Patient safety redefined. Digitised, personalised and optimised.
Patient safety redefined. Digitised, personalised and optimised.

Privacy Policy

Last updated: 21st December, 2022.

 

1. Who we are

Axian Consulting Ltd is a company incorporated in England and Wales, registered at Companies House 12932714 whose registered address is at Axian Consulting Ltd 125 Wood Street, London, United Kingdom, EC2V 7AW

For the purposes of the UK and EU GDPR (the ‘’GDPR’’), Axian Consulting Ltd. is the data controller with regard to the Personal Data described in this Privacy Notice.

Axian Consulting’s mission is to provide a comprehensive range of safety consulting and patient risk management services, across the product lifecycle for our pharma, biotech and medtech clients.

Axian Consulting have outsourced the function of the Data Protection Officer to XpertDPO Ltd.

Our Data Protection Officer can be contacted as follows:

Telephone: 353 1 678 8997 

Email: dpo@axian.consulting

Post: 20 Harcourt St, Saint Kevin’s, Dublin, D02 H364, Ireland

2. Purpose and Scope of this Notice

The purpose of this Privacy Notice is to provide you, as our data subject, with a statement regarding the Data Protection and Privacy practices and obligations of Axian Consulting and an explanation of your rights as a data subject.

This Privacy Notice applies to our business practices, and our website, which is accessible from https://axian.consulting/

As Axian Consulting is established in the United Kingdom, this document is written in the vein of UK and EU Data Protection Law, and Axian Consulting falls under the jurisdiction of the Information Commissioner’s Office UK. This Privacy Notice sets out what personal data we collect and process about you in connection with the services and functions of Axian Consulting. We are not responsible for the content or the privacy notices for any websites to which we may provide external links.

Laws that apply to us:
• General Data Protection Regulation (EU Regulation 679/2016)
• Regulations flowing from Data Protection Act 2018
• Privacy & Electronic Communications Regulation (PECR) 2003

 implementing EU Privacy and Electronic Communications Directive 2002/58/EC on Privacy and Electronic Communications, otherwise known as ePrivacy Directive (ePD)

3. What personal information do we collect?

Personal information means data which relates to an individual and which identifies that individual, either directly or indirectly, such as your name or your contact information, or information which when combined with other information can identify you. It does not include anonymised data where your identity has been removed.

Any personal data that you share with us is treated with the highest standards of security and confidentiality, strictly in accordance with the Data Protection Act 2018 and the UK and EU General Data Protection Regulation (GDPR).

We may collect, use, store and transfer different kinds of personal data about you including, but not limited to:  which we have grouped together as follows:

  • Identity Data – e.g. first name, maiden name, last name, title.
  • Contact Data– e.g. billing address, email address and telephone numbers
  • Employment/Commercial/business and/or professional data – e.g., company/organisation name, job title, and contact details
  • Financial Data – e.g. tax and payment details
  • Technical Data– e.g. internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data – e.g. your interests, preferences, feedback and survey responses.
  • Client Profile Data – e.g. website/portal username and login
  • Usage Data– e.g. information about how you use our website, products and services.
  • Marketing and Communications Data– e.g. your preferences in receiving marketing from us and our third parties, your communication preferences including email and telephone, where you register for events and for email notifications and newsletters.
  • Online surveys.The purpose of the surveys will be detailed on the questionnaire, and where necessary consent and further preference requirements will be collected at that stage.
  • Social Media – g. any interactions you have with us on any social media platforms that we participate on.

We also collect, use and share Aggregated Data such as statistical or demographic data as necessary. Aggregated Data may be derived from your personal data but where this data is Anonymous Data it is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we can combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not purposely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we purposely collect any information about criminal convictions and offences. However, please be aware that, in very limited circumstances, we may process Special Categories of Personal Data for instance if you have entered into a specific type of contract with us.

Children’s Data

Our services are not designed for, or intentionally targeted at, children 13 years of age or younger. We do not intentionally collect or maintain data about anyone under the age of 13.

Criminal Convictions / Offence Data

Axian Consulting does not collect any information from clients or prospective clients around criminal convictions and offences.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your Identity, Contact and other data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for a consultation
    • contact us directly via the contact us form
    • email your CV
    • subscribe to our service or publications;
    • request marketing to be sent to you or downloaded;
    • complete a survey;
  • Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate cookie policy for further details.
  • Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • (a)analytics providers;
      • (b)marketing and CRM providers;
      • (c)survey providers.
    • Identity and Contact Data from publicly available sources such as Social Media sources such as LinkedIn and Twitter.

5. Why and how do we process your personal data?

Axian Consulting Ltd takes your data protection seriously and will not use your personal data where we do not have a lawful basis to do so. Therefore, we will only process your personal data:

  • Where we need to perform the contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending/discussing third party direct marketing communications to you via email, telephone or post. You have the right to withdraw consent to marketing at any time by Contacting us via our contact us form, by telephone or by unsubscribing. This can be done by contacting us or via the unsubscribe button at the bottom of an email newsletter or communication, which is sent out on to current subscribers.

See the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis, we are relying on to process your personal data where more than one ground has been set out in the table below.

6. How long do we keep your personal data?

We will only retain your Personal Data for as long as it is necessary to fulfil the purposes outlined in this privacy notice or the purposes of which you have otherwise been informed including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

If you have any queries about our retention periods you can contact us on dpo@axian.consulting.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

a)    Identity

Performance of a contract with you

b)    Contact

To Manage our relationship with you which will include:

a)    Identity

a)    Performance of a contract with you

a)    Notifying you about changes to our terms or privacy notice

b)    Contact

b)    Necessary to comply with a legal obligation

b)    Asking you to leave a review or take a survey

c)    Profile

c)    Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

d)    Marketing and Communications

 

To record project and contractual requirements

a)    Identity

a)    Performance of a contract with you

b)    Contact

b)    Necessary to comply with a legal obligation

 

c)    Financial

 
   
   
   

To allow you to set up, login and manage your accounts on website portals 

a)    Contact

a)    Performance of a contract with you

b)    Profile

 

c)    Technical

 

To enable you to partake in completing a survey

a)    Identity

a)    Performance of a contract with you

b)    Contact

b)    Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

c)    Profile

 

d)    Usage

 

e)    Marketing and Communications

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

a)    Identity

a)    Necessary for our legitimate interests (for running our business provision of administration and IT services network security to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

b)    Contact

b)    Necessary to comply with a legal obligation

c)    Technical

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve you

a)    Identity

Necessary for our legitimate interests (to define types of customers for our products and services, to keep out website updated and relevant, to develop our business and to inform our marketing strategy

b)    Contact

c)    Profile

d)    Usage

e)    Marketing and Communications

f)     Technical

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

a)    Technical

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant to develop our business and to inform our marketing strategy)

b)    Usage

To make suggestions and recommendations to you about goods or services that may be of interest to you

a)    Identity

Necessary for our legitimate interests (to develop our products/ services and grow our business)

b)    Contact

c)    Technical

d)    Usage

e)    Profile

 

a)    Identity

 

b)    Contact

c)    Technical

d)    Usage

e)    Profile

7. What are your rights and how can you exercise them?

In certain circumstances, you have the following rights under data protection legislation to your personal information:

  • to know what information we hold about you (‘right to be informed‘)
  • to request access to or a copy of the information we hold about you (‘right of access‘)
  • to have your data corrected if it is inaccurate (‘right to rectification‘)
  • to have your data erased where we do not have an overriding legal obligation or reason to retain it (‘right to erasure‘)
  • to prevent your data being used, if you have contested and are pending resolution in relation to its lawful use, accuracy or impact of your rights, or require that it is retained in relation to a legal claim (‘right to restriction of processing’)
  • to object to its use, including opting out of receiving marketing such as our newsletter (‘right to object’)
  • to request that we pass data about yourself that you provided us to another organisation on your behalf (‘right to data portability’)

The right to be informed

Axian Consulting Ltd is committed to ensuring that you are always aware of what we are doing with your information and are kept abreast of any changes to the processing of your information. We do so through this Privacy Notice, which is reviewed and updated as and when required.

The right of access

The right of access is 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.

When requesting your personal information we may need to ask you to provide additional information so that we can verify your identity before we can respond to your request. This additional information will not be more information than we already hold on you, and may include the following; your full name, address and contact telephone number, any information used by us to identify you, and we may ask for details of the specific information you require and any relevant dates.

The right to rectification

We endeavour to ensure that the information we hold about you is always correct, however, there may be instances where the information we hold is incomplete or inaccurate. You can ask that we rectify any information about you that is incorrect, although we may need to verify the accuracy of the new information you provide to us first.

The right to erasure

You have the right to request that certain personal information be erased from our systems if you feel that there is an underlying legal issue to us processing your information, or, where you withdraw consent.

While you may request for your information to be erased, this does not mean that we will be able to comply with your request, as there may be a legal reason that we have to keep your information. As such, each request is considered on a case-by-case basis.

