Wildbore Veterinary Ltd respects your privacy and is committed to protecting your personal data.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
Our website and services are not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Wildbore Veterinary Ltd
Email address: email@example.com
Postal address: Wildbore Vetstop, Turner Road, Worksop, Notts, S81 7AE (please mark all correspondence for the attention of the data protection manager).
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender and proof of address identity documentation.
- Contact Data includes billing address, delivery address, email address, telephone numbers and your contact preferences.
- Financial Data includes bank account, direct debit and payment card details, and information relating to any arrangements for third parties to make payment on your behalf (such as insurance companies or charities).
- Transaction Data includes details about payments to and from you, details of any monies owed to us from you (both now and historically) and including where we decide not to provide services to you due to historic bad debts, and other details of products and services you have purchased from us, including membership to the VIP Club and membership to our Vets Deliver service.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Insurance Data includes information about pet insurance you have purchased from third party insurance provider(s)
- Account Data includes details of the account holder of each pet registered with us (including details of any additional account contacts and additional individuals who may communicate with us on behalf of a pet owner, for example where a friend or relative of a pet owner brings the pet into our practice where the pet owner is unable to do so).
- Pet Owner Data includes any notes we may make about the pet owner (or any individual who communicates with us in relation to the pet) which we deem relevant to the pet’s care or the pet owner’s account with us. We may in very limited circumstances include a note about any health condition which you have which may impact on the way that we treat your pet.
- CCTV Data includes any CCTV footage of you collected on or around our premises.
- Telephone Recording Data includes recordings of any telephone conversations we have with you.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide your pet with veterinary services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Financial, Pet Owner, Insurance and CCTV Data by filling in forms or by corresponding with us by post, phone, email or otherwise or by visiting out premises. This includes personal data you provide when you:
- register your pet with our practice;
- purchase products from us;
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please contact us for further details.
- Third parties. We will receive personal data about you from various third parties as set out below:
- Financial and Transaction Data from providers of technical and payment services.
- Insurance Data from third party pet insurance companies.
- Financial Data from third party pet insurance companies and charities.
- Identity, Contact, Account and Pet Owner Data from other veterinary practices who may refer you to our practice.
- Where you are not an account holder but communicate with us on behalf of an account holder, Identity and Contact Data from owners of pets registered with us, who may provide us with your details when they provide Account Data in respect of their pet.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data. We will contact you if we would like your consent at any point in the future.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as an account holder when you register your pet with our practice||(a) Identity
|Performance of a contract with you|
|To respond to your enquiry||(a) Identity
|Necessary for our legitimate interests (to respond to enquiries from potential and existing customers in order to offer our services where appropriate or respond to feedback or complaints)|
|To deliver veterinary services to your pet in order to fulfil our contract with you including:
(a) Manage payments, fees and charges (including where a third party such as an insurance company or charity makes payment on your behalf)
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To register you with the VIP Club and/or Vets Deliver service and provide you with the associated benefits||(a) Identity
|Performance of a contract with you|
|To administer the payment of services which you have requested from us via your pet insurance scheme||(a) Insurance||Performance of a contract with you|
|To keep a detailed record of any information which we deem relevant to your pet’s care or the services we are providing to you for example:
(d) Pet Owner
|Necessary for our legitimate interests (to ensure that our records are up to date so that we know who to contact about the pet’s case; to ensure that you receive appropriate assistance; to keep our practice staff safe)|
|To provide details of your pet’s clinical record to other veterinary practices which may happen where:
(d) Pet Owner
|(a) Necessary for our legitimate interests (to ensure that the pet receives appropriate care)|
|To interact with you on social media||(a) Identity||(a) Necessary for our legitimate interests (to interact with our customers and potential customers)|
|Where you are not an account holder but communicate with us on behalf of an account holder (for example, where you bring an account holder’s pet into our practice where they are unable to do so), we will process your personal data in order to provide veterinary care to the account holder’s pet, which may include:
|(a) Necessary for our legitimate interests (to ensure that the account holder’s pet receives appropriate care and to provide services to the account holder in accordance with our contract with them)|
|To collect and record CCTV footage on and around our premises||(a) CCTV||(a) Necessary for our legitimate interests (to ensure the safety of our staff, customers and visitors). For more information, please contact us to request a copy of the CCTV policy.|
|To record telephone conversations we have with you (including both inbound and outbound calls)||(a) Telephone Recording||(a) Necessary for our legitimate interests (for training purposes and to improve the quality of our customer service (including, for example, to investigate complaints))|
We do not currently carry out direct marketing. We will contact you in the future if this changes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
If your pet requires treatment from a veterinary practice outside of the European Economic Area (EEA), for example where you are travelling with your pet outside the EEA or where you and your pet have permanently moved out of the EEA, we may (in the course of sharing your pet’s clinical record) share your personal data with the new veterinary practice. This will involve transferring your data outside the EEA.
If we were required to transfer your personal data out of the EEA, we would ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where the third party veterinary practice is based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if this is relevant to you and you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Telephone Recording Data is stored by our telephone recording service provider, First Call, for a period of 6 months.
Details of retention periods for different aspects of your personal data are available upon request from us – please contact us if you require this information.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Other individuals who may bring your pet into our practice on your behalf, who will receive an invoice in respect of any veterinary services provided to your pet which may include your Identity, Contact, Transaction and Insurance Data.
- Charities and insurance companies who may make payment for services to us on your behalf.
- Other veterinary service providers primarily based within the United Kingdom (and occasionally to other veterinary practices who are based in the EEA, or in very exceptional circumstances to other veterinary practices based outside of the EEA) who require details of your account with us when you transfer to their practice or when we refer you to them.
- Our third party service providers who are our delivery partners in our VIP Club and Vets Deliver service.
- Service providers acting as processors based within the EEA who provide IT and system administration services and telephone recording services, including First Call.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, debt recovery agencies and insurers based within the EEA who provide consultancy, banking, legal, insurance, debt recovery and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.