Privacy Notice

Stirling Optical (Scotland) Ltd takes your data privacy seriously. We are an independent family practice focussed on delivering a personal and professional eyecare service.   In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for and committed to  complying with Data Protection Laws and the General Data Protection Regulations (GDPR) and any subsequent amendments to the legislation.

In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.

Our Contact Details:

Stirling Optical (Scotland) Ltd

78 Port Street

Striling

FK8 2LP

Email: info@stirling-optical.co.uk

Tel: 01786 447032

If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us at the above address.

Who’s Personal data do we collect and process?

We process information about our customers, employees, suppliers, professional advisors or individuals making an enquiry about our services.

What personal data does Stirling Optical (Scotland) Ltd collect and process?

We collect the following types of data:

  • General contact details such as, Name, Address, email address, Telephone number
  • Personal Details such as Date of Birth or Marital Status
  • General Communications between us and you
  • Consultation notes and information you provide to us
  • Prescription details
  • Doctors and Emergency Contact Details
  • Details of Services provided to you
  • Financial Details – such as credit history or payment or bank details
  • Information obtained through our use of cookies (please see our Cookie Policy)
  • Your marketing preferences
  • For Test and Protect – we collect your name and contact telephone number or if you do not have a telephone number, your address or email address

Please Remember: Where you provide any of this information relating to or on behalf of another individual such as an emergency contact, you must remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.

Special Categories of Personal Data that we collect:

  • Health & Medical Information

How we collect your information

In most cases we collect your data directly from you.  We collect data and process it when you:

  • Complete an online ‘contact us’ form
  • Book an appointment with us online
  • Speak to us on the telephone to discuss or use our services
  • Email or write to us to enquire about or use our services
  • Complete a Pre Consultation form
  • Provide relevant information during a consultation
  • Or if you are an individual who is listed as an emergency contact, your personal data has been provided to us by one of our customers. In such cases, we provide you with access to this privacy notice to ensure that you have our contact details, purpose for processing and categories of personal data which we are processing.
  • View our website via your browsers cookies (see our Cookie Policy)
  • Provide Contact details for Test and Protect Purposes

Social Media – where you access us via software booking services, external links or social media platforms, we have no control over those websites and the personal data they may collect.  Please always remember to review the privacy notices and cookie information on those sites.

We also receive your data indirectly from the following sources:

  • Social Media Sites
  • Marketing Lists
  • Public sources – demographic data, Market Research
  • Credit Agencies

Why we do we collect your information?

Where we collect and process personal data, we identify both the purpose and legal basis for doing so.  There are 6 possible legal bases which are:

Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose

Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject

Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person

Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

Legitimate Interests – Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.

Our purpose and legal basis for the information we collect, and process allows us to:

 

To understand your requirements prior to agreeing to provide a service to you The processing is necessary for the performance of an anticipated Contract
To understand your requirements to ensure that any service meets your needs The processing is necessary for the performance of a Contract with you
To fulfil our agreed services with you The processing is necessary for the performance of our Contract with you
To manage our business operations and comply with any internal policies and procedures It is in our legitimate interests to use some personal information to ensure that we provide and adapt our services
To notify you about changes to our service It is in our Legitimate Interests to use your personal contact  information to keep you informed about any changes that may affect you
To notify a nominated contact in the event of an emergency It is our legal obligation to notify a nominated individual in the event of an emergency
To provide information to medical professionals We will only provide your personal information with medical professionals with your Consent
To remind you when your next test is due or overdue The processing is necessary to ensure the ongoing deliver of our contract of service to you
For Marketing of similar services to past and existing customers or enquirers It is in our legitimate interests to use your personal information for marketing purposes where the services being marketed are similar to those you have purchased or enquired about previously and remain relevant to you.
For electronic Marketing of services to new individuals We rely on Consent for direct electronic marketing to individuals
To comply with our legal obligations, law enforcement, court and regulatory bodies requirements To comply with our Legal Obligations
To identify and prevent fraud It is in our Legitimate Interests to act as a responsible business
To assist with NHS Scotland’s efforts in tackling the coronavirus public health epidemic. It is in our Legitimate Interests to assist with NHS Scotland’s Test and Protect Strategy in relation to the coronavirus epidemic.

