The Network Group (TNG)
Website Privacy Notice
15 September 2021
The Network Group (TNG) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use the TNG website and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. 1. This privacy notice aims to give you information on how TNG collects and processes your personal data when you use the TNG website, including any data you may provide through the TNG website when you use our contact form. 2. Please note, that when you contact a member of TNG directly, this privacy notice does not apply. When you contact a member of TNG we encourage you to read their privacy policy, which may be located on their website. We do not control these third-party websites and are not responsible for their privacy notices. 3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 1. We are Orielton Business Services Limited, a company registered in England and Wales under company number 10828970 and with our registered office at 22b High Street, Witney, Oxfordshire, United Kingdom, OX28 6RB. We are a member of The Network Group, an NHS England Health Systems Support Framework Supplier that offers partnering, insight, engagement, empowerment and innovation to partners in the healthcare sector. 2. We are a "data controller" in respect of the information we hold about you. This means that we are responsible for deciding how we use your personal information. 1. It is important that you inform us of any changes to your personal information we hold about you so that the information which we hold is accurate and current. 2. We may update this privacy notice at any time. We display a date at the top of this privacy notice so that you will know when there has been a change. You should check this webpage on a regular basis for our most current privacy practices. 1. The TNG website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We encourage you to read the privacy notice of every website you visit. We do not control these third-party websites and are not responsible for their privacy notices. 1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 2.1 Identity Data such as your name and email address; 2.2 Technical Data such as [your internet protocol (IP) address, your login data, 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 the TNG website]; 2.3 Profile Data such as your interests, preferences, and contact form responses; 2.4 Usage Data such as information about how you use our website; 3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we 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. 4. We do not knowingly 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) or any information about criminal convictions and offences. 1. We use different methods to collect data from and about you including through: 1.1 Direct interactions. You may give us your Identity, and Profile Data by filling in forms on our website. 1.2 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 the 'Cookies' section below for further details. 1. When using the TNG website, we will automatically collect data about you via 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 website and also allows us to improve our site. 2. By continuing to browse the site, you are agreeing to our use of cookies. The cookies we use 3. We use the following cookies: 3.1 Necessary cookies. These are cookies that are required for the operation of our website. 3.2 Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region). 4. 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 the TNG website may become inaccessible or not function properly. 5. If you wish to find out more about cookies and which cookies have been set on your device, you can visit: www.aboutcookies.org or www.allaboutcookies.org. 1. We use the types of personal data listed above for a number of purposes, each of which has a "lawful basis". In accordance with the data protection laws, we need a "lawful basis" for collecting and using information about you. There are a variety of different lawful bases for using personal data which are set out in the data protection laws. 2. We have set out below the different purposes for which we collect and use your personal data, along with the lawful bases we rely on to do so. 3. 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 use this LINK and put “FAO Data Controller” in the subject line if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Why we use your information Our lawful basis for using your information To manage our relationship with you which will include: Contract: It is necessary in order to take steps to enter into a contract with your or for us to perform our contract with you. To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Legitimate interests: It is 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 re-organisation or group restructuring exercise). To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. Legitimate interests: It is 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). 1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please use this LINK and put “FAO Data Controller” in the subject line. 2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 1. We may have to share your personal data with the parties set out below: 1.1 Service providers who provide IT and system administration services. 1.2 Professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services. 1.3 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. 1.4 The Police or other law enforcement agencies in relation to security related or law enforcement investigations or in the course of cooperating with authorities, protecting and defending our rights or property or complying with legal requirements. 2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 1. Some of our external third parties host data outside of the UK in the EU, so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data outside of the UK, we ensure a similar degree of data protection is afforded to it by ensuring at least one of the following safeguards is implemented: 1.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 1.2 Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 1. We have put in place appropriate security measures 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 business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 2. We have put 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. 1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 2. 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. 1. Under certain circumstances, by law you have the right to: 1.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 1.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 1.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 1.6 Request the transfer of your personal information to another party. 2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please use this LINK and put “FAO Data Controller” in the subject line. 1. You have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
PURPOSE OF THIS PRIVACY NOTICE
WHO WE ARE
CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
THIRD PARTY LINKS
THE INFORMATION WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
COOKIES
HOW AND WHY WE USE YOUR PERSONAL DATA
Legal obligations: It is necessary to meet our legal obligations.
Legitimate interests: It is necessary for our legitimate interests (for the running of our business and the improving of our services).
Legal obligations: It is necessary to meet our legal obligations.
CHANGE OF PURPOSE
DISCLOSURE OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
RIGHT TO COMPLAIN TO THE ICO