Privacy Policy



Under the EU’s General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

BBI 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, tell you about your privacy rights and how the law protects you.

1.0     Purpose of this Privacy Notice

1.1       This Privacy Notice aims to give you information on how BBI collects and processes your Personal Data.

1.2       It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.

1.3       Where BBI or its subsidiaries act as a data processor on the instructions of a data controller, a separate Privacy Notice will be published by that data controller, usually on the relevant domain and provided directly to the relevant data subjects.

2.0       Contact details

2.1       Our full details are:

Full name of legal entity

BBI Group Holding Limited

BBI Companies

BBI Healthcare Limited, BBI Solutions OEM Limited; BBI Detection Limited & Novarum DX Ltd.

Data Protection Officer

Dr Phil Griffiths

Email address

Postal address

The Capital Tower, Greyfriars Road Cardiff CF10 3AZ


3.0       Changes to the Privacy Notice and your duty to inform us of changes

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.

4.0       The data we collect about you

4.1       We collect, use, store and transfer different categories of Personal Data about you which we have grouped together as follows:

4.2       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.

4.3       Special Categories of Personal Data these are 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). We do not normally collect any special categories of data nor do we collect any information about criminal convictions and offences other than for our employees or applicants for employment. However if we do need to processes such data we will ask for your explicit consent to do so.

5.0       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 goods or services or employee benefits). 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.

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

6.1       Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, and e-mail or otherwise. This includes Personal Data you provide when you:

6.2       Automated interactions. As you interact with our website or intranet, 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.

6.3       Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties and public sources as set out below:

7.0       How we use your Personal Data

7.1       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:

7.2       We may also use your Personal Data in the following situations, which are likely to be rare:

7.3       Generally we do not rely on consent as a legal basis for processing your Personal Data other than, where we have not had any prior relationship with you and you have not opted out of such marketing, in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing to that email or text.  

8.0       Purposes for which we will use your Personal Data

8.1       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 lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

8.2       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 if you need additional 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.



Category of Personal Data

Lawful basis for processing including basis of legitimate interest

To register you as a new client or employee.

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your service or order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

§  to recover debts due to us.

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) As an employee

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Financial

(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,

§  to study how customers and clients use our products/services;  and,

§  to administer our employee relationships

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

§  to study how customers use our products/services; and

§  to develop them and grow our business.

To administer and protect our business and our intranet and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Profile

(d) Technical

(e) Usage

(a) Necessary for our legitimate interests

§  for running our business and employee relationship,

§  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

(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

(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,

§  to grow our business)


9.0       Marketing

9.1       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:


10.0     Change of purpose

10.1     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.

10.2     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.

10.3     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.

11.0     Disclosures of your Personal Data

11.1     We may have to share your Personal Data with the parties set out below for the purposes set out in the table above.

11.2     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.

12.0     International transfers

12.1     Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.

12.2     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:


13.0     Data security

13.1     We have put in place appropriate security measures 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. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

13.2     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.

14.0     Data retention

14.1     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.

14.2     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.

14.3     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.

15.0     Your legal rights

15.1     Under certain circumstances, you have rights under data protection laws in relation to your Personal Data to request the following:

15.2     If you wish to exercise any of the rights set out above, please contacts our DPO. You can also contact the Information Commissioner’s Office via  for information, advice or to make a complaint.

15.3     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.

16.0     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.

17.0     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.

v1.2 29/05/18