Fresenius Kabi Limited and Calea UK Limited have issued this data protection statement to describe how we handle personal information relating to healthcare professionals when using our MOTIV. The data protection statement sets out the personal information that we collect and process when you use the portal. If you have any comments or questions about this data protection statement, then you can contact us at the details in section 12 attached.
2. Purpose of this statement
This data protection aims to give you information as to how we collect and process information when you use the portal. It is important that you read this statement together with any other privacy notice or data protection statement that we provide: ▪ You can find out how we process your information as healthcare professionals and/or business contacts here Data Protection Statement for Healthcare Professionals - Fresenius Kabi GB
3. About the training portal:
The eLearning portal uses a third-party content management system which is operated by Docebo UK Limited who will host and process data on our behalf. We use other third parties to provide services to support the portal and its content including HRS Communications Ltd and The Creative Engagement Group. We have robust agreements and appropriate controls in place with our third-party providers to ensure that your data is processed only in accordance with our instructions. All information on the portal is hosted in the UK. You can find out more information about how Docebo process your data here https://www.docebo.com/company/compliance-security/
4. How is your information collected
You may receive any email from us letting you know that you can register to use the portal, or you can access the portal yourself.
Either way, you will need to register online to complete the self-registration form on the portal to confirm that we may process your personal information to the extent required for you to access the portal to register for the training portal.
5. Types of personal information we collect
The types of personal information we may process about you include but are not limited to:
- Identification data such as your first name, last name, title, the organisation you work for, job title, NHS Trust, NHS Hospital and department or ward.
- Your contact information including your email address.
- Technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and portal and other technology on the devices you use to access this website.
- Your profile information such as your username and password, your feedback and survey responses.
- Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
- Training records and learning progress.
6. The legal basis on which we process information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We may use your information in order to:
- Verify your identity for security purposes.
- Contact and/or provide information on training or events that you may be interested in.
- Feedback to your hospital trust on who has completed training (if pre-implementation for a pump).
- Comply with our Disclosure UK obligations.
The processing of your personal data is necessary for the performance of a contract to beconcluded between you and us (Art. 6.1 b, GDPR). The processing of your personal data is necessary for us in order to comply with a legal obligation we are subject to (Art. 6.1 c, GDPR).
More specifically we are obliged to comply with national and, if applicable, international laws and regulations relating to the fight against corruption, anti-money laundering, anti-terrorism financing and other economic crime. We have to assess the appropriateness of the remuneration and other payments made and other support granted to you and are subject to certain documentation, publication and reporting obligations and there, can be obliged to disclose the remuneration paid or other support in kind availed to you as a speaker or other service provider, to your employer or to competent regulatory authorities, criminal prosecutors and other recipients responsible for the implementation of transparency rules upon request, or make such payment and in-kind support available publicly. This includes particularly documentation, disclosure and reporting obligations in connection with medicines, medical devices and healthcare regulations, transparency laws, laws on anti-money laundering and self-regulatory regimes such as industry and patient codes.
7. Who we share your data with?
As set out in our statement we may share your data within the Fresenius Group. You can find out more details here https://www.fresenius-kabi.com/gb/data-protection-statement-for-healthcare-professionals.
When you are using the portal, your information will be hosted by Docebo.
We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
We may also share information on the training that you have completed on the portal with the organisation that you work for.
There may be situations where we are under a duty to share your information. For example, we may be required by law to report certain information – this includes Disclosure UK or if a formal court order has been issued. We may also have to share your information when it’s necessary for the prevention or detection of crime, prosecution of offenders, or where there are serious risks to the public or our staff. We will also share data with the connected contract hospital to ensure that relevant healthcare professionals within that trust have completed the required refresher clinical product training, that is to be completed every 12 months.
8. Data retention periods
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this statement.
For your information, we will retain this for as long as you are an active user of the portal and have a legitimate interest.
9. Your data privacy rights as a user of MOTIV
9.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes; for example, if you move roles, organisation or change your name.
9.2 If you wish to access, correct, update or request deletion of your personal information you can do so by contacting us using the contact details provided in section 12 below. You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided in section 12 below;
9.3 If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. Data Security
10.1 We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
10.2 Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
We may update this statement from time to time as necessary. The terms that apply to you are those posted here on the portal on the day you use the portal. We advise you to print a copy for your records.
12. Contact Us
If you have any questions regarding our data protection statement, please contact us at the address below.
Alternatively, you may raise any questions or requests with the local Data Protection Advisor by contacting email@example.com.
The Data Protection Officer for Fresenius Kabi is located in Germany and can be contacted at firstname.lastname@example.org.
Fresenius Kabi Limited Cestrian Court, Eastgate Way Runcorn, WA7 1NT United Kingdom E-mail: data.protection-UK@fresenius-kabi.com