The right to restrict processing 

In certain circumstances you have the right to request that we restrict the processing of your personal data. This means that you can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

The right to object

You have the right to Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes. This is an absolute right.

The right to data portability

In certain circumstances, you have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Please note that due to the type of services Axian Consulting Ltd provides, there will be very few instances where this right may apply.

Rights related to Automated Decision Making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects concerning you. Please note however that Axian Consulting Ltd does not use any form of automated decision making or the profiling of individuals personal data.

Right to withdraw consent

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending/discussing third party direct marketing communications to you via email, telephone or post. You have the right to withdraw consent to marketing at any time by contacting us via our contact us form, by telephone or by unsubscribing.

In the limited circumstances where you 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, which will have been outlined in the consent form you were provided with at the time of collection. A copy will be available on request.

How do you exercise your rights?

We have appointed a Data Protection Officer to monitor compliance with our data protection obligations and with this Notice and our related policies. If you have any questions about this Notice or about our data protection compliance, please contact the Data Protection Officer.

If you wish to exercise your rights please contact our Data Protection Officer who will respond to the request within one calendar month.

Our Data Protection Officer can be contacted as follows:

XpertDPO

Telephone: 353 1 678 8997 

Email: dpo@axian.consulting

Post: 20 Harcourt St, Saint Kevin’s, Dublin, D02 H364, Ireland

Timescales for complying with your request reviewed

We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. This period begins at the point we have been able to verify your request, not necessarily at the point you make the original request.

8. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your personal data using the following personal data control mechanisms: Unsubscribe button found in all email communications or by contacting us unsubscribe@axian.consulting.

Promotional Offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have completed a survey or registered for a white paper, questionnaire or checklist, or subscribed to our monthly newsletter and, in each case, you have opted into receiving marketing related to the original request for information.

Third Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside Axian Consulting Ltd for marketing purposes.

Opting out

Axian regularly informs its customers and their employees as well as other interested parties (the recipients) with a Newsletter. Subscription to the Newsletter requires that the recipient states his/her/they/their name and an e-mail address and that by doing so, gives consent to the sending of the Newsletter and marketing messages.

You can ask us or third parties to stop sending you marketing messages at any time by visiting the email preferences page on the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Every recipient can unsubscribe from the Newsletter at any time by e‐mail to unsubscribe@axian.consulting or by selecting the unsubscribe button at the bottom of our email. No costs are incurred by subscribing to or unsubscribing from the Newsletter.

9. Data Security and protecting your information

Axian Consulting Ltd is committed to protecting the confidentiality and security of your information. We have appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 (Why and how do we process your personal data?)

  • External Third Parties, such as hosting providers.
  • Service providers acting as processors based in Europe, Asia Pacific and North America who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Europe, Asia Pacific and North America who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Marketing platforms acting as processors such as Typeform (https://www.typeform.com), MailChimp (https://mailchimp.com) and ActiveCampaign (https://activecampaign.com).
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11. International Transfers

Your information may be processed in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection and that at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

12. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies we use, please see our cookie policy

13. Your Right to Lodge a Complaint

You as the Data Subject have the right to complain at any time to a supervisory authority in relation to any issues related to our processing of your Personal Data. We would like to hear from you first if you have a complaint about how we use your data so that we may rectify the issue.

As our organisation is located in the United Kingdom, and since we conduct our data processing here, we are regulated for data protection purposes by the Information Commissioner’s Office.

You can contact the Information Commissioner’s Office:
Website: http://www.ico.org.uk/  
Phone: (+44) 0303 123 1113
Address: Head Office – Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, UK

14. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, as new features and services become available on the Website and to keep pace with technological developments and changes within our organisation. 

We will provide you with a new privacy notice when we make any substantial changes. We will also notify you in other ways from time to time about the processing of your personal data.

15. Contact Us

The Axian Consulting Ltd Data Protection Officer carries out our internal supervision in connection with our responsibilities under this Privacy Notice.

If you would like to exercise your rights, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, you may contact Axian Consulting Ltd’s Data Protection Officer:

  • by post: AXIAN CONSULTING LTD attention of Data Protection Officer, Axian Consulting Ltd, 125 Wood Street, London, United Kingdom, EC2V 7AW
  • or by email: to dpo@axian.consulting

If you would like to exercise your rights, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please contact Axian Consulting Ltd’s Data Protection Officer at dpo@axian.consulting You also have the right to lodge a complaint with the supervising authority, the Information Commissioner’s Office (ICO), at any time.

If you remain unsatisfied after the investigation by the Data Protection Officer and their response to you, you may raise a concern with the Information Commissioner.