privacy

Eyecare Opticians Privacy Policy 

Who we are?

We at Eyecare Opticians Ltd. are registered with the Information Commissioners Office as a Data Controller registration number Z1912336. We are specialist in optometry services and operate from 307 Richmond Rd, Ham, Kingston Upon Thames, KT2 5QU.

Your Privacy

Your privacy matters to us and we are committed to the highest data privacy standards, patient confidentiality and adherence with the Data Protection Act 2018 and UK GDPR.

We adopt the six core principles of data protection which are:

1. Lawfulness, fairness and transparency - we process personal data lawfully, fairly and in a transparent manner in relation to you, the data subject.
2. Purpose limitation - we only collect personal data for a specific, explicit and legitimate purpose. We clearly state what this purpose is in this Privacy Notice, and we only collect data for as long as necessary to complete that purpose.
3. Data minimisation - we ensure that personal data we process is adequate, relevant and limited to what is necessary in relation to the processing purpose.
4. Accuracy - we take every reasonable step to update or remove data that is inaccurate or incomplete. You have the right to request that we erase or rectify erroneous data that relates to you, and we will complete this task as soon as possible but guarantee to do so within a month.
5. Storage limitation - we delete personal data when we no longer need it. Whilst the timescales in most cases aren't set, we outline our retention strategy within this Privacy Notice.
6. Integrity and confidentiality - we keep personal data safe and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Collection of your Personal Data

We collect your personal information via disclosure directly from you or your parent or guardian. This might be via our website, via our booking system, telephone or face to face engagement.

Categories and Type of Personal Data Collected and processed.

We collect contact details from you (name, address, telephone number(s), email addresses and date of birth). In addition to this we collect other relevant details including current and past relevant health and medication information, your examination results including images, and relevant lifestyle information such as pastimes or work impacting on health care. We may also store associated information received from other health care professionals as part of your ongoing care.

Finally, we collect financial information where appropriate including payment card details and banking details for direct debit mandates.

We treat all personal data as sensitive but acknowledge that we also process special category data.

Child Data

Article 8 of the UK GDPR and Article 9 of the UK Data Protection Act 2018 specify how we are permitted to process data relating to children under 16 (For the UK this is under 13). Given our industry we comply with this requirement by permitting parents or guardians to make appointments for children and to provide us with their own contact details to use on behalf of the children. On the appointment confirmation we offer a statement of understanding which confirms that the recipient is indeed a parent or guardian of the child. 

Reason for Data collection and processing activities.

Contact information is captured to enable us to contact you through various communication channels on matters directly related to your treatment. This could include appointment reminders, results, check up reminders and any other information which is felt to be crucial to your care. We may also send offers from us about our services. 

Clinical data is collected as an essential means of providing you with the service which you require and without collecting this information our service could not be delivered.

Payment information is collected to facilitate the payment for our services.

Sharing of Personal Data

During the delivery of our service to you, we will share your data with other companies who are critical for the provision of our service to you and will be viewed as Data Processors. They are under contract with us and have provided sufficient guarantees that they will process your data only as per the terms of that contract and throughout processing activities will ensure your data is protected using appropriate technical and organisation measures. We may also need to share your data with other health care providers, such as the NHS, where this is needed to ensure you receive appropriate treatment and care.

We may pass information to external agencies and organisations, including the police, for the prevention and detection of fraud and criminal activity. Should any claim be made, we may pass your personal information to our insurers and if our business is wholly or partially transferred to a third party, your personal information may be one of the transferred assets.

A full list of processors is available from our Data Protection Officer.

Securing and Processing of your Personal Data

Your data is stored and processed by Optix Software Ltd within their UK facilities which has appropriate security processes and is is certified to ISO27001. If we collect Direct Debits from you these payments will be processed by Eyecare Payments Ltd. Any third-party company is only permitted to process your data for the specified purposes and in accordance with our instructions.

Your data is also stored within local devices secured using passwords and user authentication. Our practice is secure and operated to ensure data and the devices on which that data resides, are protected. 

In the unlikely event that we lose your data, or a device on which your data resides, or it is accessed by someone unauthorised, we have a duty to inform you immediately. If the loss or unauthorised access of your data has potential to cause you harm, we will also report this to the Information Commissioners Office, who are responsible for regulating data protection legislation in the UK. 

https://ico.org.uk/ 

Our legal basis for processing your personal data?

We are required to identify one of six possible legal grounds for processing. These are: 
• consent
• contract
• legitimate interests
• vital interests
• public task 
• legal obligation

As all of our processing activities are crucial to the provision of the service which we enter into a contract with you to provide, we process your data based on that contractual relationship.

We could also process your data under our legitimate interests as all processing activities are essential for the provision of our service to you.

Where special category of data is processed, we do so Article 9 (2) h – processing is necessary for…the provision of health or social care.

How long do we keep your personal data for?

We process three categories of personal data and retain this data for different periods of time.
We retain your information for as long as reasonably necessary to fulfil the purpose for which it was collected, to provide our products and services and to maintain records to satisfy tax and other legal requirements.

Contact information is retained as long as you are a customer of ours. Where you have not used our services recently, and in the absence of a direct data subject request, we hold contact information for a period of 10 years from the last appointment. 

Based on the guidance of The Association of Optometrists the clinical data we process is held for a period of 10 years.

Payment information is held by us only as long as is necessary to process the payment or to set up the direct debit mandate.

Your rights in relation to personal data

Under the UK GDPR, you have rights to access and control your personal data. These rights include:

• access to personal information 
• correction and deletion
• withdrawal of consent (if processing data on condition of consent)
• data portability
• restriction of processing and objection
• lodging a complaint with the Information Commissioner’s Office

You can exercise your rights by emailing our Data Protection Officer on EyecareOpticiansDPO@@clinicaldpo.com

If you are unhappy with anything we have done with your data, you have the right to complain to the Information Commissioners Office.

To make a complaint to the Information Commissioners Office use the link below or call their hotline on Tel No.: 0303 123 1113.    
https://ico.org.uk/concerns/ 

Use of cookies and other technologies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Transfer of data outside the EEA 
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

How to contact us?

For all data protection matters or questions relating to how we manage your data, you can contact our Data Protection Officer via these means:

Data Protection Officer: Clinical DPO.
Phone Number 0203 411 2848
Email: EyecareOpticiansDPO@@clinicaldpo.com
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