1.1.
This privacy policy aims to inform you about how M3 (EU) Limited, which operates Doctors.net.uk, (referred to as “M3”, “Doctors.net”, “we”, “us” or “our” in this privacy policy) processes your personal data and tells you about your privacy rights under data protection laws.
1.2.
For the purposes of data protection laws, we are the ‘controller’ of the personal data we collect about you through and in connection our operation of the Doctors.net.uk platform.
1.3.
Doctors.net incorporates privacy controls for members which affect how we will process your personal data. By using the privacy controls, you can specify your marketing and communications preferences and limit the publication of your information. You can access the privacy controls via account.doctors.net.uk.
2.1.
In this Section 2 we have set out:
the general categories of personal data that we process;
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
the purposes for which we may process personal data; and
the legal bases of the processing.
2.2.
Usage data : We process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems and system logs. We process usage data for the purposes of analysing the use of the website and services and serving targeted content and invitations to participate in relevant market research activities to you. The lawful basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3.
Account data : We process personal data that you provide when registering to become a Doctors.net member and set up a Doctors.net account. Your account data comprises some personal data that is mandatory in order to join Doctors.net and set up an account and some personal data that is optional once you have become a member and set up an account. We may also link the information you provide via your account with additional data sets provided by third parties for verification and internal reporting purposes.
We will use the data that you provide as part of registration for the purpose of verification through the Electronic Portfolio of International Credentials (EPIC), a service of the Educational Commission for Foreign Medical Graduates (ECFMG). The lawful basis for this processing is our legitimate interests, namely the proper administration of Doctors.net membership.
We will also use this data for the purposes of creating an account for you, authenticating access to your account, identifying you as the account holder, controlling and enabling you to access areas of our website and services that are restricted to members and enabling you to reset your password and gain access to your account if you forget your username or password.
The lawful basis for this processing is our legitimate interests, namely ensuring the security of our network, IT systems and information and providing Doctors.net members with a means of accessing our website and services.
2.4.
Use of your account data for marketing and communications purposes : We will use your account data including your email address and/or postal address to send marketing and communications that is relevant to our products and services. This may, for example, include postal mailings about our products and services if you have not visited our website recently.
You can opt-out from any specific communications by using the unsubscribe facility in the communication itself or via the Doctors.net website. We may also prompt you from time to time to revisit and update your communication preferences with the aim of ensuring that we only send you relevant and wanted communications.
We will also use your account data to serve you with targeted advertising on behalf our clients and other advertisers on our website.
The lawful basis for this processing is legitimate interests, namely:
our interests in providing marketing, advertising, communications and recruitment-related services to our clients, providing relevant information to our members and operating our business and website
2.5.
Publication data : If you post any content for publication on our website or through our services when you are logged into Doctors.net, such as forum posts, we will process your username and any personal data contained in the content you post. The publication data will be processed for the purposes of enabling such publication and identifying you as the source of the content.
2.6.
Enquiry data : We will process information contained in any enquiry you submit to us regarding products and/or services advertised on our website, such as when you complete a form requesting more information. We will process your enquiry data for the purposes of responding to your enquiry, and if you request to be contacted directly by a relevant third party organisation, we will pass the contact details you used to make your enquiry to the relevant third-party organisation for this purpose.
2.7.
Correspondence data : We will process information contained in or relating to any communication that you send to us. The correspondence data provided via email or telephone calls may be processed for the purposes of communicating with you, logging your communication through our Member Services system, and for the management of your account.
2.8.
Using your personal data for other purposes: In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for:
compliance with a legal obligation to which we are subject;
protecting your vital interests or the vital interests of another natural person;
obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice; and/or
the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
2.9.
Other people’s personal data: Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.1.
We will use your relevant account data for the purposes of automated decision-making in relation to deciding what content you will see on the site and what content will be delivered to you.
3.2.
The significance and possible consequences of this automated decision-making are that it will affect what content you will see on our site. You may contact our team at any time to discuss this screening process.
3.3.
We encourage you to keep your account data up to date, to ensure that the content delivered to you are relevant and suitable.
4.1.
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
Members of our group include:
M3 Inc (Japan)
M3 Medical Holdings Ltd (UK)
QQFS (Sweden)
Vidal Group Holdings Ltd including subsidiaries in France, Germany and Spain
IQUS Ltd t/a Rotamaster (UK)
OneHealth Communications (UK)
Data4Health (UK)
Ekas Marketing Research Services (Australia)
iDoctus (Spain)
Remedium (UK)
M3 USA
M3 (EU) Ltd which includes trading styles:
Doctors.net.uk (UK)
medeConnect (UK)
M3 Global Research
4.2.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.3.
