Practice Privacy Notice

This privacy notice provides you with details of how we collect and process your personal data.

Kings Bounty Equine Practice Ltd, is the Data Controller as is responsible for your personal data (referred to as “we” “us” or “our” in this privacy notice).

Our email address is: admin@kingsbountyequine.co.uk

Our postal address is: Kings Bounty, Church Street, Binsted, Alton, Hampshire. GU34 4NX

1. What is GDPR?

GDPR is new legislation that replaces the Data Protection Act 1998 and includes a number of important changes and enhancements. It is designed to protect the individual’s privacy, give the individual more control on how their data is used and reduce the risk of security breaches.

2. What Personal Data does Kings Bounty Equine Practice process?

Personal data means any information capable of identifying an individual. It does not include anonymised data.

  • Identity Data may include your full name, maiden name, last name, title, image
  • Contact Data may include your billing address, delivery address, email address and telephone numbers.
  • Financial Data may include your bank account and payment card details
  • Transaction Data may include details about payments between us and other details of purchases made by you.
  • Technical Data may include, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our website.
  • Profile Data may include purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We do not collect any sensitive data about you other than relevant information about your health e.g. pregnancy that may be important in an attempt to safeguard your health should you be at risk of exposure to certain drugs, chemicals and ionizing radiation. We will ask for your explicit consent before we process such sensitive data and will request your signature for this consent. (Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, biometric data, criminal convictions and offences).

You must be over 18 years old for us to process your personal data. Your horse(s) details and its medical records are stored under that account (but are not governed by the GDPR).

3. How do we collect your personal data?

We collect data about you through a variety of different methods including:

  • Direct interactions:
    You may provide data by filling in forms on paper, email or via our website or by communicating with us by post, phone, email or otherwise, including when you:
    – create an account with the practice;
    – order our products or services;
    – subscribe to our service or publications;
    – request resources or marketing be sent to you;
    – enter a competition, prize draw, promotion or survey;
    – give us feedback; or
    – Send us your photograph for marketing purposes
  • Third parties:
    We may receive personal data about you from various third parties and public sources as set out below:-
    – Facebook (based outside the EU);   When you visit our Facebook page, you are providing Facebook with personal details.  We do not use this personal data other than for merely identifying visitors who like or comment on our page. Facebook also provide generic background analytics for business pages that identifies demographics of the visiting population but without detail of the individuals ( see Aggregated Data below). Whilst we monitor and edit material on our page, we cannot take responsibility for the posts of other visitors to our page that may compromise your right to privacy. 

    – Other automated technologies or interactions: We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we could review Usage Data to work out the percentage of website users using a specific feature of our site. If we were to link the Aggregated Data with your personal data so that you can be identified from it, then it would be treated as personal data. We may collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our Cookie Policy  for further details.

    – Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as debt collectors, banks, card processing companies, couriers  based inside the EU.

    – CCTV is provided, for security reasons only, by the owner of the estate (R S Hill & Sons) upon which the office is based. Should you visit the practice, your image/vehicle details constitute personal data and as such are governed by the GDPR. We do not have access to this data ourselves but we ensure that the third party who has access to this data is GDPR compliant and only uses this data for security purposes.

4. How do we use your data?

We only use your personal data when legally permitted. The most common uses of your personal data are:

  • When we need to perform the contract between us i.e. for the purpose of providing you with a veterinary service, both emergency and elective. This would include for example, the use of your personal data to contact you regarding veterinary appointments; to respond to a request for veterinary advice; the production/sending of invoices; to collect and process payments (card/cheque/bank transfers); to complete correspondence surrounding your horse’s insurance claim; to process laboratory samples; to complete paperwork, at your request, for an individual prescription for submission to an external pharmacy of your choice; to refer your horse to another veterinary practice;  to maintain business accounts and to notify you of any changes to our terms and conditions or privacy policy.
  • 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-
    e.g. to administer and protect the running of our business e.g. provision of administration, maintenance and testing of IT services and network security, to prevent fraud and in the context of business reorganisation; to forward your personal data to a certified debt collecting agency (where appropriate) for the sole purpose of retrieving a debt to the practice , to forward your personal data to our professional indemnity insurers should a claim arise; to ask you to take a survey in order to study how we can improve our services to clients; to use data analytics to improve our website/products & services/marketing/customer relationships and experiences.

