Last Updated: 7th April 2021
Welcome to Costello Medical’s privacy notice.
Costello Medical provides scientific support to the healthcare industry in the analysis, interpretation and communication of clinical and health economic data.
Costello Medical are committed to responsibly handling your personal data with respect for individual privacy. This notice is meant to help you to understand how Costello Medical will process any personal data we collect when you visit our website (regardless of where you visit it from) 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. Please refer to the Glossary to understand the meanings of any terms used throughout this notice.
- Important information
- The data we collect about you
- How your data is collected
- How we use your data
- Disclosure of data
- Data security
- Data retention
- Your legal rights
Purpose of this notice
This privacy notice aims to give you information on how Costello Medical collects and processes your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
Information about us
Costello Medical Consulting Limited is the data controller responsible for this website and protecting personal data which you provide to us. We are registered in England and Wales at 4th Floor, 50/60 Station Road, Cambridge, CB1 2JH, England, under company number 06746770.
Costello Medical Consulting Limited and its affiliated companies will be collectively referred to as “Costello Medical”, “we”, “our” and “us”, and this privacy notice will apply to any interactions with such affiliated companies.
If you have any queries about this policy, please contact our Data Protection Team by emailing firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. The date at the top of this privacy notice indicates when it was most recently updated.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, and gender.
- Contact Data includes email address and telephone numbers.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.
We do not collect any Special Categories of Personal Data about you.
How your data is collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you give us feedback or contact us.
How we use your data
We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
||Type of Data
||Lawful basis for processing
|To respond to enquiries submitted through our website, post, phone, email or otherwise
||Necessary for our legitimate interests (to develop our products/services and grow our business)
Disclosure of data
We do not sell or otherwise disclose your personal data except as described herein or otherwise disclosed to you. We may share your personal data with the parties set out below for the purposes set out in the table above.
- Costello Medical Group Companies as set out in the Glossary.
- External Third Parties as set out in the Glossary.
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.
Costello Medical is a global company with offices located internationally in the UK, USA, Singapore and China. We may transfer the information we collect about you to countries other than your home country or other than the country in which the information is originally collected as your personal data will be accessible by our other offices internationally. We will maintain the necessary security measures to prevent unlawful access, loss, destruction or damage to any of your personal data in accordance with the legal requirements and as described in this privacy notice.
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.
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.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your personal data: see Your legal rights below for further information.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you would like to make a data subject access request in exercise of the above rights, please submit a request by contacting email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Costello Medical Group Companies:
- Costello Medical Singapore Pte. Ltd., located in Singapore
- Costello Medical Inc., based in Boston, Massachusetts, USA
- Costello Medical Shanghai
External Third Parties:
- Accredited third party service providers for our legitimate business interests, including IT infrastructure management or hosting our data on cloud platforms;
- Professional advisers including solicitors, accountants, auditors and insurers who provide consultancy, legal, insurance and accounting services to us;
- Legal and regulatory bodies which require such disclosure.
Special Categories of Personal Data: 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.
Usage Data: information about how you use our website.