry about our services
you provide your details and indicate that you are happy to receive marketing communications when signing up for a product demonstration
you buy our services
you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services
you have registered an account on our website and have indicated during the sign up process that you are happy to receive marketing communications

We may send you marketing communications by email, telephone, text message,post or social media.

We never share your personal data with third parties for marketing purposes.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destinationoutside the European Economic Area (“EEA”) by us or by our sub-contractors.Where we, or our sub-contractors, use IT systems or software that is providedby non-UK companies, your personal data may be stored on the servers of thesenon-UK companies outside the EEA. We will take all steps reasonably necessaryto ensure that your data is treated securely and in accordance with thisprivacy policy.
Infonetica Ltd is based in the UK and also has offices in Australia who haveaccess to your personal data.

How long we keep your personal data

your name and contact details for 6 years after we stop providing our services to you or to our customers who have bought services from us
a record of the services, including a copy of your full customer file, we provide to you or our customer for 6 years after we stop providing our services
complaint records for 6 years
contracts for 6 years (after the contract end date)

How you can make a complaint

If you are unhappy with the way we have used your personal data pleasecontact us to discuss this using the email address enquiries@www.infonetica.net orby telephoning +44(0) 208 334 6900.

How we keep this policy up to date

We will review and update this policy from time to time. This may be toreflect a change in the services we offer or to our internal procedures or itmay be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version ofthis policy on our websites, or you can contact us by email on enquiries@www.infonetica.net orby telephone on +44(0) 208 334 6900 to ask us to send you the latest version ofour policy.

Each time we update our policy we will update the policy version numbershown at the end of the policy and the date on which that version of the policycame into force.

This is policy version 0.0.4 which came into effect on 10th February 2021

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