Last Updated: May 2023

This privacy notice is intended for potential and actual clients, suppliers/service providers, healthcare professionals and other experts whom we provide services to or receive services from, website users, alumni network members, research participants, recruitment candidates and work experience students. In this notice, we outline how Costello Medical collects and processes your personal data, whether provided to us by you or a third party.

It is important that you read and understand this privacy notice. Costello Medical is responsible for deciding how we hold and use your personal data; therefore, we are acting as the “data controller”. We are required under data protection legislation to notify you of the information contained in this privacy notice.

We reserve the right to update this privacy notice at any time.

Contents

  1. Important Information about Costello Medical
  2. The Data We Collect About You and How We Use Your Personal Data
    • Clients and Potential Clients
    • Suppliers and Service Providers, Healthcare Professionals and Other Experts from Whom We Receive Services
    • Website Users
    • Alumni Network
    • Research Participants
    • Recruitment Candidates
    • Work Experience Students
  3. How Your Personal Data is Collected
  4. Our Legal Basis for Processing Personal Data
  5. How We Share Your Personal Data
  6. Data Security
  7. Your Legal Rights
  8. Retention and Deletion
  9. Third Party Links
  10. Further Details
  11. Contact Details
  12. Glossary
  13. Schedule 1: Sub-Processors of your Personal Data

Important Information About Costello Medical

The Costello Medical Group is made up of different legal entities, located in the UK, US, Singapore and China. When we mention “Costello Medical”, “we”, “us” or “our”, we are referring to Costello Medical Consulting Limited, the UK-domiciled parent company of the Costello Medical Group, and also to its subsidiaries.

Our Information Governance Team oversees data protection-related matters and are responsible for ensuring that your personal data is appropriately secure. If you have any questions about this privacy notice or our data protection practices, please contact the Information Governance Team through our contact details listed below.

Costello Medical Consulting Limited
4th Floor, 50/60, Station Road, Cambridge, CB1 2JH
Information Governance Team: InfoGov@costellomedical.com
T: +44 (0)1223 913 020

The Data We Collect About You and How We Use Your Personal Data

We will only use your personal data for the purpose for which we collected it and in accordance with your relationship with Costello Medical.

We may 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.

1.

Clients and Potential Clients

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, username or similar identifier, title, gender.
  • Contact Data: email address, telephone number, social media account details.
  • Technical Data: internet protocol (IP) address, your 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 services, website and applications.
  • Profile Data: any username and passwords required to utilise our services, purchase orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data: information about how you use our website, apps and services.
  • Image Data: photographs, video and audio recordings.
  • Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.

We will process your personal data primarily to manage our relationship with you and to enable our provision of services to you, which may include:

  • Processing requests, applications, or tenders from you;
  • Maintaining internal records regarding our relationship with you, including our contacts database;
  • Fulfilling our contractual obligations to you;
  • Correspondence about Costello Medical and its services, or recommending collaborations which may be of interest to you;
  • Collecting feedback on the services provided to you; and
  • Dealing with legal disputes involving you or parties you represent.

2.

Suppliers and Service Providers, Healthcare Professionals and Other Experts from Whom We Receive Services

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, username or similar identifier, title, gender.
  • Contact Data: address, email address, telephone number, social media account details.
  • Financial Data: bank account, payment details, insurance details, and employment status.
  • Education Data: professional training, academic qualifications, skills, and professional organisation membership/registration details.
  • Transactional Data: details about payments to and from you and other details of products and services purchased from or by us.
  • Technical Data: internet protocol (IP) address, your 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 services, website and applications.
  • Profile Data: any username and passwords required to utilise our services, purchase orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data: information about how you use our website, apps and services.
  • Image Data: photographs, video and audio recordings.
  • Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.

We will use your personal data most commonly for the following purposes:

  • To fulfil our contractual obligations to you;
  • To evaluate your expertise and/or services for a possible collaboration with you;
  • To facilitate business relationships in our network by maintaining information about those with expertise within the pharmaceutical, MedTech, life sciences and/or healthcare sectors, which may include recommending your services /expertise to our clients; and
  • To deal with legal disputes involving you.

3.

