Privacy
AT FARNHAM HEARING WE CARE ABOUT YOUR PRIVACY
As part of the relationship you have with Farnham Hearing, we will collect personal information about you and your hearing. We want to let you know that we respect the information you provide us with and that it’s important to you to know how it is collected, used and protected.
As part of the new EU data protection laws (GDPR) we’ve provided this Privacy Policy that you can refer to for any queries you may have about your personal information.
We may update this Policy from time to time to keep in line with any changes to legislation or to our use of your data.
If you have any questions about our Privacy Policy and practices, please contact info@farnhamhearing.co.uk or in writing to Farnham Hearing, Blencathra, Seale Lane, Farnham, GU10 1LE
1. Who are we?
We are Farnham Hearing, an independent hearing health practice. We diagnose and treat hearing impairment including tinnitus and we fit hearing aid (where appropriate) tailored to an individual’s needs.
2. Why do we process the data and under what legal basis will we process your information?
As part of the new EU laws under GDPR, the grounds that we will rely upon in order to process your information are as follows:
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Legal Obligations / Contract – we may process your information in relation to our obligations to fulfil a contract with you or under a legal obligation arising from the sale of products including those related to after-sales support services and where we are obliged to fulfil obligations or to respond to instructions issued by regulatory or legal bodies.
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Consent – When you call us or contact us via our website, you will be asked to provide consent for us to collect and process your personal and sensitive data, use your data to send marketing related information that we feel is relevant to you and your hearing and use your data for the purpose of profiling (see our profiling section for more information).
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Legitimate Interest – if you are an existing customer, have had a hearing test with us or have enquired about our services in the last 5 years and have not previously given us consent for the processing of your data, we will keep and use your data for the purposes of our legitimate interest, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your information protected. Our legitimate interests include processing orders for any of our services or products, optimising our website and customer experience, informing you about relevant products, offers and promotions via mail, email and phone and ensuring that our operations are conducted in an appropriate and efficient manner.
3. How do we collect information from you?
There are several ways of collecting the information:
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Website – You may submit your personal details through one of our online forms when requesting further information or booking an appointment to see us.
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Third party medical referral- As part of a medical treatment pathway, you may have been referred to us by Ear-, Nose- and Throat Consultants or General Practitioners who would have contacted us with your prior consent
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At the hospital – If you visit one of the hospital where we consult, the hospital reception staff will ask you to provide personal details in order to book an appointment with you
4. What type of information do we collect from you?
The type of information we collect from you can be grouped as the following:
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Personal Data – We will collect information such as your name, date of birth, address, email address and registered GP practice.
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Sensitive Data – As part of our service, we will undertake a battery of test to investigate your health of your hearing. We will then keep a record of these results so we are able to understand your needs as best as possible as well as refer back to them in subsequent appointments and tests.
5. How is your information used?
We may use your information to:
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Assist in the appropriate treatment/management of your hearing as part of a medical pathway i.e. when referred from third parties such as medical consultants and doctors
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Process orders for any of our services/products;
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Send you confirmation and reminders about your appointment dates and times;
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Seek your views and/or comments on the services we provide;
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Inform you of any changes to our services;
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Send you communications which you have signed up for and that may be of interest via mail, email, phone or SMS. When we have seen you for an appointment, you will be given the opportunity to opt in to our marketing communications and choose the types of marketing channels that you would like us to use for contacting you. If at this point you don’t give us permission, then we will not send any marketing communication to you. If you request marketing information through our digital channels, then you will be required to opt in and choose your marketing channel preferences.
6. Who has access to your information?
Your data is only dealt with by Farnham Hearing employees or contracted staff who are adequately trained and instructed to deal with safe and secure processing of customer information and are also bound by a duty of confidentiality.
We will never pass any of your details to a third party other than for medical treatment and always with your consent. We will never pass your details to any third party for marketing purposes.
7. The rights you have relating to your information
You have the right to:
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Be informed of how and why we use your data who we share your data with if applicable and under what legal basis we process your data. These details are all contained within this Privacy Policy
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Access your personal information and to confirm the nature of the information and how it is used. There are circumstances, under GDPR laws, where we can refuse your request or certain elements of your request. If this is the case, we will inform you of our reasons for doing so.
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Change your personal information if it is inaccurate. You can let us know by sending your request to the email address or postal address set out below.
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Have your personal and/or sensitive data deleted (e.g. if the information is no longer necessary for the purposes for which it was collected or processed)
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Restrict processing of your data if required. If you request this, we still store your personal data but no further processing of it would be carried out.
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Object to our processing of your Information by contacting us at the address or email address set out below. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests.
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The right to withdraw the consent for the processing of your Information for direct marketing purposes at any time. For email you will be given the opportunity to unsubscribe or opt out in the content of the messaging.
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Receive any information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organisation. This right exists in respect of information that:
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you have provided to us previously; and
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is processed by us using automated means please note that we would never process your data on a fully automated basis
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to Information of others without their consent.
Please be aware that if you do object to the processing of all or selected parts of your data by Farnham Hearing, we may not be able to provide you with adequate hearing care services or communicate with you about relevant products, services, offers and/or promotions that we feel are relevant to you.
To exercise any of your rights mentioned above, you will need to contact us at info@farnhamhearing.co.uk or in writing to Farnham Hearing, Blencathra, Seale Lane, Farnham, GU10 1LE
8. How your information will be protected
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When you give us personal information, we take steps to ensure that it’s treated in a secure way.
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We will always ensure that your information is processed meeting the following requirements,
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Processed lawfully, fairly and in a transparent manner
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Collected for specific, explicit and legitimate purpose
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Adequate, relevant and limited to the purpose it is collected
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Accurate and up to date
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Kept in a form which permits identification of the individual for no longer than is necessary
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Processed in a manner that ensures appropriate security against unlawful processing, accidental loss, destruction or damage
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Whilst we will try to ensure that your information is protected, we cannot guarantee the security of the information you send to us, and you do so at your own risk. Once it has reached us, we have stringent processes in place to ensure that your personal information on our systems meets industry security standards.
9. Profiling
We may use the data we collect from you and your hearing aid to further understand how we can support you and improve our clients’ hearing. The type of data we use profiling for are as follows:
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Data regarding your use of the hearing aid (hours per day) will provide us with an effective tool to monitor your progress and to give you better suited advice, thus improving your hearing experience.
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If we find the hearing aid is regularly being used in an environment with lots of background noise, we can use this data to adjust the filter functions on the hearing aid, giving you support in listening to speech in noisy environments.
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We will use data such as your historic sales, marketing preferences and behaviour so we can send you marketing information, offers and promotions which is most relevant to you and your hearing needs.
10. Use of ‘Cookies’
‘Cookies’ are small files which are sent by a website to your computer and stored on your hard drive to allow the website to recognise when you visit. They allow the website to remember information such as which country you are visiting the website in but do not identify you as an individual.
You are able to switch off cookies from the Farnham Hearing’s website by clicking on “use of cookies” on our home page. Turning cookies off may affect the experience you receive on our website.
11. How is your information stored and for how long?
We will only retain your information for as long as is necessary for the purpose(s) for which we have collected it. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.
12. Complaints Procedure
Please note that any concerns should be raised in the first instance to info@farnhamhearing.co.uk or in writing to Farnham Hearing, Blencathra, Seale Lane, Farnham, GU10 1LE. Please also be aware that you have the right to raise any concerns regarding data protection with the Information Commissioners Office who are our regulatory body. For the most up to date contact details please refer to their website.
13. Date of Privacy Policy
This policy was last updated in May 2018. We review the policy regularly to keep in line with UK and EU legislation.