    We send limited data (non identifying “pseudonymised” information only) to a GDPR compliant third party (appointed by Boehringer Ingleheim) for the sole purpose of providing you with a courtesy text vaccination reminder service. They do not use this data for marketing purposes. Our legitimate basis for doing so is based on ongoing client expectation of this service and the negative impact that it may have on you as an owner/loanee and your horse’s health should you not receive a vaccination reminder –  you may need to re start your vaccination course at further expense if your horse’s vaccination lapses/ your horse may be vulnerable to flu +/- tetanus /be unable to comply with the regulatory bodies overseeing competition vaccination rules etc. (If we have not given your horse its last vaccination during the last 12 months,  your vaccination reminders will automatically stop) Please note, as per our T&Cs, the responsibility of keeping vaccinations up to date remains with the owner/loanee of the horse.
    You can opt out by simply responding to the “Opt Out” option in the text or by contacting the practice by email/post/phone/website “contact us” page. We will also, when you first complete or update your client registration and marketing preferences form, give you the opportunity to opt out of this courtesy service.
  • Where we need to comply with legal or regulatory obligations e.g. HMRC legislation / the authorities on the grounds of animal welfare.
  • Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications. With your consent, we may use your personal data to send you practice specific information such as newsletters/ invites to lecture evenings / equine healthcare information including disease outbreak notification/practice offers/practice services that we feel may be of interest to you. This may be by telephone/ email/ text/ post depending on your preferences. Our use will be fair and balanced and never unduly impact on your rights as an individual – we will only contact you with specific content appropriate to the nature of our business.

    You may opt out of this should you so wish by contacting the practice by email/ post/via our website “contact us” page/phone/text.

    With your consent/at your submission we may use photographs for marketing purposes on e.g. Facebook or our website. We are unable to use photographs containing additional individuals without their consent. We cannot use images of children without parental/guardian’s consent.
    You may ask for these photographs to be removed at any time by contacting the practice by email/ post/via our website “contact us” page/phone.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at admin@kingsbountyequine.co.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. Where is my Personal Data Stored/Processed by the practice?

  • Practice Management Software (PMS) – a secure cloud based software system on which we keep our veterinary records, client account details and appointment diaries.
  • Email – any correspondence containing your personal details e.g. registration forms/ consent forms/insurance forms/laboratory forms/ dictations of our work/invoices/spreadsheets.
  • Paper copies of documents – held securely at the practice office.
  • Cloud – for the transfer and storage of files such as dictations/ reports /system back ups
  • Accountancy Software
  • Devices –  office based computers; business mobile devices ; business Tablets; Pagers; External hard drive back ups ( on and off site).
  • Diaries (paper and digital)
  • Paging service – they forward the personal data provided by you in order to page us with your emergency contact details. They keep copies of this data for their own records.
  • Via the post
  • Via Facebook / Website – posted photographs/ information with your consent
  • Payment card details are not stored at the practice but processed, via a third party using our payment terminal, and then destroyed.

6. Who has access to my Personal Data?

  • Employees of the practice – office staff, vets,
  • Remote administrators  – audio typists, virtual assistants
  • Professional advisors – Accountants/ bookkeepers/lawyers/bankers/auditors and insurers who provide consultancy, banking ,legal, insurance and accounting services.
  • Service providers who provide IT and system administration services
  • HMRC, regulators and other authorities based in the UK and other relevant jurisdictions who require reporting of processing activities in certain circumstances
  • Veterinary Students in the course of a visit only – limited personal data (such as your name/ yard address)
  • Drivers / part time help in the course of a visit
  • Suppliers – insurance company & external laboratory personnel/ paging company/other veterinary practices /external pharmacies. The transfer of data to these suppliers will only occur when requested by you.
  • Estate personnel  – for the purpose of security CCTV only
  • Debt Collectors – only in the course of a specific debt collection
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets

7. How are we protecting your Personal Data?

  • 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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
  • We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They only have access to your personal details to the extent necessary for them to perform their services to us.  We will get your express opt in consent before we share your personal data with any third party for marketing purposes.
  • INTERNATIONAL TRANSFERS
    Many of our third parties service providers e.g. Google/ Microsoft are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or-

    Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or-

    Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

    If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.Please email us at admin@kingsbountyequine.co.uk you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. How long do we store your Personal Data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 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.

In order to comply with both UK law and the advise of our professional indemnity insurers, we hold your personal data, to which your horse’s medical records are attached, until the end of our financial year (August 31st) not less that 7 years from the last date that you were invoiced by the practice.

In some circumstances you can ask us to delete your data but this can only be done once we have fulfilled our legal obligations. Should there be legitimate reason that we have to retain your details for longer e.g. a matter surrounding the medical records of your horse, we will discuss this with you at that time.

In some circumstances we may 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.

9. What are your legal rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data – see above
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at admin@kingsbountyequine.co.uk

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us.

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. What happens if your personal data is breached?

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.

11. What should you do if you wish to complain about how we have handled your personal data?

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

https://ico.org.uk.

12. Third Party Links

Our website and social media page may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website/social media page, we encourage you to read the privacy notice of every website you visit.

13. Cookies

Please be aware that when you search for our website/ use our social media page, other platforms such as Google Analytics /Facebook may set cookies on your device to analyse your entire internet usage, not just whilst you visit our sites. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

This privacy policy notice may be updated from time to time. It will be available to all clients at the point of registration and at any time on our website.

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