fbpx

PRIVACY STATEMENT / POLICY (Updated 29.06.20)

Our contact details:

Circular1, Warwick Mill, Warwick Mill Business Village, Warwick Bridge, Carlisle, Cumbria, CA4 8RR

[email protected]

+44(0)1556 510 576

www.circular1.com

Circular1 Group (“Circular1”)

Privacy Policy

Introduction

Circular 1 respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect and use personal data about you and tells you about your privacy rights and how the law protects you. 

Circular 1 provide world-leading COVID-19 testing services in the United Kingdom (our “Testing Services”).

Controller

The Circular1 Group is the “data controller” responsible for your personal data (collectively referred to as “Circular 1”, “we”, “us” or “our” in this privacy policy). This means that we are responsible for deciding how we hold and use personal information. We are required under data protection laws to notify you of the information contained in this policy. 

The Circular 1 Group is made up of different legal entities, details of which can be found in our website footer. 

  • Circular1 Health Limited, company number 12700350 whose registered office is at Warwick Mill, Warwick Mill Business Village, Warwick Bridge, Carlisle, Cumbria, CA4 8RR
  • Circular1 Investments Limited, company number SC534604 whose registered office is at Suite 12 River Court, 5 West Victoria Dock Road, Dundee, DD1 3JT Scotland

This privacy policy is issued on behalf of the Circular1 Group so when we mention “Circular1”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Circular1 Group responsible for processing your data. 

We will let you know which entity will be the controller for your data when you purchase a product or service from us or interact with our Testing Services.

If you are a past or present employee, director, contractor or consultant of Circular1, we will hold further personal data about you. For further details please contact our Data Privacy Officer or speak to your line manager or supervisor.

This policy does not form part of any contract that you may have with Circular1. It is provided for information purposes only.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Circular1 collects and processes your personal data, particularly where you interact with our COVID-19 Testing Services.

We do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them. 

Data Privacy Officer

We have appointed a Data Privacy Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact the our Data Privacy Officer using the details set out below. 

Name:  Realise HR, Data Privacy Officer

Email address:  [email protected] (ref. Lorraine Millican)

Postal address: Circular 1, Warwick Mill Business Village, Warwick Bridge, Carlisle, Cumbria, CA4 8RR 

Complaints

You have the right to make a complaint at any time to the UK Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. 

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.

Third-party links

Where this privacy notice is published on our website, please note that our 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 do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

  • 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, last name, username or similar identifier, date of birth, sex (M/F) and occupation.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Special Category Data includes ethnicity, Test Result (and date of most recent test).
  • Technical Data includes 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 our website. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Anonymised or Aggregated Data such as statistical or demographic data for any purpose. Anonymised or 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 report to the Office of National Statistics about the number of positive or negative tests we have carried out in any particular area or time.  However, if we combine or connect Anonymised or 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 policy.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with swabs or our Testing Services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Special Category and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our Testing Services;
  • request marketing to be sent to you; or
  • give us feedback or contact us. 
  • Interactions with your employer.  Your employer may give us your Identity, Contact or Special Category Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when your employer applies for our Testing Services for you.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to perform the contract we are about to enter into or have entered into with your employer.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation, such as to report positive test results to Public Health England.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us 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. 

Please note that “Legitimate Interest” in the table below means the interest of our business in conducting and managing our business to enable us to give you the best Testing Services and products and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer 

(a) Identity 

(b) Contact

Performance of a contract with you

To provide Testing Services to you as a customer

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity 

(b) Contact 

(c) Special Category

(d) Financial 

(e) Transaction 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) Medical diagnosis (Special Category only)

To provide Testing Services to your employer in respect of you 

(a) Manage payments, fees and charges owed to us by your employer

(b) Collect and recover money owed to us by your employer

(a) Identity 

(b) Contact 

(c) Special Category

(d) Financial 

(e) Transaction 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to provide our Testing Services to your employer in respect of you and to recover debts due to us by your employer)

(c) Preventative or occupational medicine, to assess the working capacity of the employee, medical diagnosis (Special Category only)

To report Test Results to your employer, to your GP, to Public Health England or any other applicable regulatory, occupational health, NHS or other health body

(a) Identity 

(b) Contact 

(c) Special Category

(a) Necessary for our legitimate interests (to provide our Testing Services to you or your employer in respect of you) 

(b) Necessary to comply with a legal obligation 

(c) Preventative or occupational medicine, to assess the working capacity of the employee, medical diagnosis (Special Category only)

(d) Public interests in the area of public health (Special Category only)

(e) Research and statistics (Special Category only)

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) 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 reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical 

(b) Usage 

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)
To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(e) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

We may send you marketing communications if you have requested information from us or you have purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting our Data Privacy Officer at any time

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your interaction with our Testing Services.

Change of purpose 

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 contact us. 

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.

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.

 

  • Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties

Other companies in the Circular1 Group acting as joint controllers or processors and who are based in the UK and/or EEA and provide IT and system administration services, laboratory and testing services, and undertake leadership reporting. 

  • External Third Parties

Service providers acting as processors based within the UK and/or the EEA who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and/or the EEA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Specific third parties listed in the table such as your GP, your employer and your employer’s occupational health provider, (but only where your employer has engaged us to provide Testing Services to you), Public Health England, NHS or other health bodies.

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 policy. 

We may share Anonymised or Aggregated Data (but not personal data) with the Office for National Statistics, Public Health England and other University, NHS or health body for research and statistical purposes including for the purposes of mapping regional behaviours and dynamics, and the spread of viruses and diseases including but not limited to SARS CoV-2 the virus that causes COVID-19.

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.

 

  • International transfers

If we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Information Commissioner. 
  • Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK Information Commissioner which give personal data the same protection it has in Europe and/or the UK. 
  • Where we use providers based in the US, we may transfer data to them if they are part of the EU/US Privacy Shield or UK/US Privacy Shield which requires them to provide similar protection to personal data shared between Europe/the UK and the US.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

 

  • Data security

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.

 

  • Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any public health, statistical, legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your employer.

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.

We will typically delete personal information about Test Results after three years (under review in line with GOV.UK). 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal and/or tax purposes.

By law we have to keep basic information about Test Results for 6 years. (Last name, mobile phone number, Test result at the last time of testing).

In some circumstances you can ask us to delete your data: see Section 8 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

 

  • Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

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.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Officer. 

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.