Data protection and privacy policy

This policy was last updated on October 3^rd, 2024.

At The KOL Connection Ltd (“The KOL Connection”) we take your privacy very seriously. Our Privacy Notice sets out how we use your personal data and your rights in relation to the personal data we hold. This Privacy Notice (“Notice”) applies to The KOL Connection and is based on globally accepted basic principles on data protection and privacy.

The KOL Connection is registered with the Information Commissioner’s Office in the UK as a Data Controller. This Notice adopts the fundamental principles of the United Kingdom’s Data Protection Act of 2018  (the “Act”) and the European Union’s General Data Protection Regulation (“GDPR”) as the minimum standards to which The KOL Connection, its employees, and suppliers adhere.

CONTACT DETAILS

Our full details are:

You have the right to make a complaint at any time to the supervisory authority for data protection issues in the country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

Please read the following carefully to understand our views and practices regarding your personal data and how we will handle it.

HOW WE COLLECT YOUR PERSONAL DATA

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site thekolconnection.com. This includes information provided at the time of making any general enquiry or when applying for a job. The information collected includes name, email, phone number, and any information provided as part of your enquiry.
• Data from our clients and prospective clients when they register with our website; request information from us; purchase our services and in compliance with our contractual obligations including managing transactions, reporting, invoices and other operations related to providing and receiving services; as part of a market research project (e.g. observer forms) or otherwise communicate with us.
• We collect data from our research participants as part of our market research studies via a number of media, including but not limited to, consent forms, audio files / recording (that may undergo voice distortion in order to render your personal data anonymous), screeners and questionnaires, publicly available sources, and adverse event reporting forms.
• If you are a research participant, we may also be lawfully passed your data by our clients, the research sponsor, for the purposes of recruitment for an applicable study (e.g. market research, advisory boards or other project).

WHAT DATA DO WE COLLECT

We collect only the minimum amount of personal data necessary which may include:

• Contact and communications information, such as:
  • Your contact details (including email address(es), telephone number(s) and postal address(es))
  • Records of communications and interactions we have had with you
• Financial information, including:
• Your bank account number(s) / IBAN, name(s) and sort code(s) / SWIFT / routing numbers, which are used for paying your incentive if you take part in market research
• Biographical, educational and social information, including:
• Your name, title, gender, nationality and date of birth
• Your voice, for example as captured as part of an audio-recording of market research
• Lifestyle and work-related information, including:
  • Your personal data captured in the work product(s), notes and correspondence you create while engaged in a market research project for The KOL Connection
  • Details of your professional activities and interests
  • Your involvement with and membership of sector bodies and professional associations
• Commercial/research-related information including:
  • Areas of interest, previous and current job description and responsibilities, previous collaborations

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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.

The nature of the personal data collected about you will depend on your relationship with The KOL Connection and the type of work we conduct. The KOL Connection may use fieldwork partners to recruit participants to participate in a research project and conduct interviews. Typically, the fieldwork partner assigns a respondent identifier (unique reference number) to minimise the personal data seen or shared with The KOL Connection.

All personal data will be processed and collected lawfully, fairly and in a transparent manner. The KOL Connection will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized.  We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We use reasonable efforts to maintain the accuracy and integrity of personal data and to update it as appropriate.

HOW WILL WE USE YOUR DATA

The KOL Connection uses the personal data we collect for the following purposes:

• In the execution of our market research studies. For example, we use information held about you to respond to you during the interview / recruitment process and this can be shared with those who are contacting you to schedule, organize an interview or conduct the research interview or to follow up for further queries.
• To respond to your enquiries, including those received via our website contact form.
• To contact our clients and prospective clients regarding our services and to provide any commissioned services.
• In employment relationships, personal data can be processed if needed to initiate, carry out and terminate the employment agreement. When initiating an employment relationship, the applicant’s personal data will be processed. If the candidate is rejected his/her data will be deleted unless the applicant has agreed to remain on file for a future selection process.
• As otherwise necessary to comply with our legal obligations.

The personal data will be processed and collected lawfully, fairly and in a transparent manner. The KOL Connection will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized.  We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. We use reasonable efforts to maintain the accuracy and integrity of personal data and to update it as appropriate.

Our legal bases for the processing of your personal data may fall into one of the following categories:

Consent

When we rely on consent for the processing of personal data, we will inform you of this fact and gain your consent for how your data will be used and handled. If we collect personal data as part of the research project we are conducting, we will obtain your consent at the time of the project as per our industry association guidelines and codes of conduct.  If special category data is included in the collection, we will collect your explicit consent for its processing.

You are free to withdraw or modify your consent at any time. Simply email us at team@thekolconnection.com or contact Nicole Boven by phone +44 (0)20 3008 8196

Legitimate interest

We also process personal data to pursue the legitimate business interests of The KOL Connection and our clients. Our ‘legitimate interests’ include providing healthcare market research services and ensuring that The KOL Connection is run in a professional and sustainable manner in accordance with relevant ethical, legal and regulatory duties and requirements.  We ensure that such processing is in balance with the rights and expectations of the data subjects whose personal data will be processed under this legal basis.

Contract

We may also process personal data if the processing is necessary for a contract we have with the data subject.

