This notice explains when and why we collect your Personal Data, how we use it, how we keep it secure and your rights in relation to it.
Personal Data is defined as information concerning any living person (a natural person who hereafter will be called the “Data Subject” / “you”).
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) which is EU wide, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the secure movement of personal data.
Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk). For the purposes of the GDPR, Equine Vet Clinic are the “Data Controller” and “Data Processor” of all personal data we hold about you.
We may need to amend this Privacy Notice from time to time however we will always let you know if we make any significant changes. You may find out more about this from our website.
Who we are
We are The Equine Vet Clinic Limited. Within this Privacy Notice we also use the abbreviation “EVC”. We are a veterinary service organisation that has been operating for 18 years.
We are the trading company incorporated in Scotland as The Equine Vet Clinic Limited, whose registered office is Murray Associates, Business First Business Centre, Linwood point, Renfrewshire, PA1 2FB, under Company Number SC434689. “Petvets” and “Animal Drug Store” are wholly owned subsidiaries of The Equine Vet Clinic Limited.
EVC is regulated by the RCVS, Belgravia House, 62-64 Horseferry Road, London, SW1P 2AF and is an Accredited Practice under the practice standards scheme.
Why do we collect your Personal Data
We collect your personal data so we can keep in touch with you about your membership of the practice, your account management and other products and services that we believe will be of interest to you. We use your personal data to manage your veterinary account and veterinary service requirements. We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The Information Commissioners Office refers to this as the ‘lawful basis’ for processing personal data. Further information about the lawful basis of our processing of your personal data is outlined below.
The kind of Personal Data we collect
The information collected about you includes:
· General identification about you and your contact information
· Information about the type of veterinary work and veterinary nursing work that you require.
· Telephone recordings of your conversations with us
· Technical information, for example your computer IP address and your facebook contact address
We do not routinely collect personal data which would be categorised as “sensitive” or “special categories of data”, unless you become involved with disciplinary proceedings, convictions, or alleged criminal activity.
How we collect your Personal Data
EVC collects Personal Data:
· Directly from you; from forms and surveys that you complete, from your correspondence and phone calls with us and details of your visits to our website, including but not limited to personally identifying information;
· Through our website (the “Site”) and other software applications made available by us for use on or through computers and mobile devices (the “Apps”);
· From our social media pages and other social media content, tools and applications (our “Social Media Content”);
· Through other means such as personal data provided to us via third party websites, our business partners or subcontractors;
Lawful Basis for processing Personal Data
We must have a lawful basis for processing your personal data. The relevant lawful basis upon which we rely is dependent upon why we need to process the data. The EVC processes data under one of three lawful bases:
1. Administration and Operation of a Contract
This is when we need to use your personal data in order to operate the contract of engaging in providing the service of veterinary care and opening an account to record clinical and financial information relating to this service.
Examples of where we use personal data for contractual administrative purposes include;
· providing you with professional veterinary services
· maintaining databases of our clients and keeping you informed;
· providing client benefits
· fulfilling an order for goods or services (whether placed online, over the phone or in person);
· so that we can respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this)
2. Legitimate Interest
This is when we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests. Broadly speaking Legitimate Interests allow us to process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests. Before we rely upon our legitimate interest we will carefully consider and balance any potential impact on you and your rights.
Examples of where we apply legitimate interests include:
Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure. We also have a legitimate interest in receiving and processing Personal Data about claimants or potential claimants which is provided to us under the terms of the Policy to safeguard your interests.
Keeping you informed: We may from time to time send you postal communications, that include;
· information about training courses
· highlighting EVC benefits and offers;
· our events and activities;
· products, services and offers (our own, and those of carefully selected third parties which may interest you or where a benefit is received by the EVC);
A newsletter may be provided as a benefit. We send these out by email two times a year to all our clients (unless you specifically ask us not to). Please be aware that our newsletters may include a number of advertisements, inserts, competitions and other information. We may also send you information by post to let you know about products and services that we believe will be of interest to you. We do our very best to keep these relevant and to a minimum.
