Love your feet

         Daly Podiatry

Foot Health Specialist


Daly Podiatry Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data if you are a client or patient of Daly Podiatry Limited.

We keep our privacy policy under regular review. This version was last updated on 22nd August 2018. You can find our latest policy on our website at www.dalpodiatry.co.uk/privacy

  1. Important information

Daly Podiatry Limited is the controller and responsible for your personal data (collectively referred to as “Daly Podiatry Limited”, "we", "us", or "our", in this privacy policy).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

Full name of legal entity: Daly Podiatry Limited

Email address: info@dalypodiatry.co.uk

Postal address: Daly Podiatry, 73 Orchard Street, Weston-super-Mare, North Somerset, BS23 1RL.

Telephone number: 01934 416640

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data and Contact Data includes [first name, maiden name, last name, title, date of birth and gender, billing address, delivery address, email address and telephone numbers].
  • Financial Data includes [bank account and payment card details].
  • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
  • Special Categories of Personal Data about you (this includes information about your health, and genetic and biometric data); data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status;
  • Can you withhold your data?

You can withhold your data from us if you wish, but where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to suspend or terminate our engagement with you, but if this is the case, we will notify you at the time.

  1. How is your personal data collected?

We may collect your data from different sources:

  • Direct interactions. You may give us your [Identity, Contact and Health Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data by using cookies and other similar technologies.
  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

[[PASTING TABLES IS NOT SUPPORTED]] More details can be found upon request.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and events may be relevant to you.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us in respect of our business and our services if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.

Third-party marketing

We do not share your contact details with any third party for the purpose of that third party sending marketing.

Opting out

You can ask to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us using the details above 0 at any time.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us 0.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may share your personal data with parties listed below for the purposes set out in the table above.

  • Medical professionals; with your consent we will share information with medical professionals such as your GP or consultant to allow continuity of care.
  • Service providers; we engage certain trusted third parties, to perform functions and provide services to our business, such as external reception services. We will share your personal information with these third parties, but only to the extent necessary to perform these services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

We may transfer your personal data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for as described in our privacy policy. However, we may also be required to retain this information in order to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our agreements.

The retention of podiatry and/or medical records is normally a minimum of 8 years, after the last appointment. For customers who are not patients but may have bought products from our business we will keep any data you may have provided for a minimum of 6 years in line with tax legislation.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out below, please contact our Data Privacy Manager.

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.

Complaint to the ICO

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

What we may need from you

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.

Time limit to respond

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

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances:

Request the transfer of your personal data to you or to a third party.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.