Smiths Group is committed to protecting the privacy of your personal information. We have written this Privacy Statement to let you know how Smiths Group uses your personal data. In this statement you will find information about the types of personal data we collect from you, when we collect your personal data and how long we keep it for, how we collect your personal data, our reasons for collecting and using your personal data, and information about how we share your personal data.  When we say "we", "us", or "our" in this Privacy Statement, we mean Smiths Group PLC.

Please take a moment to review this Privacy Statement in detail to understand our views and practices regarding your personal data and how we will treat it.

Any changes to this Privacy Statement will be communicated on www.smiths.com and, unless stated otherwise, will take effect immediately once posted.

For the purpose of applicable data protection laws, the data controller is Smiths Group PLCand you can contact us using the following contact information:

Office for Data Protection Compliance

Smiths Group PLC

4th Floor

11 - 12 St James Square

London

SW1Y 4LB

T: +44 (0) 20 7004 1600

F: +44 (0) 20 7004 1644

E: dataprotection@smiths.com

Smiths Office for Data Protection Compliance acts as Data Protection Officer for the European entities of our Smiths Medical division and may be contacted at this address.

WHAT PERSONAL DATA DO YOU COLLECT FROM ME AND USE?

We collect, store and use the following categories and types of data which identifies you or which can be used to identify you:

• identification data, such as your name, business or personal email address, business or personal address, business or personal telephone number, IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser;
• information about your job, such as your position, title, management level, work location, division, department, and position level; and
• information about your access to our network and premises, such as CCTV images, swipe card access, time recording software and internet access usage.
  
  

WHEN DO YOU COLLECT MY PERSONAL DATA?

We collect your personal data:

• when you visit any of our websites and agree to the use of cookies, or where you use our contact functionality on the websites;
• when you sign up to receive email alerts, marketing information or other communications from us via our website;
• when you report an issue, ask us a question or email us with feedback, including through any "contact us", helpline or webchat channels;
• when you respond to any surveys that we have sent to you via email; and/or
• when you use our products and services.

In most cases you provide your personal data directly to us via our website.  However, we may collect some usage data automatically when you browse our website.

WHAT ACTIVITIES DO YOU CARRY OUT USING MY PERSONAL DATA – "PROCESSING ACTIVITIES"?

We use your personal data in order to carry out the following Processing Activities:

• improve your experience when using our websites;
• help you to complete a transaction or order;
• communicate with you;
• provide you with support or education about our products and services;
• provide you with information about our products and services;
• carry out investor relationship activities;
• comply with our business, regulatory and legal obligations.

WHY DO YOU CARRY OUT THESE PROCESSING ACTIVITIES USING MY PERSONAL DATA?

Some of the laws that apply to us require us to tell you the legal reason for using your personal data. We list these below:

Consent: Where applicable and appropriate, we will ask for your consent to collect and use your personal data.  If we need your consent to collect and use your personal data we will make clear to you that the provision of your consent is voluntary.  You have the right to withdraw your consent at any time by contacting us using the contact information set out above.

Our core activities: In many cases using your personal data is core to our legitimate business interests.  Where we use your personal data for these purposes you will have the right to object to our use of your personal data by contacting us using the contact information set out above. 

We use your personal data for our legitimate interests to provide you with information about our products and services and to understand your use of our website, products, and/or services.  We use information collected via cookies (electronic text files) that we place on to your machine in order to provide you with the best level of service when using our tools.  These analytics tell us whether you had technical difficulties when using our website or to provide you with a service that is tailored to you.  Our Cookie Policy provides you with more information about our use of cookies.

Legal Requirement: At times we may receive requests from regulators or other authorised bodies to use your personal data in order to comply with a legal or regulatory obligation.  Where this is the case, we will ensure that the request is legitimate. 

Overall, the provision of your personal data is voluntary for you and not required by law. However, in order to provide the website to you, to carry out a contractual relationship with you and/or to offer other products and services to you, your personal data are necessary. Not providing your personal data may result in disadvantages for you - for example, we may not be able to carry out a contractual relationship with you or you may not be able to use certain products and services or may accept limited functionality. However, not providing your information will not result in legal consequences for you.

FOR HOW LONG DO YOU KEEP MY PERSONAL DATA?

We keep your personal information for no longer than is necessary for the purpose for which the information is collected and to manage our relationship with you. Where personal information is kept, that period will be determined based on applicable local law. For further information, please contact us as set out above.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

We explain here the rights that you may have in relation to personal data if you live in the European Union:

HOW CAN I FIND OUT WHAT PERSONAL DATA YOU HOLD ABOUT ME?

