Company Privacy Notice

BACKGROUND:

The Skin to Love Clinic understands 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 customers 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.

1. Information About Us

The Skin to Love Clinic.

Limited company registered in England under company number 08397290.

Registered address: Unit 4, Sandy Court, Ashleigh Way, Plympton, Plymouth PL7 5JX

Address: 13-15 Chequer Street, St. Albans, Hertfordshire, AL1 3YJ.

VAT number: 162291028.

Data Protection Officer: Kerri Lewis.

Email address: info@theskintoloveclinic.co.uk.

Telephone number: 01727837429.

Postal Address: 13-15 Chequer Street, St. Albans, Hertfordshire, AL1 3YJ.

We are a member of the NMC.

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:

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.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

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.

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. However, there are exceptions to this right and in certain circumstances we can refuse to delete the information in question.  In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

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.

h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.

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;
• Business name;
• Job title;
• Profession;
• Financial information;
• Information about your preferences and interests;
• Medical and cosmetic background information.

Your personal data may obtained from the following third party:

Our patients will usually receive healthcare from other organisations, and so in order to provide you with the best treatment possible we may have to collect personal information about you from them.  These may include:

• Medical records from your GP
• Medical records from other clinicians (including their medical secretaries)
• Medical records from your dentist
• Medical records from the NHS or any private healthcare organisation

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, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your account.
• We need to use the data in order to provide healthcare and cosmetic services to you
• The use if necessary in order for us to establish, exercise or defend our legal rights
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Having an appropriate business need to use your information which does not overly prejudice you.
• Supplying you with information by email and post that you have opted-in for (you may unsubscribe or opt-out at any time by unsubscribing or emailing us at info@theskintoloveclinic.co.uk with your updated preferences).

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 or telephone or text message or post with information, news, and offers on our products and 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.

We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.

The following automated decision-making method(s) may be used:

• Automated appointment reminder SMS and/or email, using your name and given contact details at the time of booking, to remind you of your appointment date and time.
• Automated email and/or SMS feedback request sent following your appointment allowing you to give us any feedback you feel necessary should you so wish.

The following automated profiling may take place:

• The type of content you may receive in marketing communication, should you consent to marketing emails and/or SMS, to give you appropriate content.

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):

• Personal data will be kept in accordance with BMA guidelines of 10 years after last treatment or death.

8. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

9. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Phorest Salon Systems, Europe. Diary management system, text and email appointment reminders, opt-in marketing.
• Payment Sense, Europe. Card information to process payments. The respective provider’s privacy policy shall apply to the payment process additionally. In this context, the payment provider shall act on behalf of the Customer and not on behalf of us.
• Go Cardless, Europe. Financial information to process payments and allow direct debits should a customer wish. The respective provider’s privacy policy shall apply to the payment process additionally. In this context, the payment provider shall act on behalf of the Customer and not on behalf of us
• Buyline Ltd. If a customer requests a finance option. The respective provider’s privacy policy shall apply to the payment process additionally. In this context, the payment provider shall act on behalf of the Customer and not on behalf of us.
• MailChimp, headquarters USA. Opt-in email communication.
• The Spire Harpenden, Europe. Should a patient require treatment at their facility. The respective provider’s privacy policy shall apply to the payment process additionally. In this context, the payment provider shall act on behalf of the Customer and not on behalf of us.
• Pharmacies such as, but not limited to, Wigmore Medical, MedFX, Boots the Pharmacy and Health Exchange, within Europe. Should a patient require treatment for which a drug or product needs to be prescribed.
• A doctor, nurse, carer or any other healthcare professional involved in a patient’s treatment.
• Other members of support staff involved in the delivery of care, such as receptionists.
• Anyone patients ask us to communicate with or provide as an emergency contact, for example a carer.
• Other private sector healthcare providers.
• A patient’s GP and dentist (including their medical secretaries).
• Other clinicians (including their medical secretaries).
• Third parties who assist in the administration of a patient’s healthcare, such as insurance companies and medical secretaries.
• Government bodies, including the Ministry of Defence, the Home Office and HMRC.
• Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland.
• The police and other third parties where reasonably necessary for the prevention or detection of crime.
• Our insurers.
• Invoicing companies and debt collection agencies.
• Other credit referencing agencies.
• Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers.
• Selected third parties in connection with any sale, transfer or disposal of our business.

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.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are 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 28 days and, in any case, not more than 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 Kerri Lewis):

Email address: info@theskintoloveclinic.co.uk

Telephone number: 01727 837429

Postal Address: 13-15 Chequer Street, St. Albans, Hertfordshire, AL1 3YJ.

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 in the clinic and on our website.