We may disclose your profile data to our suppliers or subcontractors insofar as reasonably necessary in order to deliver and/or evaluate key parts of our website services. We may disclose part or all of your data to selected third-parties who supply additional services under the Doctors.net brand.
4.4.
Financial transactions relating to our website and services may be handled by our payment service providers. We will share transaction data with these service providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints or queries.
4.5.
We may disclose your enquiry data to one or more of those selected third-party organisations identified on our website, for the purposes of the third-party organisations offering relevant products and/or services to you.
Categories of these third-party organisations are as follows:
Pharmaceutical companies
Other companies in the healthcare industry
Medical device companies
Financial services companies
Medical indemnity organisations
Medical jobs boards
Charities
Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and such third party’s own privacy policy will govern that third party's use of your personal data.
4.6.
In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1.
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the UK or European Economic Area (EEA).
5.2.
Where we are required to transfer data to our other group companies as listed in section 4, we will ensure all personal data is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. For further details please contact us.
5.3.
The hosting facilities for our website are situated in the EEA.
5.4.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.1.
This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3.
We will retain and delete your personal data as follows:
1. Your account data, financial transaction data and correspondence data may be deleted after three years from the date on which your account has become inactive. (For the definition of ‘inactive’, see our Terms and Conditions for details)
Your usage data and market research data are anonymised and will be retained.
6.4.
Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1.
We will take appropriate technical and organisational precautions and apply industry best practice to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2.
We will store all your personal data on secure servers, personal computers and mobile devices.
7.3.
Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.4.
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and your password will only be used when you log in to our website. We will never ask you for your password.
8.1.
We may update this policy from time to time by publishing a new version on our website.
9.1.
In this Section 9, we have summarised the rights that you have under data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2.
Your principal rights under data protection law are:
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
9.3.
You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data, after you supplied appropriate evidence of your identity (this will require you to log in). You can access your account data by visiting https://personal-data.doctors.net.uk/ when logged into the website.
9.4.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can update and complete your account data yourself on your profile page on the website.
9.5.
In some circumstances, you have the right to the erasure of your personal data. These circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for exercising the right of freedom of expression and information and for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6.
In some circumstances, you have the right to restrict the processing of your personal data. These circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the lawful basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. If you object specifically to the processing of your account data, then fulfilment of this request will require the termination of your membership of Doctors.net.uk.
9.8.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10.
To the extent that the lawful basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
9.12.
To the extent that the lawful basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13.
You may exercise any of your rights in relation to your personal data by contacting our Member Services team by telephone or email or via the Data Protection officer via details in sections 14-16.
10.1.
Our website includes hyperlinks to, and details of, third party websites.
10.2.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.1.
Our website and services are targeted at persons over the age of 18.
11.2.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12.1.
Please let us know if the personal information that we hold about you needs to be corrected or updated. You can also update this on the ‘Update your profile’ section of the website.
13.1.
Blocking all cookies will have a negative impact upon the usability of many websites.
13.2.
If you block cookies, you will not be able to use all the features on our website.
13.3.
We use cookies for the following purposes:
authentication - we use cookies to identify you when you visit our website, if you are logged in, as you navigate our website, and to protect our website and services generally
personalisation - we use cookies to store information about your preferences and to personalise our website for you.
advertising - we use cookies to help us to display advertisements that will be relevant to you.
analysis - we use cookies to help us to analyse the use and performance of our website and services.
13.4.
You can withdraw your consent or update your preferences at any time.
14.1.
This website is owned and operated by M3 (EU) Ltd.
14.2.
We are registered in England and Wales under registration number 3527430, and our registered office is at One Valentine Place, London, SE1 8QH, UK.
14.3.
Our principal place of business is at One Valentine Place, London, SE1 8QH, UK.
14.4.
You can contact us:
by post, using the postal address given above;
by email, using help@doctors.org.uk.
15.1.
We are registered as a data controller with the UK Information Commissioner's Office.
15.2.
Our data protection registration number is Z5861600.
16.1.
We have appointed a data protection officer who can be contacted via DPO@eu.m3.com. If you wish to complain about this privacy notice or any of the procedures set out in it please contact our Data Protection Officer.
16.2.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns, if you believe that your data protection rights have not been adhered to. You may also contact the Supervisory Authority or equivalent Data Protection Regulator in the country you reside.
UPDATED: September 2024