Privacy Policy
CliniLink Academy (operated by CliniLink Ltd)
1. Who We Are
1.1CliniLink Academy is operated by CliniLink Ltd, a company registered in England and Wales under company number 16243215, whose registered office is at Stockport Pyramid, Yew Street, Stockport Trading Estate, Stockport, SK4 2JZ. ICO Registration Number: ZB896601.
1.2CliniLink Academy is a trading platform of CliniLink Ltd. It is not separately incorporated and holds no separate ICO registration. CliniLink Ltd is the sole data controller for all personal data processed through www.clinilinkacademy.com and through www.clinilink.co.uk. Consent under UK GDPR is given to a controller rather than to a website, so a permission you give on either property is held by CliniLink Ltd and applies across both.
1.3Our data protection lead can be contacted at [email protected].
2. The Information We Collect
- Account information: your name, email address, and password (held in encrypted form by our platform provider).
- Professional information: your profession, role and, where requested, your professional registration number (for example GPhC, GMC or NMC number).
- Learning records: courses enrolled, progress, assessment results and certificates issued.
- Marketing permissions: the choices you make about receiving emails from us, including the date, wording version and point of capture of each choice.
- Payment information: for paid courses, processed by our payment provider. We do not store full card details.
- Technical information: device, browser, IP address and usage data collected through cookies and similar technologies, as described in section 10.
3. How We Use Your Information
3.1We use your information to provide the platform and your courses, to issue CPD certificates, to respond to enquiries, to process payments, to maintain the security of the platform, and to send the communications described in section 5.
3.2Your professional registration number is used for two purposes only: verifying that you are a healthcare professional so that sponsored content is served only to the intended audience, and appearing on your CPD certificate to support your revalidation record. It is not shared with sponsors or any other third party.
3.3Reporting to sponsors of funded educational activities is aggregate only, for example delegate numbers by profession. We do not provide sponsors with individual level personal data.
3.4A professional registration number is professional registration data. It concerns you as a practitioner rather than your health, and it is not special category data under Article 9 UK GDPR.
4. Lawful Bases for Processing
- Performance of a contract: providing your account, courses, certificates and paid services.
- Legitimate interests: platform security, service improvement, audience verification for sponsored content, and aggregate reporting.
- Consent: marketing communications as described in section 5, and non essential cookies.
- Legal obligation: record keeping required by tax, accounting and regulatory requirements, including records required to demonstrate compliance with the ABPI Code of Practice.
5. Marketing and Promotional Communications
5.1Service emails. We send transactional emails relating to your account and learning, for example enrolment confirmations, receipts and CPD certificate emails. These are part of the service, contain no promotional content and do not require marketing permission.
5.2CliniLink marketing. With your permission, or where permitted by law, we send emails about CliniLink’s own educational programmes, events and platform updates. You can opt out at any time using the unsubscribe link in every such email.
5.3Emails about pharmaceutical company funded programmes. Some of our educational programmes are funded by pharmaceutical companies. Emails about these programmes, and the programmes themselves, may contain promotional content about medicines and may have been developed, written, reviewed or approved by or on behalf of a pharmaceutical company. We send these emails on that company’s behalf as well as our own, and the company is named in every communication. We send them only where you have given us separate, explicit prior permission, using the following wording:
5.4How this permission is captured. The permission is requested through an unticked, optional tick box at account registration. Learners who registered before this mechanism was introduced are presented once with the same statement on the platform, with a clear agree or decline choice. Giving this permission is optional and does not affect access to any course.
5.5How this permission is recorded. Each decision is recorded against your contact record in our email platform with the date, the wording version and the point of capture. The most recent choice you make is the one we honour, so a later decline overrides any earlier permission.
5.6A single register. All our marketing is sent through a single email platform which also holds our single suppression register across www.clinilink.co.uk and www.clinilinkacademy.com. A withdrawal made on either property takes effect across both. Your general CliniLink marketing preference and your permission for pharmaceutical company funded programme emails are recorded separately, so withdrawing one does not affect the other.
5.7Withdrawing permission. You can withdraw any marketing permission at any time using the unsubscribe link in every marketing email, or by contacting us at [email protected]. Withdrawal does not affect the lawfulness of processing before withdrawal.
6. Who We Share Your Information With
- Thinkific Labs Inc., which hosts the CliniLink Academy platform, as our processor.
- Brevo, our email marketing and contact management platform, as our processor.
- Our payment provider, for paid courses.
- Professional advisers, insurers and authorities, where required by law.
Sponsors of funded educational activities receive aggregate reporting only, as described in clause 3.3. They do not receive your personal data and act as independent controllers of any information you choose to give them directly.
7. International Data Transfers
7.1We store and process personal data in the United Kingdom wherever possible. Some of our service providers, including our platform and email providers, operate outside the UK, for example in the European Economic Area, Canada or the United States, and personal data may be transferred to them for the purposes described in this Policy.
7.2Where we transfer personal data outside the UK, we ensure that an appropriate safeguard is in place. This may be a transfer to a country covered by UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism. You can request details of the safeguards we use by contacting us at [email protected].
8. How Long We Keep Your Information
- Account and learning records: for as long as your account is active, and for six years after closure to support certificate verification and regulatory requirements.
- Marketing permission records: for as long as we rely on the permission, and for six years after withdrawal, to evidence compliance.
- Payment records: six years, as required by tax law.
- Suppression records: indefinitely, in minimised form, so that a request not to be contacted continues to be honoured.
9. Your Rights
You have the right to access your personal data, to have inaccurate data corrected, to erasure in certain circumstances, to restrict or object to processing, to data portability, and to withdraw consent at any time where processing is based on consent. To exercise any right, contact [email protected]. We will respond within one month.
10. Cookies and Similar Technologies
10.1The platform uses cookies that are essential for it to function, for example to keep you signed in.
10.2With your consent, we also use analytics cookies to understand how the platform is used, and a tracking cookie set by Brevo, our email platform, which allows us to record your marketing permission choices against your contact record and to understand engagement with our communications.
10.3You can manage non essential cookies through the cookie banner and your browser settings. Full details are in our Cookie Policy.
11. Security
We use appropriate technical and organisational measures to protect your personal data, including encryption in transit, access controls and staff confidentiality obligations. No system is completely secure, and we will notify you and the ICO of any breach where the law requires it.
12. Children
The platform is intended for healthcare professionals and adults in training for healthcare roles. It is not directed at children, and we do not knowingly collect personal data from anyone under 18.
13. Changes to this Policy
We may update this Policy from time to time. Material changes will be notified on the platform or by email, and the updated version will state its effective date and version number.
14. Contact and Complaints
CliniLink Academy (CliniLink Ltd)
Registered Office: Stockport Pyramid, Yew Street, Stockport Trading Estate, Stockport, SK4 2JZ, United Kingdom
Company Number: 16243215
ICO Registration Number: ZB896601
Email: [email protected]
If you are unhappy with how we have handled your personal data, you can complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113. We would welcome the opportunity to resolve your concern first.