Privacy Policy
This Privacy Notice (“Privacy Notice”) explains and describes our policy regarding the personal data WEP Clinical (“WEP” or “We”) collect, use and disclose about individuals. This includes patients, healthcare professionals, customers, suppliers, vendors, business partners, and all other persons whose personal data is processed.
WEP values and respects your privacy regarding personal data and is committed to protecting your personal data, which we process, and this is why we process individual personal data in accordance with all relevant legal requirements. This policy aims to provide you with information in relation to how WEP collects and processes your personal data.
WEP is a provider of clinical supply and management services globally and may share information across international borders. WEP performs international sharing and hosting of data in accordance with appropriate regulatory processes where legally mandated and in accordance with the relevant legislation.
This policy sets out:
- How we use and disclose personal data;
- Individual Rights;
- The legal grounds which allow us to process your personal data;
- Where the data comes from, who gets to see it and how long we retain it for;
- Data Security;
- Retention Period;
- Cookies;
- Cross border transfer;
- Changes;
- Lodging complaints with a Regulator; and
- How to contact us.
Personal data means any information that relates to you, which can be used to identify you directly or indirectly. We collect Personal Data in various ways, on our website, as well as other sources such as for WEP to provide the requested services.
WEP adheres to data protection and privacy legislation and regulations, including but not limited to:
- EU GDPR, UK GDPR and Data Protection Act 2018;
- The US Federal Privacy Act of 1974;
- The US Health Insurance Portability & Accountability Act of 1996;
- International Conference on Harmonisation (ICH) Good Clinical Practice (GDP);
- The Canadian Personal Information Protection and Electronic Documents Act 2000;
- The Singaporean Personal Data Protection Act 2012;
- The Swiss Federal Act on Data Protection 2020; and
- The Australian Privacy Act 1988 (Privacy Act) as amended 2014 and 2017.
We have a legal obligation to ensure that we use any personal data supplied by you, in a fair and transparent manner, and we must explain how we use it.
We strive to only collect and share information when required for the purposes for which it has been sought. We may share your personal data with sponsors of Expanded Access Programs, Named Patient Programs, clinical trials, investigators of clinical trials, agents, suppliers, group affiliates and other third parties. However, any personal data collected and processed by WEP will have a lawful basis for processing, as provided and pursuant to all applicable data protection legislation.
We may collect, transfer, use and store various types of personal data, which include the following:
- Basic medical/health data – this will be data provided by the healthcare professional in order for WEP to provide the services.
- Contact data – email address, telephone numbers, delivery address and billing address.
- Personal Data in relation to Marketing and communication data, enquiries and social media. We use the following personal data: title, name, institution, telephone number, email address to communicate marketing newsletters to you. You may receive marketing newsletters from us. Our newsletters and marketing materials give you the option to “opt out”. If you decide to opt out of receiving our marketing messages or newsletters we will accept this request and automatically refrain from contacting you in this regard. The legal basis for this processing is your consent Article 6(1)(a) of the UK GDPR or our legitimate interest Article 6(1)(f) of the UK GDPR.
- Identity data, name, identifier, professional credentials, gender, data of birth.
- Employee and Identity data. We collect personal data from our employees for standard business operations, such as contact details, qualifications, and payroll information. The legal basis for this is our legitimate interest within the meaning of Article 6(1)(f) of the UK GDPR.
- Website User Data. We use cookies to collect website usage data for various purposes noted below. This information collected cannot be used to identify individuals. The legal basis for this is our legitimate interest within the meaning of Article 6(1)(f) of the UK GDPR.
- Data from business partners/vendors/suppliers/customers and healthcare providers. This is data from customers or business partners that WEP processes in the course of business. This can include contact details, email addresses, telephone and information about the business relationship. We process this data for the purposes of conducting business relationships, processing orders and responding to any enquiries. The legal basis for this is our legitimate interest within the meaning of Article 6(1)(f) of the UK GDPR as this is required in order for a business relationship to be formed. Without this data, it would not be possible to conduct the business relationship.
- Personal Data in email correspondence. We process personal data in the scope or body of email correspondence such as: personal data of the sender and recipient (the name, title and telephone number) and any other personal data that is found in an email signature. The legal basis for processing this data is Article 6(1)(f) of the UK GDPR and our legitimate interest is to communicate with other employees and stakeholders as appropriate to conduct business communication with other professionals in relation to the purpose of our business.
- CCTV/video and visitor registration. When visiting our offices or warehouses where applicable we have CCTV installed and request that visitors are registered. This personal data can include but not be limited to: name, occupation, reason for visit, telephone number and relevant information to ensure the identity of the individual is captured and where applicable video recordings. The legal basis for this is our legitimate interest within the meaning of Article 6(1)(f) of the UK GDPR. We process this data to ensure the security and safety of both our staff and visitors when on our premises.
