The website operated by us is: www.sorchabiotech.com and www.booksorcha.com
- Important information and who we are
- through your use of our website, including any data you may provide through our website.
- when you purchase and use our products and services.
- through referral forms and phone calls from members of the public.
Where you submit personal data on behalf of a child, please be aware that this privacy notice shall also apply to the child’s personal data. We have used our best endeavours to provide information via this privacy notice in a simple and transparent manner. However, if you have any further questions concerning this privacy notice or children’s personal data, please contact our DPO.
Full name of legal entity: Sorcha Biotech Limited
Email address: Info@Sorchabiotech.com
Postal address: 116 Buchanan Street, Glasgow, G1 2LW
Telephone number: 01412550464
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
If you wish to contact the ICO, the details are as follows:
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 01625 545 745
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.
- 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:
Non-Special Personal Data
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, sex, job title and company name.
- Contact Data includes home 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.
- 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 this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Personal Data
This type of data is required for the provision of COVID-19 and DNA Testing. We may collect details about your race or ethnicity, information about your health (including your medical history and GP’s details), genetic and biometric data (including DNA sample/profile) and test results via our website and/or following your use of our products and services, namely the COVID-19 and DNA testing services.
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 goods or 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 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:
- complete the forms on our website contact pages;
- apply for, purchase and use our products or services
- make an appointment;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- 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[, server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the UK and from our third party providers for emails and communications;
- advertising networks
- search information providers
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- through referral forms, by post, emails, phone calls or otherwise.
- 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 [or 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.
- Where processing is necessary to carry out COVID-19 or DNA testing, and to provide with the results of such tests.
Where we use Special Personal Data, we are required to confirm an additional lawful basis (to those set out above) for the processing of such data, which will most commonly include the following circumstances:
- Where processing is necessary for medical diagnosis, the provision of health or social care or treatment, including carrying out COVID-19 or DNA testing and providing the results of such tests.
- Express Consent that is freely, affirmatively and transparently given with regards to the processing described.
- Where is necessary for the establishment, exercise or defence of legal claims.
In addition to the data protection laws which we adhere to, we also respect the common law right of confidentiality in relation to your medical data. We will never share your record with any third party not involved in the provision of services between us (other than your registered GP) unless you Expressly Consent to us doing so.
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.
Please refer to the section on “Lawful Basis” in the Glossary to find out more about the types of lawful basis that we will rely on to process 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 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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer, including sending emails relating to your account set up, status and account credentials||(a) Identity (b) Contact||Performance of a contract with you|
|To process and deliver your [or your employers] order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us We may disclose data (including Medical Data) to External Third Parties, such as GPs and other health care professionals for the purpose of providing you with test results. External Third Parties may be used for facilitation of payments and hosting.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Special Personal Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) In addition, with regards to Special Personal Data (including medical data): (a) Performance of a contract with you[/your employer] (b) Express Consent to provide COVID-19 and/or DNA testing services and the results of such tests. [(c) Preventative or occupational medicine, to assess the working capacity of the employee, medical diagnosis.]|
|To report test Results to your employer, your GP, or any applicable regulatory, occupational health, NHS or other health body, e.g. Public Health Scotland.||(a) Identity (b) Contact (c) Special Personal Data||(a) Necessary for our legitimate interests (to provide our 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 verify with a third party your identity, status of Parental Responsibility (and consent of a child), validity and information. External Third Parties may be used for verification purposes.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Special Personal Data||(a) Legal obligation: the processing is necessary for [COMPANY] to comply with the law (not including contractual obligations) (b) Processing is necessary for reasons ensuring high standards of quality. (c) Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent|
|To anonymise data collected (which may include Special Personal Data)||(a) Identity (b) Special Personal Data||The act of anonymisation constitutes an act of processing and, where it is to be undertaken in relation to Special Personal Data we rely on: (a) Express consent – the anonymisation of data is not primary to the basis of our contract of services with you and as such the provision of primary services is not subject to or dependent on your data being used in this manner. You are able to freely give, or withdraw, consent to use of your data with regards to this purpose at any time.|
|To internally review and evaluate the quality of our products and services.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Special Personal Data||(a) Necessary for our legitimate interests (to improve and better the products and services provided). In addition, with regards to Special Personal Data: (a) Necessary for our legitimate interests (to improve and better the goods and services provided). (b) Express Consent to use your Special Personal Data to improve our services.|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) We may use External Third Parties for the hosting of data, applications, website and technical support of the same.||(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 We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.||(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 and to ensure our website displays and operates properly on your devices||(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 (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
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).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us 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 a product/service use or purchase by you.
We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.
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. For example, we may be required to disclose your data in the interests of public health, national security or serious threat to health and/or safety.
- 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 Purposes for which we will use your personal data above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
We may share anonymised or Aggregated Data (but not personal data) with the Office for National Statistics, Public Health Scotland and other university, NHS or health bodies 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
Some of our External Third Parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. You may also be located outside of the UK which requires us to send data outside of the UK. To do this we rely on Article 49 of the UK GDPR which allows us to transfer data where necessary for the performance of a contract between the Data Subject and the Controller.
Other than for the foregoing reason, whenever we transfer your personal data out of the UK or the EEA, we 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 Commissioner 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data: see your legal rights 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 DPO.
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.
Express Consent means that you have freely, affirmatively and transparently given us consent to process your data, in particular, Special Personal Data.
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. With regards to Sorcha Biotech Limited this is the terms you agree to prior to undergoing a COVID-19 or DNA test.
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.