Website Users

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name.
  • Contact Data: email address, telephone number.
  • Technical Data: internet protocol (IP) address, your 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 services, website and applications.

We will use your personal data for the following purposes:

  • If you complete a form through the Costello Medical website (e.g. to obtain further information on our services, or to register your interest in new job vacancies), we will use your information to action such form (e.g. to respond to the request or add you to the recruitment mailing list).
  • We may collect information about your use of our website. For further information on this, please see our Cookie Policy.

4.

Alumni Network Members

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, title, gender.
  • Contact Data: email address, telephone number, social media account details.
  • Employment and Education Data: employment history, professional training, academic qualifications, skills.
  • Image Data: photographs, video and audio recordings.
  • Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.

If you register to join the Costello Medical Alumni Network as a former Costello Medical employee, we will use your personal data to:

  • Keep you up-to-date with exciting news from Costello Medical as we grow, such as new services, offices and teams;
  • Invite you to catch-up with both past and present Costello Medical colleagues at Alumni Network events; and
  • Enable you to explore potential job opportunities that are available across our offices.

5.

Research Participants

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, title.
  • Contact Data: email address, telephone number.
  • Other Data: any additional personal information which you may choose to disclose to us, including in the context of your responses to any study/survey questions.

We will use your personal data for the following purposes:

  • To register your interest in participating in a study/survey.
  • To analyse the outcomes of and produce/publish findings from any study/survey which you choose to participate in.

6.

Recruitment Candidates

We may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, title, date of birth, and gender.
  • Contact Data: address, email address, telephone number, employment references, social media account details, and educational references.
  • Financial Data: bank account, payment details, and employment status.
  • Employment and Education Data: employment and job application details such as employment history, education, professional training, academic qualifications, skills, and professional organisation membership/registration details.
  • Recruitment Information: copies of right to work documentation, passport or other identity evidence, and other information included in a CV or cover letter or as part of the application process.
  • Personal Interests: work, undertakings or other financial interests in the pharmaceutical, medical technology, life sciences and/or healthcare sectors.
  • Diversity-Related Data: age, disability, gender or gender identity, race or ethnicity, sexual orientation, trade union membership, socioeconomic status or information about your health.
  • Technical Data: internet protocol (IP) address, your 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 services, website and applications.
  • Usage Data: information about how you use our website, apps and services.
  • Image Data: photographs, video and audio recordings.
  • Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences.

We will use your personal data for the following purposes:

  • Processing your application: Your personal data will be used to determine your suitability to the role which you are applying for as well as your suitability to Costello Medical as a company. Having received your CV and covering letter, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to progress your application and further assess your suitability.
  • Pre-employment screening: Your identification information will be used to verify your right to work in the location to which you are applying. If we decide to offer you the role, we will then take up references and may carry out background and other checks before confirming your appointment. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
  • Legal compliance: If you wish to disclose details of any disabilities, this will be used to consider whether we need to provide reasonable adjustments during the recruitment process, for example whether adjustments need to be made so that you will not be at a disadvantage during a test or interview.
  • Diversity hiring goals for equal opportunities monitoring: Diversity-related data will be used to monitor equality of opportunity and treatment in recruitment and will be aggregated so that it is held in an anonymised format. This data includes age, disability, gender/gender identity, race/ethnicity, sexual orientation, and socio-economic status. The data mentioned in this paragraph will not be used for any other purpose. Specifically, the decision to disclose or withhold any of this information, or the details of any information provided, will not be considered when determining your suitability to the role which you are applying for, nor your suitability to Costello Medical as a company.

7.

Work Experience Students

If you participate in a work experience programme at Costello Medical, we may collect, use, store and transfer different kinds of personal data, including those set out below:

  • Identity Data: name, date of birth.
  • Contact Data: address, email address, telephone number, and contact details for a parent /guardian.
  • Education Data: education, academic qualifications, skills.
  • Image Data: photographs, video and audio recordings.

We will use your personal data to:

  • Run the programme, including contacting you and/or your parent or guardian before, during and after the programme, as required; and
  • Where you have provided your explicit consent, to create and distribute marketing material, which may include displaying your image (whether in a photograph or video) on our website, social media and/or promotional materials.

