In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, our customers and administration assisstants of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data and your rights regarding your data.
DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles we will ensure that:
Processing is fair, lawful and transparent
Data is collected for specific, explicit and legitimate purposes
Data collected is adequate, relevant and limited to what is necessary for the purposes of processing
Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay.
Data is not kept for longer than is necessary for its given purpose
Data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
We comply with the relevant GDPR procedures for international transferring of personal data
TYPES OF DATA HELD
We keep several categories of personal data on our customers in order to carry out effective and efficient processes. We keep this data in a customers centre file relating to each customer and we also hold the data on our computer systems, for example Smoothbook.
Specifically, we hold the following types of data:
Personal details such as name, address, phone numbers, email address
COLLECTING YOUR DATA
You provide several pieces of data to us via your referring vet during the referral process and subsequently upon commencement of hydrotherapy treatment.
Personal data is kept in files or within the Company’s IT systems.
LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively provide you with the service provided.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data Lawful Basis
Making online Bookings Our legitimate interests
Sending feedback to your referring vet Our legitimate interests
Completing statements of hydro for insurance purposes Our legitimate interests
Ensuring efficient administration of our agreement Our legitimate interests
Managing accounting systems Our legitimate interests
Dealing with legal claims against us Our legitimate interests
Ensuring our administrative and IT systems are secure Our legitimate interests
SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to you:
Trade union membership
Genetic and biometric data
We do not carry out processing activities using special category data.
FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean we are unable to fulfil our requirements for entering into a contract with you. This could include being unable to offer you hydrotherapy treatment for your animal.
CRIMINAL CONVICTION DATA
We do not collect any data regarding criminal conviction data
WHO WE SHARE YOUR DATA WITH
Owner, staff who have the responsibility of carrying out treatment will have access to your data which is relevant to their function. All with such responsibility have been trained ensuring data is processed in line with GDPR.
Data is shared with third parties for the following reasons: Smoothbook to ensure an efficient booking system. We have a data processing agreement in place to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
PROTECTING YOU DATA
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
We only keep your data for as long as we need it for, which will be at least for the duration of your hydrotherapy treatment. Some data retention periods are set by law. Retention periods can vary depending on why we need your data, as set out below:
Hydro Treatment records – 5 years after conclusion of treatment.
AUTOMATED DECISION MAKING
Automated decision making means making a decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be amde about you using this process.
You have the following rights in relation to the personal data we hold on you:
The right to be informed about the data we hold on you and what we do with it;
The right to access the data we hold on you;
The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also know as ‘rectification’;
The right to have data deleted in certain circumstances. This is also known as ‘erasure’;
The right to restrict the processing of the data;
The right to transfer the data we hold on you to another party. This is also know as ‘portability’;
The right to object to the inclusion of any information;
The right to regulate any automated decision-making and profiling of personal data.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means we will stop processing your data.
MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
DATA PROTECTION COMPLIANCE
Our Data Protection Officer is: