Redx Privacy Notice
Redx Pharma discovers and develops proprietary, small molecule drugs to address areas of high unmet medical need in cancer and fibrosis. In both therapeutic areas we aim to develop drugs whose profile suggests they will be best in class, if not first in class.
This privacy notice explains what personal data we collect, when and why we collect it, how we use it, how long we keep it, the conditions under which we may share it with others, how we keep it secure and your rights.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Redx collects and processes your personal data. By personal data, we mean any information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data).
Our website is not intended for children and we do not knowingly collect personal data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Redx Pharma Plc is the controller and responsible for your personal data (collectively referred to as Redx Pharma, “we”, “us” or “our” in this privacy notice).
We have appointed a GDPR Representative who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the GDPR Representative using the details set out below.
Our full details are:
Full name of legal entity: Redx Pharma Plc
Name & Title of GDPR Representative: Andrew Booth, Group Company Secretary
Email address: email@example.com
Postal address: Redx Pharma Plc, Block 33, Mereside, Alderley Park, Macclesfield, SK10 4TG
Telephone number: 01625 469 900
You have the right to make a complaint at any time to the 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 notice and your duty to inform us of changes
This version was last updated on 25 May 2018
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.
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 notice of every website you visit.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account
- Usage Data includes information about how you use our website.
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, a contract of employment). In this case, we may not be able to proceed in to offering you a job with us but we will notify you if this is the case at the time.
2. 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 and Financial Data by submitting your CV (and if successful in your application, completing our application form) and by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for a job vacancy with us
- Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Usage Data from the following parties:
- search information providers.
- Identity Data and Contact Data from data brokers or aggregators.
- Identity Data and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
For further information about which third parties we receive information from about you please contact us using the details in Section 1.
3. 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 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 or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the personal data we may collect from you (from when you apply for a role with us to being offered a job with us), where we collect it from, why we collect it 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.
|What data is collected||How Data is collected||Reason for Data Collection|
|Full Name||CV, New Starter Form||Necessary to perform a contract with you & to comply with our legal obligation to ensure we know who we are employing.|
|DOB||New Starter Form, P45/P46||Necessary to perform a contract with you & to comply with our legal obligation to ensure we know that the person is old enough to work and to provide this information to HMRC for the purposes of calculating tax, NI.|
|Address||CV, New Starter Form||Necessary to perform a contract with you.|
|NI Number||New Starter Form, P45/P46||Necessary to comply with a legal obligation – and to provide this information to HMRC for the purposes of calculating tax, NI.|
|Gender||New Starter Form||Our legitimate interest for the purposes of equality monitoring.|
|Telephone Number||CV, New Starter Form||Our legitimate interest so that we can contact you regarding your application.|
|Email address||CV, New Starter Form||Our legitimate interest so that we can contact you regarding your application.|
|Next of Kin Details||New Starter Form||Our legitimate interest, and necessary to comply with a legal obligation, in case of an incident at work where the employee is injured and we need to contact someone to let them know.|
|Emergency Contact Details||New Starter Form||Our legitimate interest, and necessary to comply with a legal obligation, in case of an incident at work where the employee is injured and we need to contact someone to let them know.|
|Salary||Contract||To perform a contract with you as that is what we pay you in salary.|
|Bank Details||New Starter Form||To perform a contract with you as that is what we pay your salary into.|
|Previous employment details||CV||Our legitimate interest to ensure, where we have offered you a role, that you have the right skills, experience, qualification to fulfil the role.|
|Education History||CV||Our legitimate interest to ensure, where we have offered you a role, that you have the right qualifications to fulfil the role.|
|Previous employer contact details||New Starter Form||Our legitimate interest to ensure where we have offered you a role, that you have the right skills, experience, qualification to fulfil the role.|
|Health Declaration Form||Health Declaration Form||Our legitimate interest to ensure we are aware of any health issues which we may need to support, make reasonable adjustments for etc.|
|Tax Code||P45/P46||Necessary to comply with a legal obligation – legally required by HMRC for tax calculations.|
|Proof of Qualification||Copy of certificates||Our legitimate interest to ensure where we have offered you a role, that you have the right qualifications to fulfil the role.|
|Right to Work Documentation||Copy of passport, birth certificate||Necessary to comply with a legal obligation – to ensure right to work in the UK.|
|DIS Scheme form – included personal details of intended recipients||DIS Scheme form||Our legitimate interest to be able to provide details to our Death in Service provider in the case of employee death for the purpose of our Death in Service benefit.|
|Car Details||New Starter Form||Our legitimate interest to enable us to register the car with site security so a unique car parking pass can be issued by the site|
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities.
- 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 notice.
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.
We do not transfer your personal data outside the European Economic Area (EEA).
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.
7. Data retention
How long will you use my personal data for?
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.
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 requirements.
By law we have to keep basic information about our clients (including Identity, Contact and Financial Data) for six years after they cease being client for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
8. 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 to access 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 us
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 may 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 may 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.