Privacy

Privacy Notice

This Notice was last updated on: 8^th July 2021

At Narrative Health Ltd (“Narrative Health”) we take your privacy very seriously. Our Privacy Notice sets out how we use your personal data and your rights in relation to the personal data we hold. This Privacy Notice (“Notice”) applies to Narrative Health Ltd and is based on globally accepted basic principles on data protection and privacy. This Notice adopts the fundamental principles of the United Kingdom’s Data Protection Act of 2018  (the “Act”) and the European Union’s General Data Protection Regulation (“GDPR”) as the minimum standards to which Narrative Health, its employees, and suppliers adhere.

Narrative Health is registered with the Information Commissioner’s Office in the United Kingdom as a Data Controller in accordance with the provisions of the Data Protection Act 2018. Further details of the registration are available at www.ico.org.uk/.

Registered company name: Narrative Health Ltd

Registered company 9221091

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

HOW DO WE COLLECT YOUR DATA?

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site narrative-health.com. This includes information provided at the time of making any general enquiry or when applying for a job. The information collected includes name, email, phone number, IP address and any information provided as part of your enquiry.
• Data from our clients and prospective clients when they register with our website; request information from us; purchase our services and in compliance with our contractual obligations including managing transactions, reporting, invoices and other operations related to providing and receiving services; as part of a market research project (e.g. observer forms) or otherwise communicate with us.
• We collect data from our research participants as part of our market research studies via a number of media, including but not limited to, consent forms, audio and video files/recording, screeners and questionnaires, online communities, publicly available sources, mobile applications, eye tracking and facial coding, and adverse event reporting forms..
• If you are a research participant, we may also be lawfully passed your data by our clients , the research sponsor, for the purposes of recruitment for an applicable study (e.g. market research, advisory boards or other project).

WHAT DATA DO WE COLLECT?

The following is typical of the personal data collected, held, and processed by Narrative Health:

• Name (first, surname)
• Contact details (typically, phone number, fax number, postal and email address)
• Role profile (job title, job description, years of service, academic qualifications and training details

Narrative Health may occasionally collect, hold, and process the following personal data; this use will be dependent on the methodology, topic, and purpose of the market research study, as well as the types of research participants being interviewed:

• Date of Birth
• IP address
• Image and voice as part of the audio and video recording or research
• Family, Lifestyle and Social circumstances related information (for example, current marriage and partnerships, marital history and details of family and other household members, housing, habits and travel/leisure activities)
• Work related information
• Income details
• Details of professional activities and interests
• Goods or services provided and related information

We may also collect special category data, with your consent, for research purposes including:

• Information on health and medical conditions (depending on the nature of the research project we are conducting)
• Information on racial or ethnic origin
• Information concerning sexual life or orientation (as it related to a medical condition discussed as part of a research project)
• Biometric data (eye tracking, facial coding)

HOW WILL WE USE YOUR DATA?

Narrative Health uses the personal data we collect for the following purposes:

• In the execution of our market research studies. For example ,we use information held about you to respond to you during the interview / recruitment process and this can be shared with those who are contacting you to schedule, organize an interview or conduct the research interview or to follow up for further queries.
• To respond to your enquiries, including those received via our website contact form.
• To contact our clients and prospective clients regarding our services and to provide any commissioned services.
• In employment relationships, personal data can be processed if needed to initiate, carry out and terminate the employment agreement. When initiating an employment relationship, the applicant’s personal data will be processed. If the candidate is rejected his/her data will be deleted unless the applicant has agreed to remain on file for a future selection process.
• As otherwise necessary to comply with our legal obligations.

The personal data will be processed and collected lawfully, fairly and in a transparent manner. Narrative Health will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized.  We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We use reasonable efforts to maintain the accuracy and integrity of personal data and to update it as appropriate.

Our legal bases for the processing of your personal data may fall into one of the following categories:

Consent

When we rely on consent for the processing of personal data, we will inform you of this fact and gain your consent for how your data will be used and handled. If we collect personal data as part of the research project we are conducting, we will obtain your consent at the time of the project as per our industry association guidelines and codes of conduct.  If special category data is included in the collection, we will collect your explicit consent for its processing.

You are free to withdraw or modify your consent at any time. Simply email us at team@narrative-health.com or contact us by phone +44 (0) 203 397 9900.

Legitimate interest

We also process personal data to pursue the legitimate business interests of Narrative Health and our clients. Our ‘legitimate interests’ include providing healthcare market research services and ensuring that Narrative Health is run in a professional and sustainable manner in accordance with relevant ethical, legal and regulatory duties and requirements.  We ensure that such processing is in balance with the rights and expectations of the data subjects whose personal data will be processed under this legal basis.

Contract

We may also process personal data if the processing is necessary for a contract we have with the data subject.

TO WHOM WILL WE DISCLOSE YOUR PERSONAL DATA?

We will not sell, share, transfer, or rent any Personal data to any third parties in ways different from what is disclosed in this Notice. Except as otherwise outlined in this Notice, we disclose personal data only to third parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations.