In accordance with the provisions provided by the GDPR specifically Articles 13 and 14, you can exercise the following rights:
- Right to be informed – you have the right to informed about the collection and use of your personal data.
- Right to access – you are entitled to receive a copy of all personal data WEP hold about you and ask any questions in relation to how it is processed. Please send all requests to the details as provided below.
- Right to rectification – you are entitled to request any inaccurate, incomplete personal data WEP holds about you, to be corrected and completed. If any of the personal data WEP holds is inaccurate or incomplete, WEP will correct it and where practicable destroy the inaccurate information.
- Right to erasure (“right to be forgotten”) – you can make a request for erasure and require WEP to remove all personal data held about you, and consent can be withdrawn to processing at any time, as long as there is no overriding obligation on us to process personal data. This request can be made at the details provided below.
- Right to restrict processing – you have the right to request restriction of your personal data in certain circumstances. You have the right to withdraw your consent if the processing is based on your consent.
- Right to portability – you are entitled to receive the personal data you have provided to us, in a structured, commonly used and machine-readable format.
- Rights in relation to automated decision making – this includes any profiling, where you have the right to object to be part of any automated decisions.
- Right to object – you have the right to object to your personal data being processed, specifically in certain circumstances.
In order to exercise any of your rights above, if you believe WEP Clinical are not handling your personal data in accordance with applicable data protection laws, you have the right to lodge a complaint. You can contact us at the details provided below. In the event any information we hold in relation to you in accurate, we are obliged to correct and rectify it.
Additionally you have the right to lodge a complaint with the regulator, if you are not happy or have any concerns around the manner in which we have handled your personal data, we have provided the details below.
We utilise appropriate technical, administrative, and organisational safeguards to protect personal data from unauthorised use, disclosure, alteration or destruction, to ensure compliance to the Data Protection legislation and regulations. This includes limiting access to essential personnel and persons, minimising data sharing, and using password protection, encryption and pseudonymisation. However, WEP cannot 100% guarantee the storage and security of such information. To the fullest extent permitted by law, WEP disclaims all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alteration of any information you submit to our website.
Data stored in a third country is held with a reputable global data storage provider in accordance with globally recognised privacy standards.
Access to information is restricted to appropriate staff and persons, both internally and externally. WEP Clinical does not sell or trade personal information. We will use and disclose your personal data as we believe it to be necessary or appropriate in order to comply with applicable law and regulatory monitoring and reporting obligations, as well as having lawful grounds to do so.
We will retain your personal data for long is as necessary for the purpose for which the personal data was collected and to the extent required by applicable law. We will remove any personal data we no longer require, safely and securely or alternatively take steps to anonymise it.
Automated Decision Making & Profiling.
WEP Clinical does not make any decisions in respect of the personal information, solely by automated means without human involvement.
What are cookies?
Cookies are small text files that are stored on your electronic device like a computer, tablet or mobile phone when you visit a website. They are widely used to make a website work more efficiently.
How we use cookies & how to control your cookies
We use cookies on the WEP website to ensure we are providing the best possible experience for visitors to our website. Please see below a brief explanation of the cookies that we use and why:
- Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
- Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
- Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
- Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
The WEP website may contain links to other websites that we do not own or operate. We do not control, recommend, or endorse and are not responsible for these websites or their content, products, services or privacy policies. Downloading material from certain websites may risk infringing intellectual property rights or introducing viruses into your system. When you leave the WEP website, you should read the privacy and cookie policies of these other websites.
Some data we collect may be stored and processed in any country where we engage in services or service providers, including the U.S. and where our affiliates operate.
There are some non-EEA countries which are recognised by the European Commission and the Information Commissioner’s Office as having adequate levels of data protection according to EEA standards. For any transfers which are considered to be inadequate by the European Commission and the Information Commissioner’s Office, we have put in place measures which are adequate in order to ensure compliance and protect your Personal Data. These measures are pursuant to the European Commission and the Information Commissioner’s Office. We ensure that the recipient is bound the required and compliant contractual documentation including but not limited to the EU Standard Contractual Clauses and the UK Addendum in order to protect your Personal Data.
We may modify this Policy from time to time. Any changes and the updates will be posted on this website. This policy is not a contract and does not create any legal rights or obligations.
To request a copy of your information, or request to exercise any of your individual rights, please email: or dataprivacy@wepclinical.com or legal@wepclinical.com
Write to us at:
111 Power Road
Chiswick
London
W4 5PY
An individual’s access to and use of the Site and its contents are subject to the terms and conditions of this Privacy Policy and all applicable laws. By accessing and using the Site, Site users accept and agree to these terms and conditions without any limitation or qualification. Use of the Site is also subject to the Terms of Use posted on the Site (“Terms of Use”).
Effective date – October 2024