Procedure for handling of personal data, Hegenberger Medical, CVR 38984853
Hegenberger Medical
Innovation Centre
99 Park Drive
Milton Park
OX14 4RY
United Kingdom
customer.service@hegenbergermedical.com
This procedure has been elaborated based on Article 30 of the GDPR and the guidelines of the Danish Data Protection Agency. More detailed descriptions of specific workflows and procedures are given in separate documents.
When an institution purchases retractors from us, we handle the information received for the purpose of fulfilling the sales agreement.
In contrast to sales to private recipients, we obtain the information from third parties, as the purchaser is providing information on other contact persons at institutions. This is also necessary to fulfil the sales agreement.
When we are contacted with questions regarding products they have purchased from us, the purpose of handling their data is fulfilment of the sales agreement. For other requests, the data are handled for the purpose of responding to the questions with which the person contacts us. If the person sends us sensitive data, this will be deleted as quickly as possible.
In marketing via newsletters, social media or direct inquiries, the personal data are handled for the purpose of selling the company’s product. We follow good marketing practice here.
Personal data handled in connection with personnel administration has the purpose of complying with the applicable laws and the employment agreement.
In connection with both sales and purchasing, personal data are handled for the purpose of fulfilling the purchase agreement as well as the applicable laws.
In Hegenberger Medical, we handle the following categories of personal data:
Here is how the different categories of personal data are handled for different categories of recorded entities:
The personnel category covers permanent employees, temporary employees (including employees with wage subsidies), contract workers and trainees.
In this category, both general personal data such as name, address, contact information and photos are handled, as well as personal identification numbers and, in some cases, sensitive personal information, such as medical data in connection with absences due to illness.
Business partners are contacts from companies which Hegenberger Medical sells to, makes purchases from or with which it has other forms of cooperation. For example, this cooperation can include sponsorships, joint development projects, investment, institutions etc.
In this category, only general personal data are handled, typically name, contact information, place of employment and job title.
Professional contacts are persons with expertise within Hegenberger Medical’s technical field and who contribute with feedback on the retractor, for example. Some professional contacts may also appear on images or may assist at trade fairs, but will be treated as contract workers in this context.
In this category, only general personal data are handled, typically name, contact information, place of employment and job title, as well as email communications with the person.
This category includes those persons we are in contact with at hospitals, midwifery schools and other institutions who purchase specula. They will often be department heads at hospitals.
In this category, only general personal data are handled in the form of name, contact information, place of employment and job title. Email correspondence will be conducted with these persons.
Within the context of good marketing practice, we will contact relevant persons employed at hospitals, midwifery schools and other institutions who could potentially be interested in our retractor.
In this category, only general personal data are handled in the form of name, contact information, place of employment and job title. Email correspondence will be conducted with these persons.
We receive various inquiries via email, contact forms and social media.
The information handled is that given to us by the person on placing the inquiry. In the event that we receive sensitive personal data (typically medical data) in an inquiry, we will ensure that these are deleted as soon as the inquiry has been answered. Persons making inquiries will be informed of this.
We transmit personal data to a number of external services, suppliers, partners and public entities. In most cases, this transmittal is based on a data processing agreement. In individual cases, the external contacts are partners with their own independent data security obligations.
In cases where a supplier uses a server located in a third country, the data processing agreement will ensure security in connection with these servers.
We retain and delete personal data based on the following principles:
Sensitive personal data and ID numbersare retained only to the extent required by law, necessary for a concluded contract or by agreement.
General personal data are retained for as long as necessary for current purposes and are subsequently retained or deleted based on the following principles:
A general guideline has been prepared for use by Hegenberger Medical’s personnel for handling personal data, including a series of more detailed procedures for specific work steps for use by persons working in a specific area.
