Privacy Policy
Wellington Wellness Centre Privacy & Data Policy
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
Wellington Wellness Centre, based at 4 Wellington Square, Ayr, KA7 1EN, which hereafter for the purposes of this Privacy Notice will be referred to as WWC, is pleased to provide the following information:
Who we Are?
WWC is a company, providing on-site occupational health services from vision, hearing and pulmonary function tests to on site drug and alcohol testing with full chain of custody procedures. We are supported by external doctors and physicians and sessional nurses in the field of occupational health.
Personal Data
a) For the purposes of providing occupational health services we may require detailed information of your/ your employees medical conditions, work activities, working environments and contact details. We will only collect what is relevant and necessary. When we examine you/your employees, we will make notes which may include details concerning their medication, treatment and other issues affecting their health. This data is always held securely, is not shared with anyone not involved in their treatment, although for data storage purposes it may be handled by pre-vetted staff who have all signed an integrity and confidentiality agreement. To be able to process your/their personal data it is a condition of any treatment that you/your employees provide explicit consent to allow WWC to document and process their personal medical data. Contact details provided such as telephone numbers, email addresses, postal addresses may be used to send you/your employees reminders of future appointments and provide reports or other information concerning your/their treatment. As part of our obligations there may be circumstances related to treatment, on-going care or medical diagnosis that requires the sharing of medical records with other healthcare practitioners e.g. GPs, consultants, surgeons and/or medical insurance companies. Where this is required, we will always inform you/ your employees first unless we are under a legal obligation to comply.
b) For marketing purposes, WWC may also use the contact details provided to respond to you/your employees enquiries, including making telephone contact and emailing information which we believe may be of interest to you/ your employees.
c) In making initial contact you consent to WWC maintaining a marketing dialogue with you/your employees until you/your employees either opt out (which you/your employees can do at any time) or we decide to desist in promoting our services. WWC may occasionally also act on behalf of you/ your employees in the capacity of data processor, when we may promote services provided by individuals/ businesses, who may not be employed by us. WWC do not broker your data and you/your employees can ask to be removed from our marketing database by emailing or phoning our offices using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you/your employees from marketing forms and surveys you/your employees complete, from records of our correspondence and phone calls and details of visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
e) The WWC website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. These cookies help WWCS to identify and track website visitors and their website access preferences. Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the WWC website.
f) WWC will only collect the information needed so that we can provide you/your employees with the services you require. We do not sell or broker your data.
Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Employer/Employee Consent and legitimate interest to respond to enquiries concerning the services provided.
Legitimate interests pursued by WWC
To promote occupational health and provide examinations, tests, or treatments for occupational health.
Consent
Through agreeing to this privacy notice you/your employees are consenting to WWC processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
Disclosure
WWC will keep you/your employees personal information safe and secure, only staff engaged in providing your treatment will have access to you/your employee records, although our administration team will have access to your/ your employees contact details so that they can make appointments and manage your account. WWC will not disclose your/your employees personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
Retention Policy
WWC will process your/your employee’s personal data during the duration of any treatment and will continue to store only the personal data needed for eight years after the contract has expired to meet any legal obligations. After eight years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details.
Data storage
All Data is held in the United Kingdom. WWC does not store personal data outside the EEA.
Your rights as a data subject
At any point whilst WWC are in possession of, or processing your/your employee’s personal data, all data subjects have the following rights:
Right of access – you/your employees have the right to request a copy of the information that we hold about you/ your employees.
Right of rectification – you/your employees have a right to correct data that we hold about you/your employees that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you/your employees to be erased from our records.
Right to restriction of processing – where certain conditions apply you/your employees have a right to restrict the processing.
Right of portability – you/your employees have the right to have the data we hold about you/your employees transferred to another organisation.
Right to object – you/your employees have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you/your employees also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that WWC refuses you/your employees request under rights of access, we will provide you/ your employees with a reason as to why, which you/your employees have the right to legally challenge. At your request WWC can confirm what information it holds about you/your employees and how it is processed.
You can request the following information:
Identity and the contact details of the person or organisation (WWC) that has determined how and why to process you/ your employee’s data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of WWC and information about these interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your/your employees rights to correct, erasure, restrict or object to such processing.
Information about your/your employee’s right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you/your employees are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you/ your employees.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
WWC will accept the following forms of identification (ID) when information on your/your employee’s personal data is requested: a copy of your/your employees driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If WWC is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to hello@wellingtonwellness.co.uk or writing to us at the address further below.
Complaints
In the event that you/your employees wish to make a complaint about how your/your employees’ personal data is being processed by WWC you/ your employees have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Roseanne Savage
Telephone 01292 287703 or email: hello@wellingtonwellness.co.uk
ICO
Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/