1.1 We are committed to safeguarding the privacy of our website visitors and patients. This policy explains how we comply with our obligations under the law to protect your personal data.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and patients; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to Auris Ear Care Limited. For more information about us, see Section 11.
- How we use your personal data
2.1 In this Section 2.1 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
Category of personal data
Description of category
Items of data collected
Source(s) of data
Purpose(s) for which data will be used
Legal basis of processing
Data about use of the website
IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use
Analytics tracking system: Google Analytics
Analysing the use of the website
Legitimate interests, namely monitoring and improving the website
Information contained in any enquiry submitted regarding services
First name, last name, email address, mobile number, address
Individual concerned or parent / guardian
Patient in the case of GP data
Selling our services and obtaining consent relating to medical procedures
We will only process it on the basis of explicit consent
Information about our patients, their medical conditions and their medical procedures
As per enquiry data, plus information about consent (adult or child) to treatment which includes D.O.B, gender, allergy details, general practitioner (GP) name, GP telephone number, GP address, GP postcode, parent first name, parent last name, parent email address, parent mobile number, parent signature, relationship to child, signature, examination findings, procedure details, prescription details and follow up plan.
Clinician details to include name of clinician, location and signature.
Individual concerned or parent / guardian, or clinician
Providing our service. Monitoring and assessing the quality of our service. Continuity of patient care and record keeping for medico-legal purposes.
The performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract**
Insofar as patient data includes health data, we will only process it as necessary for the purposes of preventive medicine, medical diagnosis, the provision of health care and the management of health care services pursuant our contract
Information provided for the purpose of subscribing to our email notifications and/or newsletters
Name and email address
Sending the relevant notifications and/or newsletters
*Insofar as we process the personal data of minors and GP personal data, the legal basis of that processing is our legitimate interests, namely the proper provision of treatments and the administration of our business more generally.
** In limited cases a different basis may apply. Where the contract or prospective contract is with your employer, the legal basis of processing will be our legitimate interests, as identified above. Similarly, insofar as we process the personal data of minors and GP personal data, the legal basis of that processing is the same legitimate interests.
2.2 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.3 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.4 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.5 Please do not supply any other person's personal data to us, unless we prompt you to do so.
- Providing your personal data to others
3.1 This Section 3.1 sets out details of the third parties to whom we may disclosure or transfer personal data.
Category of personal data
Third party access to data
Analytics services provider: Google, Inc
Enquiry data and patient data
National Health Service (NHS) (primary, secondary and tertiary care)
Care Quality Commission (CQC)
Health and Care Professions Council (HCPC)
General Medical Council (GMC)
Royal College of Surgeons (RCS)
UK social services
Local emergency services (police, ambulance, fire brigade)
Insurance companies: the patient's insurance company and our professional indemnity insurance providers
Contractors: self-employed Auris Ear Care personnel
Hosting and I.T services providers: DOWO Digital
Marketing communications services provider: The Rocket Science Group (trading as Mailchimp)
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Category of personal data
Data retention period
18 months following collection
Enquiry data and patient data
Between 12 months and 24 months following the date of the enquiry. However, if the user becomes a patient, the data will be kept for 8 years from date of procedure
Not more than 1 month following any un-subscription from the relevant notification or newsletter
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
5.3 All personal data stored in our website database will be stored in encrypted form.
5.4 Data that is sent from your web browser to our web server, or from our web server to your web browser, will also be protected using encryption technology.
5.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data by email is inherently insecure, and we cannot guarantee the security of data sent by email.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
- Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Updating information
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10.3 We use session cookies (PHPSESSID) to identify your browser as you navigate our website. These cookies will be deleted when you close your web browser.
10.5 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
10.6 Blocking all cookies will have a negative impact upon the usability of many websites.
- Our details
11.1 This website is owned and operated by Auris Ear Care Limited.
11.2 We are registered in England and Wales under registration number 11494141, and our registered office and principal place of business is at 10 Harley Street, London, W1G 9PF, England.
11.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
11.4 We are registered as a data controller with the UK Information Commissioner's Office.
11.5 Our data protection registration number is ZA479317