Statement on the use and disclosure of personal data
The Lamond Veterinary Clinic Limited (“The Practice”) is committed to protecting and respecting its clients’ privacy. This policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from clients and others, or that clients and others provide to us, will be processed by us.
In accordance with Regulation (EU) 2016/679 of 27 April 2016 (“GDPR“), we recognise personal data as any information related to an identified or identifiable individual. Depending on the context of interactions with the Practice, we collect and use different types of personal data from clients, prospective clients, employees, locums, students and others on work placements, candidates, contractors and suppliers.
The legal basis on which we justify the collection, storage and processing of personal information is “Legitimate Interest”.
In order to ensure that the Practice complies with data protection regulations intended to protect personal information (The General Data Protection Regulations), we need to confirm that we have consent to hold and to make use of certain information which clients and others supply or have supplied to us.
Collection, storage and use of clients’ personal data
When a pet is registered in the Practice we have to gather some essential information including the owner’s title, first name, surname, address and a contact telephone number. The provision of this information is a precondition of service under all but the most exceptional circumstances. As part of the registration process we will also ask clients to supply an email address and mobile phone number(s). Information gathered in this way is stored on our secure database, integral to the practice management software application in use in the Practice.
We may also ask for these details for other reasons and these details are collected either in person, by telephone or online, to help us:
To maintain detailed records of veterinary services rendered and to administer client accounts effectively, including details of amounts paid and / or owed
To register new clients or to update client details if they change
To register pets on our Practice Health Plan
To make appointments
To process the fees due for any treatment
To contact clients about their pet or about their account with the Practice
To deliver a safe and secure service by helping to prevent and detect fraud. (We may need to disclose information to assist legal or debt recovery processes)
To speed up form filling processes if clients have registered online (where applicable)
To respond to any issues or queries
To notify clients about changes or improvements to our service, or about offers which we believe may be of interest to them
To contact clients in the event that an unpaid balance remains on their account, requesting prompt settlement or a commitment to settle the account within a mutually agreed time period. In the event that the balance remains unpaid, we reserve the right to engage the services of a debt collection agency, and will provide details to that third party to facilitate their contact with the client in question as part of the debt collection process.
We also work with and securely exchange information with pet insurance providers, specialist referral service providers, external laboratories and other providers of services who help to maintain our secure database, maintain our website, administer our Practice Health Plan and support our social media and promotional activity. Details of these third parties and a description of information shared are given at the end of this document.
For as long as clients remain active clients of the Practice, or unless asked to desist, the Practice will retain a client record containing any personal details clients provide to us, details of clients’ animal or animals registered as patients of the Practice, and details of veterinary consultations, other treatments, advice given by vets or vet nurses, prescriptions and non-prescription items purchased from the Practice.
We will ask for clients’ consent to send, by text message, e-mail or post, reminders of treatments due for their animal or animals such as vaccination boosters, wormers and flea treatments.
We will ask for client’s consent to send, by text message, email or post, details of changes or improvements to our service, offers, products and services which may be of interest to clients. The mechanism by which these communications are managed may include the sharing of client contact details with one or more of the Practice’s technical services providers. Such sharing arrangements will be subject to secure agreements that ensure that data shared will not be retained, sold, shared with any other party, or used for any purpose other than those described here.
We may contact clients by telephone to discuss treatment options or outcomes, to discuss the results of blood tests or other analyses or to obtain further details in respect of complaints or enquiries raised by clients.
We may use for the purpose of promotional, marketing and publicity purposes in any media worldwide any comments or feedback (excluding personal data) which clients post publicly or provide to the Practice, without notice and without any fee being paid.
We may disclose client personal information to third parties:
Under the circumstances described above.
If the Practice or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share a client’s personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions or agreements or contracts between us or to protect the rights, property, or safety of the Practice, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and our internal investigations including customer complaints and claims.
Clients have the following rights:
The right to be informed
The right of access (see note below on how to obtain a copy of the personal information we hold)
The right to rectification
The right to erase
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling
Clients have the right to ask us not to capture, store or use any of their personal data. In exercising this right, it must be understood that the recording and storage of clients’ name, address and contact telephone number, given at the point of registering a pet at the Practice, or when veterinary services provided by the Practice are accessed, is a precondition of service, and that clients’ name, address and contact telephone number will be requested, recorded and stored should they subsequently register a pet or access veterinary services.
Clients have the right to ask us not to process their personal data for marketing purposes. We will inform clients (before collecting their data) if we intend to use their data for such purposes, and we will seek client consent in advance. Clients can exercise their right to prevent such processing by indicating on the forms we use to collect their data, for example, the new client registration form or our online new client registration form, or by confirming their wishes in respect of processing personal data when in contact with a member of our staff. Clients can also exercise their right not to receive informational or promotional information at any time by contacting the Practice in person, at email@example.com or on 01506 461462.
Our website may, from time to time, contain links to and from the websites of providers of services to the Practice and other organisations. If a client follows a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Clients are advised to check these policies before they submit any personal data to these websites.
For answers to questions or concerns about how we collect, store or use data, please contact:
The Practice Manager
The Lamond Veterinary Clinic Limited
In the event that we are unable to resolve a question, complaint or concern about our collection, storage and use of personal data, further information and support can be obtained from the Information Commissioner’s Office – https://ico.org.uk/your-data-matters/raising-concerns/
Visitors to our website
When someone visits www.lamondvet.co.uk (“the Website”) we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not ask Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will make our intentions clear to users of the site and we will explain what we intend to do with it.
