Privacy NoticeWe understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us
Hawthorn Hearing Ltd.
Registered in England under company number 15189966.
Registered address: 6 Oldbury Cottages, Oldbury Lane, Ightham, Sevenoaks, TN15 9DE
Data Controller: Grant Booth
Email address: info@hawthornhearing.co.uk
Telephone number: +44 7873145645
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
4. a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
4. b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
4. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
4. d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
4. e) The right to restrict (i.e. prevent) the processing of your personal data.
4. f) The right to object to us using your personal data for a particular purpose or purposes.
4. g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
4. h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
Name;
Date of birth;
Gender;
Address;
Email address;
Telephone number;
Job title;
Profession;
Payment information;
Related Medical Conditions/ history you inform us of;
Hearing Instrument data and history;
Information about your preferences and interests;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, it is in our legitimate business interests to use it or to carry out duties relating to healthcare. Your personal data will be used for the following purposes:
Supplying products and services to you. Your personal details are required in order for us to enter into a contract with you.
Providing relevant data to medical professionals
Providing and managing our aftercare services to you
Personalising and tailoring our products and services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing info@hawthornhearing.co.uk.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
While we are working with you – for the whole period in order to fulfil our legal, statutory obligations and for our legitimate business interests.
After our relationship has ended – Your name and contact details along with a history of our provision of services/ products will no longer be processed. The records will be made inactive:
Adult Data is stored for 8 years since the last appointment will then be made ‘inactive’ within our system.
Child data is stored until the data subject has reached 25th or 26th birthday subject to the data subject being 17 years or under at time of appointment at this stage the data will be made ‘inactive’.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer personal data within the European Union or under the equivalent regulatory body in North America. This means that it will be fully protected under the GDPR or equivalent.
9. Do You Share My Personal Data?
We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, the procssing and delivery and necessary repair of hearing instrumentation. In some cases, those third parties may require access to some of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EU, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of info@hawthornhearing.co.uk or in writing using the details in Part 1.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website at www.hawthornhearing.co.uk