GVG Brooks Equine Veterinary Practice is committed to protecting the privacy and security of your personal information.
GVG Brooks Equine is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This policy applies to our clients, our suppliers, our website users and other third party processors. This policy does not form part of any contract of employment or other contract to provide services. We may update this policy at any time.
Data protection principles
|We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
How is your personal information collected?
We collect personal information about our clients, website users and suppliers, by completing registration forms and supplier enquiry forms, via telephone or face-to-face enquiries or through our website. We may sometimes collect additional information, from third parties including clients, suppliers, veterinary surgeons and other referees or in order to perform background checks, throughout the registration process and when providing veterinary services.
How we use your personal data
|We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. 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. Ensuring warranties remain valid etc.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest [or for official purposes].
GVG Brooks Equine uses the information collected from you to perform the contract we have entered into with you to provide you with the benefits of being a GVG Brooks Equine client. GVG Brooks Equine also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, GVG Brooks Equine will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.
Common methods of using your information include:
We provide a break down of these common methods on our registration form, and ask clients to specifically opt-in to each. We contacted our existing clients in May 2018 seeking their consent.
You can withdraw consent at any time by contacting us by email at email@example.com, or in writing to the address listed in the final section of this document.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing a benefit or service) [or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).]
Change of purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. GVG Brooks Equine will use such information to identify its visitors. GVG Brooks Equine may also collect statistics about the behavior of visitors to its website.
Any information GVG Brooks Equine holds about you and your business encompasses all the details we hold about you and any transactions including any third-party information we have obtained about you from public sources and our own suppliers, such as credit processing agencies or references, provided by you in the course of your application. GVG Brooks Equine will only collect the information needed so that it can provide you with veterinary and prescription services.
Legal basis for processing any personal data
The legal basis for processing your personal data is to meet GVG Brooks Equine’s contractual obligations to its clients to provide veterinary services:
We do not need your consent to process your personal data in order to perform our contractual obligations to you. In limited circumstances, we may approach you for your written consent to allow us to process certain data or particularly sensitive data. If we do so, we will provide you with full details of the information that we would like it and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
|We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. For example, when exporting horses.
If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: IT services, payment processing providers, market research, product fulfilment and data analytics. The activities for which we use third-party service providers may change from time to time in order for us to meet the needs of the business.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
GVG Brooks Equine will process personal data during the duration of any contract and will continue to store only the personal data needed for up to six years after the contract has expired to meet any legal obligations. These obligations include our statutory obligation under the Royal College of Veterinary Surgeons (RCVS) code of practice. After six years, any personal data not needed, will be deleted.
Data is held in the United Kingdom, using multiple secure servers. GVG Brooks Equine does not store personal data outside the EEA.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us by emailing firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Right to complaint
Should you wish to raise a complaint regarding how we process your information, we ask you initially contact us in writing. This can be via email, firstname.lastname@example.org at the postal address in the final section of this document.
Our complaint policy is available at request from our office, or is available on our website at www.gvgbrooksequine.co.uk.
Should you feel you have been treated unfairly, it may be appropriate to raise a concern to the Information Commissioner’s Office.
The details for each of these contacts are:
Data Protection Regulator: Dr Stephen Brooks BVSc (Hons) MRCVS
GVG Brooks Equine, B1-2 The Courtyard, Dovers Farm, Lonesome Lane, Reigate, RH2 7QT
Telephone 01737 246109 or email email@example.com
Information Commissioner’s Office
Telephone 0303 123 1113 or complete a form at: https://ico.org.uk/concerns/handling/