Privacy notice

Welcome to the privacy notice of Alpha Biolaboratories Limited, a company registered in England and Wales under company number 09987941 and with our registered office at 14 Webster Court, Carina Park, Westbrook, Warrington, Cheshire, WA5 8WD.

Alpha Biolaboratories Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and/or when you use our products and services, namely the DNA, Drug or Alcohol Testing Kits. This privacy notice will tell you about your privacy rights and how the law protects you.  Furthermore, this notice implements the requirements of the General Data Protection Regulation (the law which protects and controls the use of personal data) and the ‘Caldicott Principles’ which are guidelines designed to ensure that all UK patient data remains confidential unless consented to otherwise. Alpha Biolaboratories Limited has developed systems and processes to ensure that the standards set out in both documents are met or exceeded.

The website operated by us is www.alphabiolabs.ie

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Alpha Biolaboratories Limited collects and processes your personal data:

• through your use of our website, including any data you may provide through our website when you contact us via our contact page or when you use our live chat feature;
• when you purchase and use our products and services, including use of our DNA, Drug or Alcohol Testing Kits; or
• through referral forms and phone calls from lawyers, sample donors or members of the public.

Where you are submitting personal data on behalf of a child, please be aware that this privacy notice shall also apply to the child’s personal data. We have done our best to write this privacy notice in simple clear terms, but if you have any questions concerning this privacy notice or your child’s personal data, please contact us at quality@alphabiolabs.com

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Alpha Biolaboratories Limited is the controller and responsible for your personal data (collectively referred to as Alpha Biolaboratories Limited, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Alpha Biolaboratories Limited

Name or title of DPO: Rachel Flanagan

Email address: rflanagan@alphabiolabs.com

Postal address: 14 Webster Court, Warrington, WA5 8WD

Telephone number: 0333 600 1300

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you would like to contact the ICO, the details are as follows:

 

• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• Tel: 01625 545 745
• Email: team@ico.org.uk
• Website: ICO.org.uk

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 22 May 2018 and historic versions are archived here can be obtained by contacting us.

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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Non-Special Category of Personal Data

• Identity Data includes first name, last name, username or similar identifier, title, date of birth, job title & company name.
• Contact Data includes home address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, 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 website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data 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 your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

This category of data was previously referred to as ‘Sensitive Personal Data’. This type of data is required for the provision of DNA, Drug and Alcohol Testing. We may collect details about your race or ethnicity, information about your health (including your medical history and GP details), genetic and biometric data (including DNA sample/profile) and test results via the website and/or following your use of our products and services, namely the DNA, Drug and Alcohol Testing kits.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services, namely DNA, Drug and Alcohol testing). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• complete the forms on our website contact pages;
• use the live chat feature on our website;
• apply for, purchase and use our products and services, namely the DNA, Drug and Alcohol Testing kits;
• make an appointment;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• give us some feedback.
• 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 and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:

analytics providers such as Google based outside the EU and from our third party providers for emails and communications.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sage Pay.
• Through referral forms and phone calls from lawyers, sample donors or members of the public

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• 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 processing is necessary to carry out DNA, Drug and Alcohol Testing, and to provide you with the results of such tests.

Where we use a ‘Special Category’ of data, including Medical Data, we are required to confirm an additional lawful basis (to that set out above) for the processing of such data which will most commonly include the following circumstances:

• Where processing is necessary for, medical diagnosis, the provision of health or social care or treatment, including carrying out DNA, Drug and Alcohol testing, and providing the results of such tests.
• Express consent that is freely, affirmatively, and transparently, given with regards to the processing described.

