Privacy Policy

Pattern Health Education Ltd is the data controller responsible for the personal information described in this Privacy Policy.

Privacy enquiries: privacy@patternhealth.co.uk

This Privacy Policy explains how we collect, use and protect personal information when you visit our website, contact us, purchase or access our educational products, or interact with us on behalf of an organisation.

Personal information we collect

Depending on how you interact with us, we may collect:

• your name;
• email address;
• professional role or job title;
• practice or organisation name;
• billing address;
• payment and transaction status;
• information required to create and administer a learner account;
• technical and access information associated with use of our website or programme platform; and
• information you provide when contacting us.

Website enquiries

If you use our website contact form, we may collect your:

• name;
• email address;
• organisation;
• role, if you choose to provide it;
• approximate learner numbers, where relevant and if you choose to provide them;
• enquiry type; and
• message.

We use this information to receive, manage and respond to your enquiry.

Please do not provide patient-identifiable information or personal health information through our contact form.

We do not ask for patient data or personal health information through our website or educational programmes.

How and why we use your information

We process personal information only where we have a lawful basis for doing so.

Contract

We may process your information where necessary to:

• process a purchase;
• provide access to an educational programme;
• administer your account or licence; and
• provide services you have purchased from us.

Legitimate interests

We may process your information where necessary for our legitimate business interests, including to:

• receive and respond to enquiries;
• communicate with prospective customers and organisations about our educational products and services;
• administer relationships with customers and organisations;
• operate, maintain and secure our website and services; and
• improve our services.

Where we rely on legitimate interests, we consider whether those interests are proportionate and balanced against your rights and interests.

Legal obligations

We may process and retain information where necessary to comply with legal, accounting, tax or regulatory requirements.

These distinctions are important because the ICO requires organisations to state both their purposes and lawful bases and, when relying on legitimate interests, explain what those interests are.

Service providers

We use trusted third-party service providers where necessary to provide website hosting and contact-form functionality, educational programme hosting and learner administration, payment processing, and business invoicing and administration.

These providers may process personal information on our behalf where necessary to provide their services.

Where required, we put appropriate data protection arrangements in place with service providers.

We do not sell your personal information.

This category-based disclosure is permitted under UK GDPR. The ICO says organisations may provide either recipients' names or the categories they fall within, provided categories are as specific as possible.

Website enquiries

Our website contact form sends the information you provide to Pattern Health Education so that we can respond to your enquiry.

Our website implementation does not intentionally store contact-form submissions in a separate website database.

Information may nevertheless be processed through the technical infrastructure and systems used to operate the website and deliver the enquiry to us.

If your enquiry subsequently results in a customer, contractual or organisational relationship, relevant correspondence may become part of our business records and may be retained for the applicable period described below.

How long we keep your information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including where retention is required for legal, accounting or regulatory purposes.

As a general rule:

• Website and institutional enquiries: we normally retain enquiry correspondence while the enquiry is active and for up to 12 months after the last meaningful interaction, unless it develops into an ongoing customer or contractual relationship or there is another legitimate reason to retain it.
• Learner and programme records: relevant learner and programme administration records may be retained for the duration of programme access and for up to 6 years afterwards, where necessary for business, contractual, accounting or legal purposes.
• Payment, invoice and accounting records: retained for up to 6 years, or longer where required by law.

Where information is no longer required, we will delete or anonymise it where appropriate.

The ICO requires privacy information to state the retention period or, where a specific period cannot be given, the criteria used to determine it.

International transfers

Some of the service providers we use may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we take steps to ensure appropriate protections are in place as required by applicable UK data protection law. These may include applicable adequacy regulations or approved contractual safeguards.

You can contact us at privacy@patternhealth.co.uk if you would like further information about safeguards relevant to your personal information.

Security

We take appropriate technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.

However, no internet-based service or method of electronic transmission can be guaranteed to be completely secure.

Cookies and similar technologies

Our website and educational programme platform may use cookies and similar technologies required for functionality, security and operation.

Our programme platform may use cookies and similar technologies for functions including account access, security, checkout and programme delivery.

Where non-essential cookies or similar technologies requiring consent are used, we will provide appropriate information and obtain consent where required by law.

Marketing communications

We do not sell personal information for marketing purposes.

We may contact existing customers or relevant business contacts about programme administration, service information and, where permitted by law, relevant educational products or updates.

Where a communication constitutes direct marketing, you can opt out at any time using any unsubscribe mechanism provided or by contacting:

privacy@patternhealth.co.uk

Service and administrative communications necessary to manage an account, purchase or programme are not marketing communications.

Your data protection rights

Depending on the circumstances and the lawful basis for processing, you may have rights including:

• access – to request a copy of personal information we hold about you;
• rectification – to ask us to correct inaccurate or incomplete information;
• erasure – to ask us to delete your information in certain circumstances;
• restriction – to ask us to restrict processing in certain circumstances;
• data portability – in circumstances where this right applies; and
• objection – to object to certain processing, including processing based on legitimate interests.

You have the right to object at any time to the use of your personal information for direct marketing.

These rights are not absolute and whether a particular right applies depends on the circumstances and our lawful basis for processing.

To exercise your rights, contact:

privacy@patternhealth.co.uk

The ICO specifically requires privacy information to explain the rights available to individuals, and notes that these can differ according to the lawful basis relied upon.

Complaints

If you have concerns about how we use your personal information, please contact us at:

privacy@patternhealth.co.uk

We will acknowledge a data protection complaint within 5 working days and aim to provide a written response within 14 working days.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator.

Information Commissioner's Office

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, legal requirements or how we process personal information.

Where appropriate, we will bring material changes to your attention.

The current version will always be available on our website.

Contact us

For questions about this Privacy Policy or how Pattern Health Education handles personal information, contact:

Email: privacy@patternhealth.co.uk

ICO registration number: ZC109451