Wright & Morten Veterinary Group Limited is committed to protecting and respecting your privacy. This policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of the Data Protection Act 1998 (the "Act") and 2018 GDPR compliance, the data controller is Wright & Morten Veterinary Group LLP, 26-38 Cumberland Street, Macclesfield, Cheshire, SK10 1BZ.
By using the services provided by the Wright & Morten Veterinary Group, you understand and agree that personal information you provide will be held on a database created and operated by us, and/or other selected third parties.
What information do we collect and why?
When you register your animal with us, you will be asked for some essential information including your title, first name, surname, postal address, email address, telephone and if applicable payment information. You may also be requested to give your details for other reasons. These details are collected either in person, by telephone or online, to help us:
• Register your details as a new client or update your details if they change
• Register your pet on health plans
• Make appointments
• Process the fees due for any treatment
• Contact you about your pet, your account or credit status where required;
• Deliver a safe and secure service by helping to prevent and detect fraud. We may need to disclose information to assist legal or debt recovery processes;
• Understand your needs and listen to your feedback via market research/shopping analysis, customer polls and surveys;
• Enhance your experience by delivering a more personally tailored service; • Respond to any issues or queries via the customer service advisor teams; and/or
• Notify you about changes to our service.
How we protect your information
We endeavour to protect your information by:
• Keeping your information up-to-date and accurate. Please note that, to do this, we require you to tell us if any of your details such as your name or address change; and
• Having in place strict security procedures for the storage and disclosure of your information to prevent unauthorised access.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to and/or through any relevant on-line portals; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Protecting your security
To ensure that your credit, debit or charge card is not being used without your consent, we will validate name, address and other personal information supplied by you against appropriate third-party databases. By accepting these terms and conditions you consent to these checks being made. In performing these checks personal information provided by you may be disclosed to a registered Credit Reference Agency which may keep a record of that information. You can rest assured that this is done only to confirm your identity, that a credit check is not performed and that your credit rating will be unaffected. All information provided by you will be treated securely and strictly in accordance with the Act.
Statement on the use and disclosure of Personal Data
We may send you by SMS, email or post, details on offers, products, reminders and services which may be of interest to you. We may also telephone you to discuss treatment details or for market or service research.
We may also permit selected third parties to use your data to provide you with information about goods and services which may be of interest to you and they may contact you about these by post or telephone. They may also contact you by email or SMS where you have consented to receiving such communications.
We may monitor or record telephone calls to ensure our quality standards are maintained and for fraud prevention purposes.
We may use for the purpose of promotional, marketing and publicity purposes in any media worldwide any comments or feedback (excluding personal data) which you post publicly or provide to the surgeries, without notice or without any fee being paid.
We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Wright & Morten Veterinary Group LLP or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions or agreements or contracts between us or to protect the rights, property, or safety of Wright & Morten Veterinary Group LLP, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, debt recovery, credit risk reduction and our internal investigations including customer complaints and claims.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise your right not to receive marketing information at any time.
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have a right to access the personal data about you that is held by us. To obtain a copy of the personal information we hold about you, please write to us at the following address: The Practice Manager, Wright & Morten Veterinary Group LLP, 26-38 Cumberland Street, Macclesfield, Cheshire, SK10 1BZ.
If you have any queries about data protection, please contact us on 01625 501500.
PRIVACY NOTICE FOR JOB APPLICANTS
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Practice, 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 for and your rights regarding your data.
A) 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
B) TYPES OF DATA HELD
We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers;
- name and contact details of your next of kin;
- your photograph;
- your gender, marital status, information of any disability you have or other medical information;
- right to work documentation;
- information on your race and religion for equality monitoring purposes;
- information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
- references from former employers;
- details on your education and employment history etc;
- driving licence;
- criminal convictions.
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the recruitment exercise.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
Activity requiring your data
Carrying out checks in relation to your right to work in the UK
Making reasonable adjustments for disabled employees
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion
Our legitimate interests
Making decisions about salary and other benefits
Our legitimate interests
Making decisions about contractual benefits to provide to you
Our legitimate interests
Assessing training needs
Our legitimate interests
Dealing with legal claims made against us
Our legitimate interests
Our legitimate interests
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership
- genetic and biometric data.
We carry out processing activities using special category data:
- for the purposes of equal opportunities monitoring
- to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.
G) CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis as stated above to process this data.
H) WHO WE SHARE YOUR DATA WITH
Employees within our practice who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons: eg. processing payroll, HMRC, VDS, Insurance companies, HSE this list is not exhaustive.
We may also share your data with third parties as part of a Practice sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
I) PROTECTING YOUR 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.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
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 that we will stop processing your data and there will be no consequences of withdrawing consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
K) AUTOMATED DECISION MAKING
Automated decision making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
L) YOUR RIGHTS
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 of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly;
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known 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 known 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.
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact Practice Manager or Managing Partner
M) 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.
N) DATA PROTECTION COMPLIANCE
Our appointed compliance officer in respect of our data protection activities is:
Practice Manager and Managing Partner
Tel- 01625 501500
All policies are subject to change