Narrative Health will ensure that any third party to whom we disclose personal data provides the same level of privacy protection as is required by the applicable data protection regulations and agrees in writing to provide an adequate level of privacy protection.

We may disclose your personal data to:

• Any staff member of Narrative Health where necessary to allow that staff member to respond to any enquiry you make or as part of the market research process.
• Other employees, agents, and contractors (e.g. suppliers who process data on our behalf, such as our accountants, solicitors, employment recruitment agencies and research suppliers including transcription agencies and research platform providers).
• Pharmaceutical and Medical Device manufacturers that sponsor our research projects if an adverse event, product complaint or safety issue is raised within the interview. In this situation, and if applicable based on your home country, you will be asked if you give your consent for your details to be passed on to our client for this purpose. We may also, with your consent, pass on audio or video footage to help illustrate our findings and help our clients better understand their business issue.
• External auditors, tax authorities and inspectors (such as HMRC, auditors).

In addition, we may disclose your personal data to:

• Allow us to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
• Investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
• Transfer information about you if Narrative Health is acquired by or merged with another company. In this event, Narrative Health will notify you before information about you is transferred and becomes subject to a different Notice.

HOW DO WE STORE YOUR DATA?

The data that we collect from you is stored securely on encrypted servers. It may be transferred to and stored at a destination outside your home country and it may also be processed by our team operating outside of the United Kingdom and Europe who work with us or via our suppliers.

We may also process personal data via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

Our United States based affiliate, Narrative Health LLC, complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework and the Swiss-U.S. Data Privacy Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom and Switzerland to the United States, respectively.

Narrative Health has certified to the Department of Commerce that it adheres to the DPF Principles for data protection: notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability for personal data submitted by data subjects in the European Union, United Kingdom and Switzerland and our Data Privacy Framework self-certification is available here.

If there is any conflict between the terms in this Notice and the DPF Principles, the DPF Principles shall govern.

Narrative Health acknowledges that as a participant in the DPF Framework it is under the enforcement authority of the Federal Trade Commission.

To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/s/

FOR HOW LONG WILL WE RETAIN YOUR PERSONAL DATA?

Your personal data will not be kept for longer than is required for the purpose of the processing or is required per applicable law.

Information related to our market research activities, including adverse reporting data and its source materials, may be held up to 10 years or per the guidelines dictated by the contractual terms of our clients if they are different from our internal retention guidelines.  We retain personal data such as research participant contact details only for as long as is required per the related processing.

For more information on our retention guidelines, you can contact us at team@narrative-health.com.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

We would like to make sure you are fully aware of all of your data protection rights, which may vary depending on the applicable legal basis of processing of your personal data:

• The right to access– You have the right to obtain confirmation that your personal data is being processed and to request copies of the personal data we hold.
• The right to rectification– You have the right to request that we correct any information you believe is inaccurate. You also have the right to request to complete the information you believe is incomplete.
• The right to erasure– You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing– You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing– You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability– You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to where the rights of persons other than you would be violated by the provision of such access.  If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

Please note that in some cases, especially if you wish us to delete or cease the processing of your personal data, we may no longer be able to provide our services to you.

If you would like to exercise any of these rights, please connect with us at via email, phone or postal mail as noted in the HOW TO CONTACT US section of this Notice.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to make a complaint to your local supervisory authority responsible for data protection matters.

CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to this Notice will be posted on this page and date stamped. We will notify you if we make changes that materially affect the way we handle personal data previously collected, and we will allow you to choose whether your personal data may be used in any materially different manner. If there is anything you are no longer happy with please feel free to access your rights as set out above, but by continuing to allow us to hold your information you are accepting any changes made to this Notice.

HOW TO CONTACT US

Questions, comments, and requests regarding this Notice should be addressed to team@narrative-health.com

Alternatively, you may call us at: +44 (0) 203 397 9900

Or write to us at:

Narrative Health Ltd
20-22 Wenlock Road
London
N1 7GU
United Kingdom

Attn: Privacy Team

EU Data Protection Representative:

Our data protection representative for the European Union is:

JAVIER RODRIGUEZ

Address:

10 Calle Siete Picos,
Madrid, 28002
Spain

Email: privacy@narrative-health.com

WHAT IS A COOKIE?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.

You can find more information about cookies at:

www.allaboutcookies.org and www.youronlinechoices.eu

For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.

COOKIES WE USE ON THIS WEBSITE

We use the following cookies:

• Necessary cookies. These are cookies that are required for the operation of the website.  They include, for example, cookies that enable you to log into parts of the website.
• Analytical cookies. These cookies allow us to recognise and count the number of visitors to the website and to see how they move around within the website when they are using it.  This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
• Third party cookies. These are used to third parties (such as Google) to enable their services to work, for example Google Captcha on forms or Google Maps. Some third parties use their cookies for advertising purposes. We have no control over these cookies and provide a link to the third party’s privacy policy, where you may have the option to opt-out of their data collection.