1. Who we are and what we do
Who we are
We are Origins (“us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 11537316 and we have our registered office at Wey Court West, Union Road, Farnham, Surrey, GU9 7PT. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZA517024.
What we do
We create and deliver patient focused strategy, insights, data, and solutions, which guides pharma and biotech companies to improve value by involving patients throughout the entire product life cycle. Origins is headquartered in the UK and works on an international basis. We are part of Resonant Group, and we are committed to protecting the privacy and security of the Personal Data we process about you.
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
2. Purpose of this privacy notice
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.
3. Who this privacy notice applies to
This privacy notice applies to you if:
- You visit our website
- You are a Patient we work with
- You are one of our Clients or Supplier
- You are a Healthcare Professional
- You are a Patient Organisation we work with
- You enquire about our products and/or services
- You sign up to receive newsletters and/or other promotional communications from us
4. What Personal Data is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.
5. Personal Data we collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases, and retention periods’.
6. How we collect your Personal Data
We collect most of the Personal Data directly from you in person, by telephone, or email and/or via our website.
However, we may also collect your Personal Data from third parties such as:
- reputable recruitment agencies who work on our behalf
- others to whom you have provided consent
- publicly available sources such as social media platforms
7. Purposes, lawful bases, and retention periods
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
|Categories of individuals||Categories of Personal Data||Purpose of Processing||Lawful Basis||Retention Period|
|Patient||Name, address, email address, medical condition, Patient ID Number, opinion of product/service interview recording, social media handles, any other information shared with us||To participate in research and projects||Consent||6 years from the end of project|
|Client||Name, job title, work email address, work phone number, company you work for||To manage our business relationship with client||Legitimate interests – to manage our business relationship with you||6 years from the end of contract with client|
|Recruitment agencies||Name, job title, work email address, work phone number, company you work for||To manage our agency relations||Legitimate interests – to manage our business relationship with you||6 years from the end of contract with recruitment agency|
|Healthcare Professional||Name, job title, work email, work phone number, organisation you work for, interview recordings, opinion of product/service||To participate in research and projects||Contract||6 years from the end of contract|
|Healthcare Professional||Name, work email address, job title company you work for||To send and receive documents||Contract||6 years from the end of contract|
|Healthcare Professional||Name, work email address, work phone number, job title, company you work for, passport details, bank details||To arrange travel||Contract||6 years from the end of contract|
|Patient Organisations||Name, job title, work email address, work phone number, company you work for||To engage with us or participate in our research and projects||Legitimate interests||2 years from the end of project|
|Third party suppliers||Name, job title, work email address, work phone number, company you work for||To manage supplier relationship||Legitimate interests – to manage our supplier relationship with you||6 years from the end of contract with supplier|
|Existing/Prospective, Patient client, HCP, Supplier, Patient Organisation||Name, email address, any other information shared||To enquire about our services||Legitimate interest – to communicate with you to provide assistance about your enquiries||1 year following last meaningful contact|
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information. Your personal data is securely stored in accordance with our IT policy.
8. Sharing your Personal Data
We may pass your personal data on to third-party service providers contracted with Origins in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil specific services they provide to complete patient focused strategy, insights, data, and solutions projects. When they no longer need your data to fulfil this service, they will dispose of the details in line with Origins’ procedures. In the event we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent (both to record your sensitive personal information and to pass along to a third party) unless we are legally required to do otherwise. If you are taking part in a market research project with us, please refer to your project consent form for full details on who your personal data will be shared with, and how this will be done.
9. International Transfers
Your Personal Data may be processed outside the UK / European Economic Area (“EEA”). This is because the organisations we use to provide our services to you are located outside of the UK/EEA.
We have taken appropriate steps to ensure that the Personal Data processed outside the UK/EEA has an essentially equivalent level of protection to that guaranteed in the UK/EEA. We do this by ensuring that:
- Your Personal Data is only processed in a country which the UK Secretary of State and European Commission has confirmed has an adequate level of protection (an adequacy decision); or
- We enter into International Data Transfer Agreement/International Data Transfer Addendum or Standard Contractual Clauses (whichever is applicable) with the receiving organisations and adopt supplementary measures, where necessary.
A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk) and a copy of the SCCs can be found here Standard Contractual Clauses (SCCs) .
10. Your rights and how to complain
You have certain rights in relation to the processing of your Personal Data, including to:
- Right to be informed
You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.
- Right of access (commonly known as a “Subject Access Request”)
You have the right to receive a copy of the Personal Data we hold about you.
- Right to rectification
You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Right to erasure (commonly known as the right to be forgotten)
You have the right to ask us to delete your Personal Data.
- Right to object to processing
You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.
- Right to restrict processing
You have the right to restrict our use of your Personal Data.
- Right to portability
You have the right to ask us to transfer your Personal Data to another party.
- Automated decision-making.
You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
- Right to withdraw consent
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
- Right to lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at: Contact us | ICO
Or by telephone on: 0303 123 1113
For supervisory authorities in other countries within the EU see the link below:
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
11. Children’s Privacy
We do not offer our products and services directly to children, and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.
12. How to contact us
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
Origins, Bedrock Healthcare Communications
One Fleet, Ancells Road, Fleet, Hampshire, GU51 2UN
firstname.lastname@example.org | 01252 240200
13. Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time. We will notify of the changes where required by applicable law to do so.
Last modified June 2023