Privacy Statement

GVG Brooks Equine Veterinary Practice is committed to protecting the privacy and security of your personal information.

This Privacy Policy describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to our clients, our suppliers, our website users and other third party processors. If you have any queries regarding your personal information or how we process our data, please contact us at admin@gvgbrooksequine.co.uk.

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.

It is important that you read this policy, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 

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:

  • Holding your name, address, telephone number and email address on our secure server
  • Holding your horse’s clinical history on our secure server
  • We may contact you by text message (SMS) or email in order to optimise your horse’s care – this may include vaccination, dental, worming and check-up reminders.
  • We may contact you by text message (SMS) or email in order to keep you up to date with latest practice news and offers
  • If you have downloaded the Horse Dialog app, you have consented to us contacting you via the app, sending push notifications in connection with your horse’s care – to provide reminders on treatments, rehabilitation programmes and to notify you of practice news and offers.
  • We may pass your contact details and your horse’s clinical history to a referral veterinary hospital if required to do so to provide veterinary services.
  • We may pass your contact details and your horse’s clinical history to your insurance company should you submit a claim. By submitting a claim form you are providing your consent, in line with our obligations to ensure we perform our contract with you.
  • We may pass your horse’s clinical history to a paraprofessional part of a multidisciplinary team involved in your horse’s care. This may include, but is not limited to: Farriers, Equine Dental Technicians (EDTs), Physiotherapists, Equine Osteopaths, Equine Chiropractors, Sport Massage Therapists.

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 admin@gvgbrooksequine.co.uk, 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.

GVG Brooks Equine 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. Our website uses cookies to help GVG Brooks Equine identify and track visitors and their website access preferences. GVG Brooks Equine website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before visiting GVG Brooks Equine’s website. If you would like to know how to do this, please look at the help menu on your browser. You can also find out more about the way cookies work on http://www.cookiecentral.com.

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:

  • Legitimate interests pursued by GVG Brooks Equine and/or its clients.
  • To promote the marketing and consulting services offered by GVG Brooks Equine and/or to market the services and/or products offered by GVG Brooks Equine’s existing clients.
  • We aim to seek specific consent for the common methods we process clients data, as outlined above. By completing a registration form, or giving verbal or written consent for communication you are consenting to GVG Brooks Equine processing your personal data for the purposes outlined.
  • There are some existing clients we have been unable to contact to gain specific consent. For those that have not responded to us, we will only use information as required to ensure we uphold our contract.
  • You can withdraw or amend consent at any time by emailing admin@gvgbrooksequine.co.ukor writing to us.

 

Consent

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.

 

Data sharing

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.

 

Retention Policy 

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 Storage 

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:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

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 admin@gvgbrooksequine.co.uk.

 

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 admin@gvgbrooksequine.co.uk. 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, admin@gvgbrooksequine.co.ukor 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.

Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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 admin@gvgbrooksequine.co.uk

Information Commissioner’s Office

Telephone 0303 123 1113 or complete a form at: https://ico.org.uk/concerns/handling/