You may contact us using the contact information above if you would like more detailed information about what personal data we have collected from you, including the categories of personal data processed, the purposes of the processing and the third parties to whom that data is transferred.  You may also request a copy of your data. Note that we do have to take into account the interests of others, and certain other legal obligations or restrictions, so this is not an absolute right. 

CAN I ASK YOU TO DELETE OR CORRECT MY PERSONAL DATA? 

You may contact us using the contact information above if you would like us to delete your personal data or to have your personal data corrected and, if required to do so, we will comply with your request.

CAN I ASK YOU TO STOP USING MY PERSONAL DATA?

You may contact us using the contact information above if you would like us to stop using your personal data (either entirely or for some of our Processing Activities) and, if required to do so, we will comply with your request.

CAN I ASK YOU TO TRANSFER MY PERSONAL DATA TO A THIRD PARTY?

You may contact us using the contact information above if you would like us to transfer your personal data to a third party in a structured, commonly used and machine readable format and, if required to do so, we will comply with your request.

DO YOU SECURELY STORE MY PERSONAL DATA?

We apply strict security standards, controls and processes to protect your personal information from unauthorised access, loss or accidental deletion.  These include restricting who can have access to your personal data and protecting your data with security tools appropriate to the type of information e.g. encryption software and secure file transfer tools.  We also require that our third party processors who handle your personal data do the same.

DO YOU USE COOKIES?

Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remembering your preferences and generally improving the user experience.

Our Cookie Policy provides you with more information about our use of cookies.

DO YOU SHARE MY PERSONAL DATA WITH THIRD PARTIES?

To help us carry out our Processing Activities, we may need to share your personal data with entities within and outside of Smiths Group as follows:

• Smiths Entities – we may transfer your data to other Smiths Group entities who may collect, transfer and/or use the personal data we have collected from you for some or all of our Processing Activities.  Where we share your personal information with other Smiths Group entities, they will use your information in a manner consistent with the purposes for which it was originally collected and consistent with this Privacy Statement and applicable data protection and privacy laws.
• Our Data Processors – from time to time, we may share your personal data with our third party service providers or with other Smith Group entities who provide us with investor relationship, company secretarial, legal, regulatory, corporate advisory, event management, talent management, recruitment, marketing, communication and/or IT support services ("Data Processors"). In order to provide such services, our Data Processors process your personal data on our behalf.  Our Data Processors have met our criteria as trusted guardians of personal data and are subject to contractual obligations to implement appropriate security measures to safeguard your personal data and to process personal data only as instructed by us.
• Other Third Parties – your personal data may also be transferred to regulators, courts, and other authorities (e.g. tax and law enforcement authorities) and independent external advisors (e.g. lawyers, auditors). We may also share certain personal data with business partners, customers and suppliers to carry out our business activities.

For the full list of the Smiths Group entities, Data Processors and other third parties that we may share your data with, please contact us as set out above. Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information.  You should check the privacy policies of third party websites before you submit any personal information to them.

We do not sell or rent the personal information we collect from you without your prior explicit consent.

DO YOU TRANSFER MY PERSONAL DATA OVERSEAS?

Some of the Smiths Group entities, Data Processors and other third parties that we share your personal data with are located outside of the European Economic Area (EEA).

If we transfer your personal data to entities outside of the EEA (which include our IT service providers, recruitment partners and other Smiths entities in the US and India), we will make sure that your data is being protected as required by applicable data protection law. For transfers to other Smiths Group entities, Smiths will be bound by the EU Standard Data Protection Clauses (see - Article 46(2)(c) of the General Data Protection Regulation). For transfers to third party service providers, we will do this either by putting in place the EU Standard Data Protection Clauses (see - Article 46(2)(c) of the General Data Protection Regulation) OR if the third party service provider is located in the USA, we will check if the third party service provider has signed up the EU-US or Swiss-US Privacy Shield framework, thereby providing an adequate level of data protection as recognized by the EU Commission (Art. 45 (1) GDPR).  In this case, we will require in our contract with them that they remain signed up to the Privacy Shield framework while processing your personal data.

You can ask for a copy of the appropriate safeguards by contacting us as set out above.

WHAT SHOULD I DO IF I AM NOT HAPPY WITH HOW MY INFORMATION IS BEING USED? 

You can contact us using the contact information above if you are not happy with how we are handling your personal data.   

You also have the right to complain to our relevant supervisory authority, which is the Information Commissioner’s Officer (ICO) in the UK, who is responsible for ensuring we correctly follow the General Data Protection Regulations 2016 or to any other competent data protection supervisory authority.  You can contact the ICO at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Contact details of other European data protection supervisory authorities can be found here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080