Welcome to Harvey Walsh Limited’s privacy notice. Harvey Walsh Limited is a legal entity which is part
of the OPEN HEALTH group. OPEN HEALTH is a business comprising of several legal entities which provide
health economic and outcomes research, strategic market access, modelling and meta-analysis and other
services to healthcare and life science industry.
Harvey Walsh Limited, whose registered address is 25 Canada Square, Level 37, Canary Wharf, London, E14 5LQ.
We are also known as and trade as OPEN Health in the healthcare sector. In this notice, we refer to ourselves
as "Harvey Walsh". This notice includes information on how Harvey Walsh collects and processes your Personal
Data, and the various ways we may interact with you, including via this website.
Harvey Walsh is a health informatics company, operating in the healthcare and technology sector.
Harvey Walsh takes your privacy seriously. This notice tells you how we look after your Personal Data when
you interact with us and gives you information as to Your Privacy Rights.
The links are provided to make navigation easier. Please also use the Glossary
to understand the meaning of some of the terms used in this.
Please read this privacy notice together with any other privacy notices we may provide as part of your
interactions with us, therefore, this privacy notice supplements any other notices, and is not intended
to override them.
2. Data Controller
If you have any questions about this privacy notice, including any requests to exercise Your Privacy Rights
please contact us at:
Harvey Walsh Limited:
Email address: firstname.lastname@example.org
Postal address: The Heath Business and Technical Park, Runcorn, Cheshire, WA7 4QX
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority 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 at
email@example.com in the first instance.
3. Changes to this Privacy Notice
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.
4. The data we may collect about you
Personal Data, or personal information, means any information about a living individual
from which that person can be identified. It does not include data where your identity
has been removed (anonymous data).
Depending on how you interact with us we may collect, use, store and transfer different kinds of
Personal Data about you which we have grouped together follows:
includes first name, maiden name, last name, username or similar identifier, marital status, title,
date of birth and gender.
includes billing address, delivery address, email address and telephone numbers.
includes bank account and payment card details.
includes details about payments to and from you.
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 our websites.
includes your interests, preferences, feedback and any survey responses.
includes information about your work history, specialisms and qualifications.
Marketing and Communications Data
includes your preferences in receiving marketing and or newsletters from us and any
communication preferences collected.
Market Research Data
includes any personal and or Special Categories of Personal Data you have shared with us as a participant
in a survey or as part of our contract or agreement with you.
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
Pseudononysed data this is Personal Data that is about you but is not directly identifiable as
it is coded to protect your privacy. Hospital Episode Statistics Data also known as HES Data is
Pseudonomysed Data when shared with us and we do not have the code to make it identifiable.
See section 7
5. How is your personal data collected?
We use different methods to collect data from and about you, including via:
You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by
corresponding with us by post, telephone, email or otherwise. This includes Personal Data you
provide when you do any of the following:
- meet us at an event
- take part in research either on line, by phone or face to face
- subscribe for publications
- take part in a campaign where you share your Personal Data and experiences
- approach and/or contract with us to perform services
- give us feedback
- contact us online in a networking or social media forum
- make an enquiry to our website
- you send us your CV or biography
- you contact us to request our services
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment,
browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other
Third parties or publicly available sources
We may receive Personal Data about you from various third parties and public sources as set out below:
- (a) analytics providers;
- (b) registers of information such as HES from NHS Digital
- (c) search information providers such as Google, Chrome
(d) Identity and Contact Data from publicly availably sources such as Companies House
and the Electoral Register, British Medical Association and similar international organisations,
6. How we use your personal data
Most commonly, we will use your Personal Data in the following circumstances:
Where we need to perform a contract we are about to enter into, or have entered into.
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 or regulatory obligation.
Where it is in the public interest to do so.
With your explicit consent (which you may withdraw at any time).
We have set out below 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
firstname.lastname@example.org 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 details below
Relationship to Harvey Walsh
Clients and potential Clients
To manage our relationship with you which will include:
Communicate with you regarding services we are delivering on your behalf
Ask you to give feedback on performance
Recommend goods or services that may be of interest to you
To understand your role in your organisation
Type of data
- (a) Identity
- (b) Contact
- (c) Profile/Job title
- (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
Performance of a contract with you
Necessary for our legitimate interests (to keep our records updated and gather
feedback on performance)
Necessary for our legitimate interests (to develop our products/services and grow our business)
How long will we keep it?
For the period of our contract with you plus up to 5 years unless specified differently in our contracts.
Who do we share it with?
- Authorised subcontractors as set out in contract arrangements
- Harvey Walsh Group companies including its parent companies and investors
- Potential investors in the Harvey Walsh Group
Just browsing (website user)
Relationship to Harvey Walsh
To ensure that you can navigate the website appropriately and have a positive user experience
Type of data
Our website hosting provider may collect your IP address. This will provide them with information such
as location (town) and your computer or mobile device. We do not have control over the data the provider
We generate log files about browsing patterns. This is statistical data which does not identify you
as an individual. It is useful for us for security reasons and so that we can see which pages are most
popular and whether a particular event has increased traffic to our website.
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google").
The information generated by the cookie about your use of the website (including your IP address)
will be transmitted to and stored by Google on servers in the United States.
Google will use this information for its own purposes in accordance with its own
You may refuse the use of Google Analytics cookies by selecting the appropriate settings on your browser;
however, please note that if you do this you may not be able to use the full functionality of
this website. Google has an Opt-out Browser Add-on to provide website visitors the ability to
prevent their data from being used, please visit the following website for further information:
Google Analytics Opt-out.
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate business interests to promote services
How long will we keep it?
Due to the fact that we cannot identify users by their IP address and for the security and performance
of our web services, we keep this data indefinitely.
Who do we share it with?
Your IP address is recorded by Google Analytics services and stored in our web server logs at UK
Fast hosting in the UK.
7. Hospital Episode Statistics (HES) Data
Harvey Walsh is a Sole Data Controller and a Data Processor of Hospital Episode Statistics (HES) data
under licence from NHS Digital.
Hospital Episode Statistics (HES) is a database containing details of all admissions, A and E attendances
and outpatient appointments at NHS hospitals in England.
Initially this data is collected during a patient's time at hospital as part of the Commissioning
Data Set (CDS). This is submitted to NHS Digital for processing and is returned to healthcare
providers as the Secondary Uses Service (SUS) data set and includes information relating to
payment for activity undertaken. It allows hospitals to be paid for the care they deliver.
Further information on HES data can be found at
Legal Basis for Processing
We process HES data in accordance with a Data Sharing Agreement (DSA) and Data Sharing Framework
Contract (DSFC) with NHS Digital.
HES data are processed as a legitimate interest under General Data Protection Regulation Article 6 (1) (f)
and Article 9(2)(j). This processing is necessary to deliver the purpose of improved outcomes for patients
and benefits to the wider health and social care arena.
Use of HES data
Harvey Walsh use pseudonymised Hospital Episode Statistics Data comprising of Admitted Patient Care,
Outpatients, Critical Care, A&E, Emergency Care (ECDS) and Civil Registry Data to undertake analysis,
develop services and provide solutions to providers of Healthcare and life sciences services such as
Clinical Commissioning Groups (CCGs), Commissioning Support Units (CSUs), Hospital Trusts, NHS England,
Public Health England, Sustainability and Transformation Partnerships (STPs), NHS Trusts, Clinical teams,
Health and Wellbeing Boards, Universities, Life science industry, Pharmaceutical companies, Medical
Device companies, Academic Heath Science Networks (AHSNs), Integrated Care Systems (ICS), Patient
Groups and Charities and other NHS organisations.
These organisations use the outputs and insights provided by Harvey Walsh to work collaboratively
with NHS organisations to promote health and improve the wellbeing of patients.
The use of the data supports the development of innovative solutions and service improvement, to track
outcomes and provide the real world evidence as required by the NHS, NICE and other regulatory bodies.
The aim of which is to improve patient care and support enhanced access to improved services and
innovative solutions. In addition these clients use these outputs for the purposes of providing
supporting information required by the NHS for business cases, epidemiological research, pathway
analysis, burden of disease analysis, health economic research, predictive analytical modelling,
NICE submissions and quality and outcome analysis. The outputs of which are shared directly or
indirectly with the NHS to support improvements in patient care.
The data we receive is pseudonymised and non-identifiable; this means individuals cannot be identified
from the data.
Record level data supplied by NHS Digital to Harvey Walsh is not supplied to any third party organisation.
All outputs are aggregated with small numbers suppressed in line with the HES analysis guide and
the mental health suppression rules.
HES data are not used to populate automated decision making tools.
HES Data Security and Retention
HES data are retained on a rolling 10 year basis. HES data are securely processed and stored in England
at locations disclosed with NHS Digital conforming to both ISO27001 and the DSP Toolkit. The HES data
are securely destroyed in accordance with NHS Digital data destruction standards when required under
Opt Out From HES
Harvey Walsh do not hold direct identifiers in which to remove your data from HES.
If you would like to understand the national data opt-out then please visit
which has all the up-to-date information on opt-outs and how they work.
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies.
9. Change of purpose
We will 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. 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.
10. Disclosures of your personal data
We may have to share your Personal Data with the parties set out below as well as in the table
in paragraph 6 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table in paragraph 6 above
Third parties to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your Personal Data in
the same way as set out in this privacy notice.
We require all third parties to respect the security of your Personal Data and to treat it in
accordance with the law.
11. International transfers
All data is not transferred outside the European Economic Area (EEA) apart from Google Analytics
data which is stored in the USA. Where data is transferred to the USA we rely on Standard Contractual
Clauses (SCC) as our mechanism for restricted transfers.
12. Data security
We are ISO27001/2013 compliant Certificate Number: 9164-ISMS-001, this means we have put in place
appropriate safeguards 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.
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.
13. Data retention - how long will you use my personal data for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature,
nd 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 requirements. We are required by law to
keep basic information about our customers (including Contact, Identity, Financial and Transaction Data)
for at least six years after they cease being customers for legal reporting purposes.
See Table in part 6.
14. 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
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 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 overrides 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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) 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 us at
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.
15. 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.
16. Time limit 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.
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).
Personal Data means data which relate to a living individual who can be identified
from those data, or from those data and other information which is in the possession of, or is likely
to come into our possession of, the data controller and includes any expression of opinion about and
individual and any indication of the intentions of the data controller or any other person in respect
of the individual.
Special Categories of Personal Data this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data.
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.
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.
Third Parties has the following meanings.
External Third Parties means:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking,
legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the EEA or Outside the EEA who require
reporting of processing activities in certain circumstances including the public interest.
Other third parties are set out in the Table in part 6.
means a person who (either alone or jointly or in common with other persons) determines the purposes
for which and the manner in which any personal data are, or are to be processed.
, in relation to personal data, means any person (other than an employee of the data controller)
who processes the data on behalf of the data controller.
Pseudononysed data this is Personal Data that is about you but is not directly identifiable
as it is coded to protect your privacy.