You can decide not to receive these communications or change how we contact you at any time. If you would like to stop receiving our newsletters, or information about new products and services, please let us know by contacting us using the details provided at the end of this Notice.
Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our clients.
Internal Research and Analysis: Your personal data also helps us to get to know you better. Likewise, keeping a record of your veterinary work helps us to send you relevant information.
We may carry out internal analysis on data relating to our clients.
We analyse data to determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you and to provide you with the most relevant information as long as this does not harm any of your rights and interests. To do this, we may make use of profiling and screening techniques of our client database to communicate with you effectively and efficiently.
Due Diligence: We may need to conduct investigations on clients and potential customers to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
For more information about your rights, please see Your rights as a data subject below.
This is when you have given us express permission to use your data for a specific purpose. We use opt-in consent to send you the information about new products and services by email, text message (SMS) or telephone. You can set your preferences in respect of electronic communications by contacting us via email.
We will only send you electronic marketing if you’ve requested it. As part of our service we will send you electronic communications (emails and SMS) relating to the products you’ve requested and relating to any service(s) that we deem applicable. However we, and carefully selected third parties, will only send you electronic direct marketing communications if you have given us your explicit consent, and only via the channels you have agreed.
You have a legal right to prevent your information being used for marketing purposes and you can change your preferences to opt out of receiving marketing at any time by contacting us using the details provided at the end of this Notice.
EVC will process personal data for the duration of any contractual relationship we have with you and will continue to store only the personal data needed after the contractual relationship has ended in line with our Data Retention policy. We continually review what information we hold, and delete what is no longer required.
Data is held in the United Kingdom using secure servers and secure off site storage facilities. EVC does not transfer personal data outside the EEA.
Sharing of Personal Information
We may share Personal Data with insurance parties including reinsurers, financial institutions and other business partners or suppliers such as accountants, actuaries, auditors, lawyers and other professional advisers. EVC may share Personal Data with other data processors such as printing companies, who will act strictly under our instructions. To prevent any commercial conflicts of interest, the names of these parties are confidential. We may also share the information with government or other public authorities such as HMRC, law enforcement and other regulators. Data shared in this way will be kept in accordance with each firm’s Data Retention Policy.
Your rights as a data subject
At any point whilst EVC is in possession of or processing your personal data, all data subjects, have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to ask us to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. This would not apply to accounts in arrears or areas where there are unresolved financial arrangements.
Right to restriction of processing – where certain conditions apply you have a right to ask us restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation. Your medical records will be transferred to any veterinary practice of your choice.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to a decision based solely
on automated processing or profiling.
EVC can, at your request, confirm what information it holds about you and how it is processed.
If, after carefully considering any request that you might make in respect of the above rights, we refuse your request we will provide you with a reason as to why. You have a right to challenge our decision to refuse your request and can do so by making a complaint (see below).
Automated decision making
No automated decision making takes place including within EVC.
EVC tries to exceed your expectations in everything that we do. However, we know that there may be times when we do not meet our own high standards. When this happens, we want to hear about it, in order to deal with the situation as quickly as possible and put measures in place to stop it happening again.
· To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
· To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
· To make sure everyone in our organisation knows what to do if a complaint is received.
· To make sure all complaints are investigated fairly and in a timely way.
· To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
· To learn from complaints and feedback to help us to improve what we do.
We take complaints very seriously and we treat them as an opportunity to develop our approach. This is why we are always very grateful to hear from people who are willing to take the time to help us improve. In the event that you wish to make a complaint about how your personal data is being processed by EVC, you have the right to complain to EVC Practice manager who is also the data protection officer. If you do not receive a response within 30 days or should we fail to provide you with details of the data requested you have the right to refer your complaint to the Information Commissioner.
We have provided our contact details and those of the Information Commissioner below:
The Equine Vet Clinic
Brown Egg farm
Information Commissioner’s Office
Tel 0303 123 1113