PRIVACY POLICY

1. Context and overview

Key details

Policy prepared by:  MedQuest Global Marketing Research, Inc.

Introduction

MedQuest Global Marketing Research, Inc. needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures MedQuest Global Marketing Research, Inc.:

*  Complies with data protection laws and follows good practice

*  Protects the rights of staff, customers and partners

*  Is open about how it stores and processes individuals’ data

*  Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organizations — including MedQuest Global Marketing Research, Inc. — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1.  Be processed fairly and lawfully

2.  Be obtained only for specific, lawful purposes

3.  Be adequate, relevant and not excessive

4.  Be accurate and kept up to date

5.  Not be held for any longer than necessary

6.  Processed in accordance with the rights of data subjects

7.  Be protected in appropriate ways

2. People, risks and responsibilities

Policy scope

This policy applies to:

*  The head office of MedQuest Global Marketing Research, Inc.

*  All staff of MedQuest Global Marketing Research, Inc.

*  All contractors, suppliers and other people working on behalf of MedQuest Global Marketing Research, Inc.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

*  Names of individuals

*  Postal addresses

*  Email addresses

*  Telephone numbers

*  Subject ID numbers

*  IP addresses

*  Any other information that could be used to potentially identify a subject involved in    

    MedQuest Global Marketing Research, Inc.’s project work.

*  All media used in the course of work (i.e. voice recordings, video recordings)

Data protection risks

This policy helps to protect MedQuest Global Marketing Research, Inc. from data security risks, including:

*  Breaches of confidentiality. For instance, information being given out inappropriately.

*  Failing to offer choice. For instance, all individuals should be free to choose how the 

    company uses data relating to them.

*  Reputational damage. For instance, the company could suffer if hackers successfully gained 

    access to sensitive data.

Responsibilities

Everyone who works for or with MedQuest Global Marketing Research, Inc. has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The Chief Operating Office is ultimately responsible for ensuring that MedQuest Global Marketing Research, Inc. meets its legal obligations.

The Chief Operating Officer is responsible for:

*  Keeping employees and contractors updated about data protection responsibilities, risks and 

    issues.

*  Reviewing all data protection procedures and related policies, in line with an agreed schedule.

*  Arranging data protection training and advice for the people covered by this policy.

*  Handling data protection questions from staff and anyone else covered by this policy.

*  Checking and approving any contracts or agreements with third parties that may handle the 

    company’s sensitive data.

*  Ensuring all systems, services and equipment used for storing data meet acceptable security 

    standards.

* Performing regular checks and scans to ensure security hardware and software is functioning 

   properly.

*  Evaluating any third-party services the company is considering using to store or process data. 

    For instance, cloud computing services.

*  Approving any data protection statements attached to communications such as emails and 

    letters.

*  Where necessary, working with other staff to ensure marketing initiatives abide by data 

    protection principles.

3. General staff guidelines

All employees will complete training on MedQuest Global Marketing Research, Inc. Data Protection Policy upon employment. Once training is completed they will sign this document indicating they have completed the training and the document will be countersigned by the Chief Operating Officer confirming training is complete.

The only people able to access data covered by this policy should be those who need it for their work.

Data should not be shared informally. When access to confidential information is required, employees can request it.

MedQuest Global Marketing Research, Inc. will provide training to all employees to help them understand their responsibilities when handling data.

Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

In particular, strong passwords must be used and theyshould never be shared.

Personal data should not be disclosed to unauthorized people, either within the company or externally.

Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

Employees should request help from their manager or the data protection officer if they are unsure about any aspect of data protection.

Employees must report immediately to the Chief Operating Officer any of the following:

*  Inadvertent receipt of personal information/data

*  Any record or data breach or potential record or data breach that they become aware of in 

    the course of their job duties.

*  Any knowledge of handling of sensitive material not in compliance with the guidelines in this 

    document. This includes knowledge of co-workers, subcontractors, etc. mishandling personal 

    information/data.

4. Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Chief Operating Officer.

When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

*  When not required, the paper or files should be kept in a locked drawer or filingcabinet.

*  Employees should make sure paper and printouts are not left where unauthorized people 

    could see them, like on a printer.

*  Data printouts should be shredded and disposed of securely when no longer required. 

    When data is stored electronically, it must be protected from unauthorized access, 

    accidental deletion and malicious hacking attempts:

*  Data should be protected by strong passwords that are changed regularly and never 

    shared between employees.

*  If data is stored on removable media (like a CD or DVD), these should be kept locked away 

    securely when not being used.

*  Data should only be stored on designated drives and servers, and should only be uploaded 

    to an approved cloud computing services.

*  Servers containing personal data should be sited in a secure location, away from general 

    office space.

*  Data should be backed up frequently. Those backups should be tested regularly.

*  Data should never be saved directly to laptops or other mobile devices like tablets or smart 

    phones.

*  All servers and computers containing data should be protected by approved security 

    software and a firewall.

5. Data use

Personal data is of no value to MedQuest Global Marketing Research, Inc. unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

*  When working with personal data, employees should ensure the screens of their 

    computers are always locked when left unattended.

*  Personal data should not be shared informally. In particular, it should never be sent by 

    email, as this form of communication is not secure.

*  Data must be encrypted before being transferred electronically. When personal data is 

    sent it must be through the company secure FTP site.

*  Employees should not save copies of personal data to their own computers.

6. Data accuracy

MedQuest Global Marketing Research, Inc. will take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort MedQuest Global Marketing Research, Inc.  should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

*  Data will be held in as few places as necessary. Staff should not create any unnecessary 

    additional data sets.

*  Staff should take every opportunity to ensure data is updated. For instance, by confirming 

    a respondents details when they call.

*  MedQuest Global Marketing Research, Inc. will make it easy for data subjects to update the 

    information MedQuest Global Marketing Research, Inc. holds about them. 

*  Data should be updated as inaccuracies are discovered. For instance, if a customer can no 

    longer be reached on their stored telephone number, it should be removed from the 

    database.

7. Subject access requests

All individuals who are the subject of personal data held by MedQuest Global Marketing Research, Inc. are entitled to:

*  Ask what information the company holds about them and why.

*  Ask how to gain access to it.

*  Be informed how to keep it up to date.

*  Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the Chief Operating Officer at mkrueger@medquestglobal.com. 

The Chief Operating Officer will aim to provide the relevant data within 14 days.

The Chief Operating Officer will always verify the identity of anyone making a subject access request before handing over any information.

8. Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, MedQuest Global Marketing Research, Inc. will disclose requested data. However, the Chief Operating Officer will ensure the request is legitimate and seeking assistance from legal advisers where necessary.