PRIVACY NOTICE for HUNGERFORD VETS LTD
FOR CUSTOMERS AND PROSPECTIVE CUSTOMERS
This notice applies to you if you are an individual customer who (i) has been in contact with us to register with us; or (i) we have contacted you about the services/products we offer as a business.
This notice does not form part of any contract for services or products. A copy of our client terms and conditions can be found at www.hungerfordvets.co.uk or on our notice board in Reception
References to we, our or us in this privacy notice are to Hungerford Vets Ltd; Registered number 7471392; Registered Office The Veterinary Hospital, 4 Bath Road, Hungerford, Berks, RG17 0HE and its branch surgery, trading under Belmont Veterinary Clinic
We are committed to respecting your privacy. This notice is to explain how we may use the personal information we collect and use about you during and after your working relationship with us. This notice also explains how we comply with the law on data protection and what your rights are.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Practice Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.
1. PERSONAL INFORMATION WE COLLECT
When you interact with us or we interact with you in relation to our services, you may provide us with or we may obtain personal information about you, such as the following:
- Contact and identity details: information that allows us to contact you directly such as your name, email address, telephone number(s), and addresses
- Purchase details and requirements: details of the products or services you have asked us to provide to you, history of visits and treaments
- Financial and business information: credit/debit card details (paper copy only), payment and receipt details, refund or credit details and details of payment transactions with you,
- Records of your interactions with us: such as any enquiries or complaints you make, telephone conversations, letters and other correspondence (including e-mail).
- Responses to any feedback forms, surveys or competitions: we keep records of any responses you give us;
- CCTV images: recorded by our CCTV systems – car park area only.
2. SPECIAL CATEGORIES OF PERSONAL INFORMATION
We will not collect, store and use the following “special categories” of more sensitive personal information regarding you,:
- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
- information about your trade union memberships;
- health and sickness records, medical records and health professional information and
- biometric information about you, for example fingerprints, retina scans.
We may ask you specifically if you will consent for us to note the following categories of information for the sole purposes of allowing our staff to help you more efficiently
- information about any specific medical condition or disability information
If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.
3. WHERE WE COLLECT YOUR INFORMATION
We will collect personal information from a number of sources. These include the following:
- Directly from you: from yourself, through our website, make a complaint, contact us by phone, email or communicate with us directly in some other way, consent forms.
- Third parties authorised by you: a family member or someone else authorised by you.
- Others: such as insurance companies (claims only), referral clinics,
If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.
4. WHAT WE USE YOUR PERSONAL INFORMATION FOR
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.
|Purpose||Personal information used||Lawful basis|
|To enable us to provide our services or products to you or the organisation you work for|
|All the personal information we collect||This is necessary to fulfil our contract with you|
Welfare of your pet(s)
We have a legitimate interest in fulfilling our contracts with you
|Make payments to and receive payments from you||Transaction and payment information|
|This is necessary to fulfil our contract with you|
We have a legitimate interest in fulfilling our contracts with organisations
|Marketing to you our services or products which may be of potential interest to you or the organisation you work for||Name, personal contact details and other identifiers, and marketing preferences||We have a legitimate interest in marketing our services and special offers to you in order to promote animal welfare|
You may have requested that we send to you details of certain products and/or services
|To manage our business and internal reporting||All the personal information we collect about you||We have a legitimate interest to ensure that we operate efficiently and manage our business properly|
To be able to manage and perform our contract with you
|To deal with enquiries, complaints and other communications from you and dealing with legal disputes involving you||All the personal information we collect about you||We have a legitimate interest to ensure that we operate efficiently and deal with any enquiries, complaints or other communications|
We have a legitimate interest to ensure that all legal claims are managed effectively
|To conduct data analytics studies and customer satisfaction surveys to review, and better understand our customer, retention, attrition and satisfaction levels||Our client records and any information you provide in response to our client satisfaction surveys||We have a legitimate interest in order to improve as a business.|
|For the purpose of complying with any legal and regulatory requirements||All the personal information we collect about you|
|We have a legal obligation to comply with legal requirements and we have a legitimate interest in complying with any regulatory requirements|
|Storage of records relating to you and also records relating to our business||All the personal information we collect about you|
|To be able to manage and fulfil our contract with you, we may have a legal and/or regulatory obligation to do so and we also have a legitimate interest to keep proper records|
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or comply with legal obligations. For other personal information, whilst you may not be under an obligation to provide it to us, if you do not provide it then we may not be able to properly perform our services for you.
You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us and we do not usually rely on consent as a basis for processing your personal information. However if we have asked you for consent, and you have given us your consent to use your personal information, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.
Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide or carry out certain activities.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We share personal information with the following parties:
• Any party approved by you: for example family members.
• Pet insurance companies (claims only)
• Referral Clinics
• Account Arrears Collection
• Other service providers to our business and advisors, administration and IT services and other service providers. All our third-party service providers are required to take appropriate security measures to protect your personal information.
• Advisors: either advisors appointed by you, for example legal advisors, or advisors appointed by us.
• Purchasers of our business: buyers or perspective buyers to whom we may sell or negotiate to sell our business.
• The Government, government bodies or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.
6. DIRECT MARKETING
Email, post, telephone and SMS marketing: from time to time, we may contact you by email, post, telephone or SMS with information about products or services we believe you may be interested in.
We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you have purchased similar services or goods from us previously or you ask us to send you the information.
You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at firstname.lastname@example.org or by using the details set out in the “Contacting us” section below.
TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
In limited circumstances the people to whom we may disclose personal information as mentioned in the section “Who we share your personal information with” above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.
If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.
7. HOW LONG DO WE KEEP PERSONAL INFORMATION FOR
The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual veterinary practice and regulatory requirements. Generally, where there is no legal requirement, we retain all physical and electronic records for a period of approximately 7 years following the end of our client relationship with you or the organisation you work for because this is the limitation period for claims related to breach of contract. The exceptions to this general rule are:
- Where you have not yet become a client and we are only engaged in marketing to you, we will retain your details for a period of 7 days since our last interaction, unless you or the organisation you work for later becomes a client.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You can contact us by using the details set out in the “Contacting us” section below.
8. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION
You have the following rights in relation to your personal information:
- the right to be informed about how your personal information is being used;
- the right to access the personal information we hold about you;
- the right to request the correction of inaccurate personal information we hold about you;
- the right to request the erasure of your personal information in certain limited circumstances;
- the right to restrict processing of your personal information where certain requirements are met;
- the right to object to the processing of your personal information;
- the right to request that we transfer elements of your data either to you or another veterinary practice; and
- the right to object to certain automated decision making processes using your personal information.
Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.
9. CHANGES TO THIS NOTICE
We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.
10. CONTACTING US
In the event of any query or complaint in connection with the information we hold about you, please email email@example.com or write to The Practice Manager, Hungerford Vets Ltd, The Veterinary Hospital, 4 Bath Road, Hungerford, Berks, RG17 0HE. To correct or update information we already hold on you, please contact firstname.lastname@example.org.