ai365 is a wholly owned subsidiary of Purcom Procurement Services Limited (Purcom) and HC Insight Ltd (HCI). Both organisations are made up of dedicated commercial and clinical professionals who specialise in helping Healthcare Providers develop creative strategies and realise their growth potential. This is principally achieved by undertaking detailed insightful analyses to develop comprehensive and clear commercial and/or clinical strategies, tactical plans and well-designed services that help to navigate a future direction.

Detail of services provided

ai365 is commissioned (via either Purcom or HCI) by pharmaceutical companies and other healthcare companies and organisations to provide either strategic planning services, data analytics or specialist services supporting procurement and management of clinical homecare services and patient support programmes. The company provides an end-to-end service from service design through to supplier selection and management, data analytics and audit of provider organisations.

Purcom acts as a data processor on behalf of ai365 (including HCI) of low-level personal data. The
data controller of the company is Daniel Roberts.

Personal data held by Purcom

All data held is under a legitimate interest or by written consent.

Individual Medical Consultants

Information about individual doctors may be gathered from public websites. On occasions these are passed onto clients of ai365 in a spreadsheet format. The information collected is based on an individual consultant’s place of work and medical speciality. In some cases, permission from each individual is not sort or collected. It is deemed that the volume of contact this would incur to the health care professional would be burdensome in consideration of the low level of personal data collected (name, place of work and speciality). There is a legitimate interest for ai365 holding and processing this data.

Private Medical Insurance (PMI) Personnel

(specific staff, such as Contract Managers, Clinical Pharmacist, Nurses and Customer Service leaders).

Any member of a PMI team whose personal data is stored and processed will be informed that
Purcom is holding their data and the purpose for which their data is being held.

Healthcare Provider Personnel (Pharmacists, Nurses and Managers)

Any member of a healthcare provider team whose personal data is stored and processed will be
informed or have given their written consent. Purcom will inform all individuals why their data is
being held and the purpose for which their data is being held.

Does use personal data for marketing purposes?

ai365 (Purcom / HCI) does not use personal data for unsolicited market approaches. The Company
does not send newsletters or emails to prospective or existing customers. All connections are through
direct contact with clients e.g. from one dept to another in a Pharmaceutical Company.

Under what Legal Agreement is Personal Data held?

ai365 (Purcom / HCI) rely on legitimate interest or informed consent as the legal basis for processing
personal data.

ai365 (Purcom / HCI) undertakes a three-point test that must be undertaken if legitimate interest is
the reason for lawful holding and processing of data.

• Purpose test – is there a legitimate interest behind the processing?
• Necessity test – is the processing necessary for that purpose?
• Balancing test – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

When applying these principles to ai365 (Purcom / HCI):

1. The legitimate interest behind processing personal data lies in assisting in accurate communication between a client and health care professional. The outcome of processing the data is that medical professionals and therefore patients have access to the latest cancer therapies relevant to their area of speciality or disease.
2. The processing of data (from publicly available websites) is necessary for the purpose of communication and contact. It is not an unsolicited marketing activity but a specialist list of names and medical specialities that enable trained professionals to communicate with each other.
3. In balance it is beneficial for the health care professional to have their data processed by ai365 (Purcom / HCI). The processing of accurate data enables accurate information to be passed to appropriate health care professionals. This will lead to enhanced and relevant knowledge of drugs and therapeutic treatments being passed onto patients. The individual’s rights and interests are not compromised by the processing of this data.

Your rights under GDPR Legislation

If ai365 (Purcom / HCI) is holding your personal data, then under the GDPR legislation you have the following lawful rights:

Please follow the link below for more detailed information.

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

1. The right to have your data erased
   
2. The right to be informed about the personal data ai365 (Purcom / HCI) hold
   
3. The right to access the personal data we hold, but only your personal data, not anything belonging to ai365 (Purcom / HCI) or another person
   
4. The right to have any errors in the data we hold rectified
   
5. The right to restrict what ai365 (Purcom / HCI) do with the data and how we process it

All applications for data review should be made to [email protected]