DISCLOSURES OF YOUR PERSONAL DATA

We will not sell, share, transfer, or rent any Personal data to any third parties in ways different from what is disclosed in this Notice. Except as otherwise outlined in this Notice, we disclose personal data only to third parties who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations.

The KOL Connection will ensure that any third party to whom we disclose personal data provides the same level of privacy protection as is required by the applicable data protection regulations and agrees in writing to provide an adequate level of privacy protection.

We may disclose your personal data to:

• Any staff member of The KOL Connection where necessary to allow that staff member to respond to any enquiry you make or as part of the market research process.
• Other employees, agents, and contractors (e.g. suppliers who process data on our behalf, such as our accountants, solicitors, employment recruitment agencies and research suppliers including transcription agencies and research platform providers).
• Pharmaceutical and Medical Device manufacturers that sponsor our research projects if an adverse event, product complaint or safety issue is raised within the interview. In this situation, and if applicable based on your home country, you will be asked if you give your consent for your details to be passed on to our client for this purpose.
• External auditors, tax authorities and inspectors (such as HMRC, auditors).

In addition, we may disclose your personal data to:

• Allow us to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
• Investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
• Transfer information about you if The KOL Connection is acquired by or merged with another company.

HOW WE SECURELY STORE, TRANSFER AND PROCESS YOUR DATA

The data that we collect from you is stored securely on encrypted servers. It may be transferred to and stored at a destination outside your home country and it may also be processed by our team operating outside of the United Kingdom, Europe, and US who work with us or via our suppliers.

We may also process personal data via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

INTERNATIONAL TRANSFERS

Whenever we do transfer your personal data to another jurisdiction, we will take appropriate steps to protect such, which includes the following:

• Entering into an agreement with the third party which includes clauses that offer adequate protection for your information and these will offer no less protection than are provided by those determined by the EU commission, a template copy of which is available at: https://commission.europa.eu/law/law-topic/data-protection_en; or
• Otherwise ensuring that information would only be transferred to third parties in jurisdictions that have at least the same data privacy protection for personal data as the jurisdiction from which the personal data originates from. For example, in the case that the personal data originates from the EEA or UK and is transferred to a third country that has been deemed to offer adequate protection by the EU Commission or UK ICO for the processing of your personal data.

DATA PROCESSING USING Artificial Intelligence (AI)

The KOL Connection are committed to the ethical and responsible use of Artificial Intelligence (AI).  Where we utilise AI systems, we ensure they are designed to respect human rights, privacy, and dignity, ensuring transparency, fairness, and accountability. We implement robust security measures to protect personal data (including anonymisation), regularly audit our systems, and provide clear explanations of AI outcomes. Additionally, we continuously monitor, assess and evaluate our suppliers that utilise AI technologies and only use Suppliers that incorporate safeguards to ensure that the processing does not infringe on the rights of third parties.

HOW LONG WILL WE RETAIN YOUR PERSONAL DATA

Your personal data will not be kept for longer than is required for the purpose of the processing or is required per applicable law.

Personal data relating to market research will be kept for a maximum of 7 years following the end of each market research project.

If you sign a consent form to take part in market research, your name, the date, and the amount you received as an incentive will be kept for 6 years for accounting and audit purposes.

Information recorded in connection to adverse event reporting may be stored indefinitely, in order to comply with laws around adverse event reporting.

Personal data relating to job applications will be kept for 1 year following the end of the recruitment process.

For more information on our retention guidelines, you can contact us at team@thekolconnection.com.

YOUR RIGHTS AND ACCESS TO INFORMATION

We would like to make sure you are fully aware of all of your data protection rights, which may vary depending on the applicable legal basis of processing of your personal data:

• The right to access– You have the right to obtain confirmation that your personal data is being processed and to request copies of the personal data we hold.
• The right to rectification– You have the right to request that we correct any information you believe is inaccurate. You also have the right to request to complete the information you believe is incomplete.
• The right to erasure– You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing– You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing– You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability– You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you have subscribed to us or agreed to be on a contact list to receive information from us, you can ask to be removed at any time by emailing team@thekolconnection.com.

Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to where the rights of persons other than you would be violated by the provision of such access.  If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

Please note that in some cases, especially if you wish us to delete or cease the processing of your personal data, we may no longer be able to provide our services to you.

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.

If you would like to exercise any of these rights, please connect with us via email at team@thekolconnection.com or contact Nicole Boven by phone +44 (0)20 3008 8196.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to make a complaint to your local supervisory authority responsible for data protection matters.

TIME 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.

CHANGES TO OUR PRIVACY POLICY

We keep our Privacy Notice under regular review and reserve the right to revise it at any time. There is a date at the beginning of this policy which indicates the date it was updated. Please revisit this policy each time you consider giving personal information.

COOKIES WE USE ON THIS WEBSITE

We use the following cookies:

• Necessary cookies. These are cookies that are required for the operation of the website.  They include, for example, cookies that enable you to log into parts of the website.
• Analytical cookies. These cookies allow us to recognise and count the number of visitors to the website and to see how they move around within the website when they are using it.  This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
• Third party cookies. These are used to third parties (such as Google) to enable their services to work, for example Google Captcha on forms or Google Maps. Some third parties use their cookies for advertising purposes. We have no control over these cookies and provide a link to the third party’s privacy policy, where you may have the option to opt-out of their data collection.