How we protect client information
The security of clients’ personal information is important to us and we will use our best efforts to protect this information by:
- Using appropriate technical and organisational measures to safeguard personal information. Our technical service providers use encryption technology where appropriate to enhance privacy and help prevent information security breaches. They and we use industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.
- Keeping client information up-to-date and accurate (we are required by law to do this). Please note that, to do this, we need clients to tell us if any of their details such as name or address change. From time to time we will also ask clients to confirm that the details we hold are still accurate.
- Having in place strict security procedures for the storage and disclosure of client information to prevent unauthorised access.
In the event that we have in place an agreement to share information with a provider of services (for example IT support, practice management software or database support) and that provider may process or store such information outside of the EEA, we will ensure that contractual agreements are in place which place the service provider under a clear obligation to treat such information securely and in accordance with this policy and the applicable data protection legislation. Such contractual agreements will only allow transfer of personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. In addition we will insist that, when required, service providers use specific contracts approved by the European Commission (EU Standard Contractual Model Clauses) which give personal data the same protection it has in Europe; or where service providers are based in the USA, we may permit the transfer of data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the USA.
All third parties who provide services to the Website are required to sign a contract requiring them to have appropriate technical, administrative and physical procedures in place to ensure that client information is protected against loss or misuse.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect clients’ personal data, we cannot guarantee the security of data transmitted to and/or through the website and so any transmission is at clients’ own risk. Once we have received clients’ information, we will use strict procedures and security measures to try to prevent unauthorised access.
Protecting clients’ security
To ensure that credit card and debit card transactions are secure we will not make copies of or retain any client card or bank account details and we will process card payments using only secure payment technologies. We will maintain compliance with the requirements of the PCIDSS (Payment Card Industry Data Security Standard). All information provided by clients will be treated securely and strictly in accordance with the requirements of the PCIDSS and GDPR.
Clients have a right to access the personal data about them that is held by us. Clients can obtain a copy of the personal information we hold about them by writing to us at the following address (please note that such requests must be made in writing or by e-mail, the Practice may take up to one month to provide the information and requests which are manifestly unfounded or excessive may be refused or be subject to a financial charge):
The Practice Manager
The Lamond Veterinary Clinic Limited
Collection, storage and use of employee, locum, student, intern or persons on work placement, contractors and suppliers personal data
The Practice receives and uses various types of personal data in order to conduct our day to day business activities. We apply the data minimisation principle in the collection and use of personal data ensuring that we only collect information that is necessary and by fair means, and providing notice and requiring consent when necessary.
Some of this data is collected directly from employees and others in the following situations when:
Application is made for a position with the Practice
The Practice negotiates and/or establishes a contractual relationship (e.g. on employment or commercial terms)
The Practice is provided with any type of service or with goods
When our website is visited, e-mails are sent or received, e-commerce services are accessed, or visits to and/or contributions to social media pages are made
The purposes for which we collect and use personal data other than in situations where individuals are clients of the Practice may vary depending on the context, such as if the individual is an employee, a web site user, a student, an intern, a person on a work placement, a contractor or a supplier of goods and/or services. The Practice will always collect and use personal data according to the purpose limitation principle.
Employees and candidates: we use employee and candidate personal data to consider applicants for employment and to administer applications. When an individual has an employment or commercial relationship with the Practice, we use personal data to administer and develop our contractual relationship, to conduct performance evaluations and to comply with legal obligations, including tax and labour regulations.
Contractors and suppliers: when a contractor or supplier has a business or professional relationship with the Practice and provides personal information such as home address, telephone number, bank account details or e-mail address we may store and use such personal information to administer our business relationship and to comply with tax and other regulations.
If clients have any questions or concerns about the way in which the Practice applies its data protection policy, these can be raised by contacting us on 01506 461462 or at firstname.lastname@example.org
Third party technical services providers with whom personal data and other data may be shared (arrangements to share data with third party technical services providers are always subject to a confidentiality agreement):
|Organisation||Service provided||Nature of information shared|
|Henry Schein Veterinary Solutions||Practice management software (PMS) provider||Full access to records held in the PMS application|
|Henry Schein Veterinary Solutions||Patient treatment reminders system||Client e-mail, mobile number, address, pet name and treatment history|
|Henry Schein Veterinary Solutions||Informational and promotional communications||Client e-mail, mobile number, address, pet name and some elements of treatment history|
|Vet Help Direct||Management of social media channels, informational and promotional communications||Client e-mail|
|Vet Help Direct||Website design, hosting and maintenance||Contact form details completed online|
|Vet Dynamics||Analysis and interpretation of data harvested from PMS||Services, products sold, client ID reference|
|Simply Health||Administration of Practice Pet Health Plan||Initial application form details|
|Pet insurance services providers||Pet insurance||Client name, address|
|Veterinary referral specialist centres including East Neuk Veterinary Clinic Orthopaedic Referral Service, Royal (Dick) School of Veterinary Studies||Specialist veterinary referral services||Client name, address, animal clinical history as maintained by the Practice|
|Veterinary clinical services providers||Various analytical, clinical and other veterinary services||Client surname, animal name, animal ID (numeric), animal clinical history|
|Other veterinary practices and providers of veterinary services||Veterinary services including out of hours emergency services, vet practices from which or to which a client is transferring||Animal clinical history as maintained by the Practice|