Please be aware that, by consenting to Costello Medical publishing a photograph and/or video in which you feature online and/or in promotional materials, your personal data may be processed by other third parties outside of Costello Medical’s control. Costello Medical’s ability to restrict the processing of your personal data will be limited to Costello Medical-controlled processing only.

How Your Personal Data is Collected

We collect personal data from you directly when you get in contact with us and use our services. We may combine the information you provide with other information from other sources, such as professional social media platforms and external third parties.

We will collect additional personal data in the course of our services-related activities throughout the period of our working relationship with you.

If you submit any personal data relating to another individual to us, we expect that you have the requisite authority to do so.

Your duty to inform us of changes

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.

Costello Medical will not process personal data without having a legal basis for doing so. The legal bases that Costello Medical may rely on include:

  • Your consent;
  • A contractual requirement necessitating the processing of your personal data;
  • A legal obligation which is binding upon Costello Medical; and/or
  • Our own or a third party controller’s legitimate interests, which does not disproportionately curtail your rights and freedoms.

Where Costello Medical is relying on legitimate interests to process personal data, we have conducted a legitimate interest assessment. Occasions where we may be relying on legitimate interests as our legal basis for processing personal data include:

  • Creating and maintaining professional network databases;
  • Operating our alumni network;
  • Creating and distributing marketing materials that incorporate personal data; and
  • Carrying out business development activities with new and/or existing clients or suppliers.

How We Share Your Personal Data

We may share your personal data with:

  • Other entities within the Costello Medical Group;
  • Trusted 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; and
  • Legal and regulatory bodies which require such disclosure.

We may additionally share your personal data with third parties where required by law, where it is necessary to fulfil our contractual obligations with you or where we have another legitimate interest in doing so.

The Costello Medical Group operate globally and so we may transfer, store and process your personal data outside of the country where it is collected. If we do transfer data internationally, all transfers will be compliant with applicable data protection legislation.

Data Security

All entities in the Costello Medical Group adhere to appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

All relevant third-party service providers are assessed and required to have appropriate security measures in place to protect your personal data. 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Under certain circumstances, by law you have the right to:

  • Request access to your personal data. 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 your personal data. 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.
  • Request restriction of processing 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 transfer of your personal data. 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 listed above, please contact the Information Governance Team in writing (InfoGov@costellomedical.com). We will respond to your request within one calendar month.

In addition, you have the right to make a complaint at any time to your local data protection authority with respect to data protection issues. However, we will endeavour to resolve any complaint you may have in the first instance, and request you contact Costello Medical first to resolve any issues you may have regarding our processing of personal data.

Retention and Deletion

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Third-Party Links

Our website or applications 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 or application, we encourage you to read the privacy policy of every platform you visit.

Further Details

If you are looking for more information on how we process your personal data including on data security, data retention and lawful processing bases, please email the Information Governance Team using the contact details listed below.

Contact Details

Costello Medical Consulting Limited
4th Floor, 50/60, Station Road, Cambridge, CB1 2JH
Information Governance Team: InfoGov@costellomedical.com
T: +44 (0)1223 913 020 

Glossary

Costello Medical Group:

  • Costello Medical Consulting Limited, located in Cambridge, U.K.
  • Costello Medical Singapore Pte. Ltd., located in Singapore
  • Costello Medical Inc., located in Boston, Massachusetts, U.S.A.
  • Costello Medical Shanghai, located in Shanghai, China

Schedule 1

Sub-processors of your personal data

Below are details of key services providers and group entities; depending on the scope of relevant activities, these suppliers and group entities may be involved in the processing of personal data.

Name Location of Data Processing Purpose of Processing
Costello Medical Inc. US To improve business effectiveness across the global organisation, including facilitating day-to-day operations, effective communication, financial administration, supplier management and IT system management
Costello Medical Singapore Singapore
Costello Medical Shanghai Shanghai
Cubic Interactive Limited UK Project and customer relationship management
Druva Europe Limited UK Data backup
Egnyte, Inc. UK and EU Cloud-based file server
Little Fish (UK) Ltd UK IT services provision and administration
Microsoft Corporation UK, EU, and US Productivity applications and services
Workable UK, EEA and US Recruitment management and administration
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