GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2.Who are we?
Mr Ian Jobson is the data controller. This means he decides how your personal data is processed and for what purposes. Our contact details are: Rochford Veterinary Surgery 19 East Street Rochford Essex SS41DB . For all data matters contact Mr Jobson on firstname.lastname@example.org or by Post to the surgery Address
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
Processing data necessary for the performance of a contract with you regarding your pet or other business contract and to fulfil any legal obligation compliance.
To inform you of relevant services and products that may be of interest to you . Full details of the legal basis for processing your personal data is set out in section 5 below
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data such as names address and contact details together with details of your pets and information about their health and financial data related to your transactions with the surgery
We have obtained your personal data from yourself or a family member usually either by telephone or in person at the surgery
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|☐ Consent of the data subject;||Where you will have specifically indicated a willingness for the data to be used ie for supplying you with details of services that may be of interest to the health of your pet
|☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||Information required to perform the contract to care for your animals health . Matters relating to looking after your pets health such as vaccination and parasiticide reminders|
|☐ Processing necessary for compliance with a legal obligation||Compliance with Relevant UK laws and the requirements of government agencies such as HMRC and the requirements of the RCVS|
|☐ Processing necessary to protect the vital interests of a data subject or another person
|☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
|Processing related to such areas as Notifiable or Reportable Diseases in the UK or related to issue and maintenance of Pet Passports|
|☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||Processing of data and sharing of data with insurance companies in order to arrange cover or process a claim, send laboratory tests etc.
Similarly where processing and sharing of data is necessary for the legitimate purposes of referring animals for specialist/further treatment
Sharing and processing of data to enable Online Appointment booking, Vaccination and other reminders to be sent out.
Storage/Backup of data online such as with GSuite/ Microsoft365 ,necessary for secure storage and retrieval of our business data.
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with other animal health professionals to whom your pet is being referred ie Specialist Veterianry Centres or Physiotherapy centres, Insurance companies in connection with arranging cover or to process a claim, with third party companies who perform specific data processing actions for us ie to send out reminders or allow you to make online appointment bookings and also with Government bodies or law enforcement who have a legal right to request it
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of usually 7 years in order fulfil our legal requirements under UK tax and accounting law and in case of any legal claims or complaints, also so that we have relevant Medical histories available from your pets
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract between ourselves and yourself for the care of your pet or provision of other business service . As stated earlier there are also some sorts of data which we require for legitimate business purposes as previously described.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA then you have a right to withdraw your data form processing
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not transfer any of our practice management system data outside the European Economic Area. Any documents or email stored on Gsuite outside the EEA are covered by enhanced PrivacyShield protection provisions as per our Data Protection Agreement with Google
11. Automated Decision Making
We do not use any form of Automated decision making in our Business
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER on email@example.com or by Post to Rochford Veterinary Surgery. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.