 

Where we rely on your consent you have the right to withdraw this consent at any time by contacting us using the contact information on this statement.

Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to improve on our service, security and prevent fraud or illegal activity in favour of the wellbeing of our customers, employees and shareholders.

Direct Marketing

We may send you details of similar services to those you have enquired about or purchased from us previously.   You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.

We will never share or sell your information to any other party for marketing purposes.

Who we share your information with?

From time to time we may share your personal information with the following third parties for the purposes set out above:

  • Accountants, Regulators and Governing bodies
  • Lawyers and other Professional Services
  • Software and Cloud storage providers
  • Fraud detection Agencies
  • Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
  • Medical Professionals (only with your consent)
  • Debt Collection Agencies or Credit Reference Agencies
  • Selected Third Parties in connection with any future sale, transfer or disposal of our business
  • We will share contact details with NHS Scotland’s Test and Protect Services upon request from them where they advise that a positive case has been identified that has a link to our business. They will use this detail to make you aware and give  guidance on any need to self-isolate.  For more information please see their privacy information:

https://www.informationgovernance.scot.nhs.uk/covid-19-privacy-statement/

International data transfers

Although we don’t transfer your information outside of the UK, with today’s modern technology including Cloud Storage and software, some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country.  Where this is the case, we make sure that additional safeguards are in place such as ensuring that those countries have a decision of adequacy or have included standard contract clauses in their terms to support the protection of your data.

Automated decision-making or Profiling

We do not process personal data for automated decision making or profiling

How Long do we keep personal data for?

We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy.  We maintain and review a detailed retention policy which documents how long we will hold different types of data.  The time period will depend on the purpose for which we collected the information and is never on an indefinite basis.  Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).

The following details the criteria used to establish the retention period set out within our policy.

Where it is still necessary for the provision of our Services

This includes the duration of any contract for services we have with you and for a period of 10 years after the end of any contract with a view to meeting our regulatory obligations, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records.  Most of our retention periods are determined on the basis of this general rule.

Where required by Statutory, contractual or other similar obligations

Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data regarding pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

Test and Protect

We will retain your contact details for Test and Protect for a period of 21 days since your visit to our premises.

Your Rights as a data subject 

As a data subject, you have rights in relation to your personal data in most cases (with some limited exceptions).  These are:

The Right to Access – You have the right to request details of personal information held or processed and to copies of this data.  We do not usually charge for this service.

The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.

The Right to Erasure – You have the right to request that we erase your personal information under certain conditions

The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances

The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.

The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.

You also have the Right to Withdraw Consent where you have previously provided this at any time.

To exercise any of these rights, or if you have a complaint please contact us using the contact details at the beginning of this notice.

You also have the right to complain to the Supervisory Authority.  Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:

Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline: 0303 123 1113

Online Enquiries: https://ico.org.uk/global/contact-us/

Contractual Obligations and Consequences

In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, employment and legal obligations) or can also result from contractual provisions.  This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided.  In those circumstances where the data is not provided or where certain rights are exercised, (for erasure or objection) there is a possible consequence that the contract could not be fulfilled or concluded and may be cancelled.

Cookies & similar technologies

When you visit our Website, we use cookies and similar technologies to provide you with a better, faster and safer user experience, to Analyse the performance of the site itself or to show you personalised advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you visit or use the Website.

Some non-necessary cookies such as Analytics and Advertising require your consent before being placed on your browser which is why you will often see ‘pop up’ boxes or banners asking you to accept cookies when you visit a website.

For full information on our use of cookies and how to manage them, please see our Cookie Policy.

Data security

We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.

We store customer records in cloud-based services which have controlled and restricted access.  We operate records management and Information security policies which detail our standards of physical security, cloud storage security monitoring, access control including the ability to restore any data, and password security measures and controls.  We also maintain and use anti-virus and malware software and firewalls.

Changes to our Privacy Notice

Stirling Optical (Scotland) Ltd keep our Privacy Notice under regular review.  This Privacy Notice was last updated on 18th January 2020.