Privacy Notice – Reviewed April 2026

 

This privacy notice tells you what to expect Newmarket Strategy Ltd. (“we”, “our” or “us”) to do with your personal information.

Contact details

Email:

info@newmarket-strategy.com

Post:

The Smiths Building
179 Great Portland Street
London
W1W 5PL
United Kingdom

Phone:

+44 207 368 1611

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

  • professional contact details
  • published professional opinions
  • areas of expertise
  • institutional affiliation
  • professional role and seniority
  • published research and authorship
  • conference or event participation.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

  • Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
  • Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
  • Your right to erasure– You have the right to ask us to delete your personal information. Read more about the right to erasure.
  • Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
  • Your right to object to processing– You have the right to object to the processing of your personal data. Read more about the right to object to processing.
  • Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability. This right applies only where processing is based on consent or contract, and does not apply to processing carried out on the basis of legitimate interests.
  • Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Legitimate interests— We process personal information about individuals working in healthcare, life sciences, the NHS and public sector, pharmaceutical and biotech industries, and patient advocacy where we have a legitimate business interest in doing so, and where that interest is not overridden by your rights and interests.

This includes processing your information for the following purposes:

    • Market research and insight — conducting interviews, surveys, and qualitative or quantitative research to support healthcare and life sciences projects on behalf of our clients. Where you participate in research, this will be on an informed basis.
    • Stakeholder identification and mapping — identifying and recording individuals who are relevant to a particular therapy area, policy issue, or healthcare system question, based on their publicly available professional profile and expertise.
    • Advisory and expert engagement — establishing and maintaining relationships with individuals who may serve on advisory panels or contribute expert input to client programmes.
    • Intelligence and landscape analysis — gathering, reviewing, and synthesising publicly available information about individuals’ published positions, institutional roles, and professional activity to inform client strategy and deliverables.
    • Client reporting — including relevant professional information about individuals in reports, briefings, and other deliverables prepared for our clients, where this is appropriate and proportionate to the purpose.

We rely on legitimate interests because this processing supports the legitimate commercial and research objectives of our clients, who operate in regulated industries with a direct interest in understanding healthcare policy, clinical practice, and patient perspectives. The information we process is predominantly professional in nature, sourced from publicly available records, and handled with appropriate confidentiality obligations. We do not consider that this processing causes undue harm to individuals’ rights or interests, given its professional context and the reasonable expectations of those operating in public-facing roles within these sectors.

You have the right to object to processing carried out on the basis of legitimate interests. If you wish to do so, or to understand more about what information we hold about you, please contact us using the information at the top of this privacy notice.

  • Consent – where you participate in research activities such as recorded interviews or surveys, we will obtain your consent before doing so. All relevant information and consent documentation will be provided to you in advance. You do have the right to withdraw your consent at any time.

Sources of Personal Information

We obtain personal information about individuals from a range of publicly available and professionally recognised sources. These include:

  • Professional networking platforms — such as LinkedIn and similar platforms where individuals have published their professional profile, affiliations, and areas of expertise
  • Organisational and institutional websites — including NHS trusts, integrated care boards, academic institutions, learned societies, professional bodies, and pharmaceutical or biotech company websites, where individuals are listed in professional capacities
  • Published research and clinical literature — including journal articles, conference papers, abstracts, and posters where individuals are named as authors, investigators, or contributors
  • Conference and event records — including speaker listings, faculty rosters, programme agendas, and attendee information published by event organisers in the healthcare and life sciences sectors
  • Government and regulatory sources — including the General Medical Council (GMC) register, NHS England Digital workforce data, the ABPI disclosure database, Companies House, and other statutory registers where professional information is publicly recorded
  • Healthcare directories and databases — including specialist directories of clinicians, prescribers, and healthcare decision-makers used in the life sciences industry
  • Media and press coverage — including trade publications, healthcare news outlets, and professional journals where individuals are quoted, profiled, or referenced in a professional context
  • Patient advocacy and charity sector sources — including the published materials, websites, and public communications of patient organisations and advocacy groups, where individual representatives are named
  • Client referrals and introductions — where our clients introduce us to individuals relevant to a project, or provide us with contact information as part of the delivery of services
  • Direct professional interactions — including business cards, email correspondence, and professional introductions at events, where individuals share their contact details in a professional context

Disproportionate Effort — Why We Do Not Always Notify Individuals Directly

Under Article 14 of the UK GDPR, where we collect personal information from a source other than the individual themselves, we are ordinarily required to provide that individual with information about how we use their data. However, Article 14(5)(b) disapplies this requirement where providing such notice would involve disproportionate effort.

We rely on this provision in the following circumstances, and for the following reasons:

Volume and nature of processing — In the course of delivering market research, stakeholder engagement, and advisory services to clients in the healthcare and life sciences sectors, we regularly identify and record information about a large number of individuals. These individuals are identified by virtue of their publicly visible professional roles and published expertise. Providing a personalised privacy notice to each individual at the point their details are recorded would in many cases be impractical, disproportionate to the limited professional information held, and inconsistent with reasonable professional expectations in these sectors.

Nature of the information — The personal information we process in these circumstances is predominantly professional in nature. It relates to individuals’ job titles, institutional affiliations, areas of clinical or scientific expertise, published views, and publicly available contact details. It does not typically include sensitive or special category information. The individuals concerned operate in public-facing professional roles in which a degree of professional visibility is inherent and expected.

Source of the information — The information is obtained from publicly available sources, including professional registers, institutional websites, published literature, and industry databases. Individuals who publish information in these contexts have a reasonable expectation that it may be accessed and used for legitimate professional purposes.

Alternative safeguards — In place of individual notification, we maintain this publicly accessible Privacy Notice, which explains in full the categories of individuals whose data we may process, the sources from which we obtain it, the purposes for which it is used, the legal bases we rely on, and the rights available to those individuals. We consider this notice to be a meaningful and accessible alternative to individual notification in the circumstances described.

Residual individual notification — Where we make direct contact with an individual whose data we have collected from a third-party or public source, we ensure that the individual is directed to this Privacy Notice at or before the point of first contact. This ensures that individuals who are actively engaged by us are informed of their rights and our processing at the earliest practicable opportunity, regardless of whether individual notification was provided at the point of data collection.

We keep this assessment under review and will provide individual notification where it is practicable and proportionate to do so, or where required by law.

Who do we share your information with

Your data may be included in deliverables shared with pharmaceutical, biotech, or other life sciences clients Newmarket works with. All data is subject to strict confidentiality and security obligations.

Personal data is not shared with third parties beyond the purposes described above. Where data is shared with clients as part of project deliverables, this is done on the basis of legitimate interests as described in this notice. Any other sharing of personal data will only take place where a separate lawful basis exists, or where explicit consent has been obtained.

How long we keep information

Personal data will not be kept longer than is necessary for the purpose of a project. We will review the necessity of keeping the personal data on completion of the project. This means that data will be destroyed, erased or anonymised from our systems when it is no longer required for the completion of a project or future projects.

We are likely to carry out interviews gathering information to complete projects. Any interviewee data will only be kept for the purpose of completing a relevant project and for completion of similar projects in the future should this be reasonable. The interviewee data will then either be destroyed, erased or anonymised as required.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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