In addition to the data protection laws which we adhere to, we also respect the common law right of confidentiality relation to your Medical Data.  We will never share your records to any third party not involved in the provision of services (other than your registered GP or a sample collector) between us unless you expressly consent to us doing so.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 us at info@alphabiolabs.com 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 table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, including sending emails relating to your account set up, status and account credentials.	(a) Identity (b) Contact	Performance of a contract with you
To deliver products and services to you, namely DNA, Drug and Alcohol Testing kits, and for managing payments, fees and charges relating to the same. We may disclose data (including Medical Data) to External Third Parties, such as GPs, sample collectors and other health care professionals for the purpose of providing you with test results. External Third Parties may be used for facilitation of payments and hosting.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) In addition, with regards to Special Data – Medical Data: (a) Performance of a contract with you (b) Express Consent to provide DNA, Drug and Alcohol Testing and the results of such tests.
To verify with a third party your identity, status of Parental Responsibility (and consent of a child), validity and information. External Third Parties may be used for verification purposes.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical Data	(a) Legal obligation: the processing is necessary for Alpha Biolaboratories Limited to comply with the law (not including contractual obligations) (b)  Processing is necessary for reasons ensuring high standards of quality. (c) Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
To anonymise data collected (which may include Special Categories of data)	(a) Identity (b) Medical Data	The act of anonymisation constitutes an act of processing and, where it is to be undertaken in relation to Special Data we rely on: (a) Express consent – the anonymisation of data is not primary to the basis of our contract of services with you and as such the provision of primary services is not subject to or dependent on your data being used in this manner.  You are able to freely give, or withdraw, consent to use of your data with regards to this purpose at any time.
To internally review and evaluate the quality of our products and services.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Medical Data	(a) Necessary for our legitimate interests (to improve and better the products and services provided. In addition, with regards to Special Data – Medical Data: (a) Necessary for our legitimate interests (to improve and better the goods and services provided). (b) Express Consent to use your Medical Data to improve our services.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Contacting you by email or phone regarding your account (welcoming you to our service), reminding you of appointments and dates, re-engaging with you, maintenance of your account and updating of details. We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). We may use External Third Parties for the hosting of data, applications, website and technical support of the same.	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences and to ensure our website displays and operates properly on your devices.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company not related to Alpha Biolaboratories Limited.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at info@alphabiolabs.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you using our products and services, namely the DNA, Drug or Alcohol Testing kits.

Cookies

Most websites you visit will use cookies to help customise your experience. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO YOUR COOKIE POLICY.]

Change of purpose

We will only 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@alphabiolabs.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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. For example, we may be required to disclose your data in the interests of public health, national security, or serious threats to health and/or safety (including child abuse or neglect).

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External third parties, such as a GP, sample collector, solicitor, social worker and any other party who has taken part in a related DNA, Drug or Alcohol Test.
• External payment partners, where there is a customer dispute over whether the services paid for have been provided.
• 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. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Some of our External Third Parties are based in outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.  You may also be located outside of the EEA which requires us to send data outside of the EEA.  To do this we rely on Article 49 of GDPR which allows us to transfer in this instance as the transfer is necessary for the performance of a contract between the data subject and the controller.   For instance, conducting a test for immigration purposes.

Other than for the foregoing reason, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us using the DPO contact detail in section 1 if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We work hard to prevent your personal data from being accidentally lost, destroyed, used or accessed in an unauthorised way, altered or disclosed. In particular:

We use a secure server to protect any financial transactions on our website. We also take appropriate physical, electronic and managerial measures to ensure that the data disclosed to us is kept secure, accurate and up to date, and kept for only as long as is necessary for the purposes for which it is used. For finance reasons some information may be retained for longer.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All of our reports are sent as a pdf file that require a password to open them.  This password is picked by the person who instructs the test. This password protects the report from being opened by anyone who does not know the password.

If you would like us to send a copy of the report without a password protecting it, you will need to send us a written request confirming:

• You want us to remove the password protection
• You understand the report will be able to be opened by anyone who receives it
• You are happy to accept responsibility for any consequences as a result of the removal of the password
• You will not hold us accountable for any data breach due to the removal of the password
• You have read and are happy with this privacy notice.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use those strict procedures and security features set out above, to try to prevent unauthorised access.

8. 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, and 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. 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 processing it.

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 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 override 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.

Further information on these rights can be can be found on the ICO website. https://ico.org.uk/

If you wish to exercise any of the rights set out above, please contact our DPO, who’s details can be found at the top of this notice.

No fee usually required

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.

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.

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.

10. Glossary

LAWFUL BASIS

Express Consent means that you have freely, affirmatively and transparently given us consent to process your data, in particular, Medical Data.

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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting info@alphabiolabs.com

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. With regards to Alpha Biolaboratories Limited, this is the terms you agree to prior to undergoing a DNA, Drug Alcohol or test.

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

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities.