Privacy Notice

Hereford Vision Surgical Group Limited takes the security of your personal data very seriously. If, after reading this privacy notice, you have any further questions, please feel free to contact us directly at tracy@herefordvision.com

1.  INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.HerefordVision.com and our business Hereford Vision Surgical Group Limited.

By providing us with your data, you warrant to us that you are over 18 years of age.

Hereford Vision Surgical Group Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Full name of legal entity: Hereford Vision Surgical Group Limited

Email address: tracy@herefordvision.com

Postal address: Suite 1a, Shire Business Park, Wainwright road, Worcester, WR4 9FA

If you are not happy with any aspect of how we process your data, you do have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), however, we should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at tracy@herefordvision.com

2.  WHAT DATA DO WE COLLECT? FOR WHAT PURPOSE AND ON WHAT GROUNDS DO WE PROCESS IT?

Personal data means any information capable of identifying an individual, including contact details, IT-related data and of course information regarding your health (special category data, see below).

We may process the following categories of personal data about you:

·       Communication Data includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. This data is processed for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful grounds for this processing are our legitimate interests, which, in this case, are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

·      Customer Data includes data relating to any services we provide, such as your name, title, health information, billing information, email address, phone number and contact details. We process this data to supply the services you have requested and to keep records of your medical treatment. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. 

·       User Data that includes data about how you use our website and any online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful grounds for this processing are our legitimate interests, which, in this case, are to enable us to properly administer our website and our business. 

·      Technical Data includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from analytics tracking system, such as Google analytics. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content to you and to understand the effectiveness of our marketing.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business, as well as to inform our marketing strategy.

Special Category Data

We need to collect the following sensitive data about you in order to deliver the healthcare services we provide:

·      information about your health and biometric data

We collect and process this data under Article 9 of the GDP regulations, specifically 9(2)h, which states: ‘processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3.’

Paragraph 3 states: ‘Personal data referred to in paragraph 1 may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.’

Where we are legally required to collect personal data, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (e.g. to carry out healthcare treatments). If you do not provide us with the requested data, we may therefore have to cancel the treatment you have requested but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at tracy@herefordvision.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. Where required or permitted by law, we may process your personal data without your knowledge or consent.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly, for example by filling in forms on our site or by sending us emails or letters. We may also automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details Cookie Policy.

We may receive data from third parties such as:

•      analytics providers such as Google based outside the EU, 

•      providers of technical, payment and delivery services, such as data brokers or aggregators. 

•      we also receive sensitive data from opticians, for example, relating to post-operative treatment results, or initial referrals. Before this is shared with us you will be requested to provide explicit consent to your optician.

4.  DISCLOSURES OF PERSONAL DATA  

We may have to share your personal data with the parties set out below:

•      Professional advisers including lawyers, bankers, accountants, auditors and insurers 

•      Service providers who provide IT and system administration services.

•      Government bodies that require us to report processing activities.

•       Video production companies (only with your explicit consent in advance).

•      Third parties to whom we sell, transfer, or merge parts of our business or our assets. 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

5.  INTERNATIONAL TRANSFERS  

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to data, hence European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third-party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

•      We will only transfer your personal data to countries that the European Commissionhave approved as providing an adequate level of protection for personal data by; or

•      Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

•       If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

6.  SECURITY OF DATA

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization, which we believe are compliant with the GDPR legislation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, they must keep it confidential and they are contractually obliged to do so. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

7.  DATA RETENTION  

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. Although we have a separate data retention policy, generally speaking, medical notes will be kept for 30 years.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8.  YOUR LEGAL RIGHTS  

Under data protection laws you have rights in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at tracy@herefordvision.com

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 or refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month, but 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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), however, we should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 9.  THIRD-PARTY LINKS  

This website may on occasion 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.

10.  COOKIES  

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.