SEE Employee Eyecare

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Duncan & Todd (Group) Limited collects and processes your Personal Data through your use of this website, including any data you may provide through this website or input on the SEE hub, sign up to our newsletter OR purchase a product or service OR take part in a competition OR complete a survey.

It is important that you read this Privacy Policy together with any other data protection or fair processing information we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data, and our reasons for sharing it with third parties. This Privacy Policy supplements other notices, fair processing and contractual information, and is not intended to override them.

Data Controller

Smart Employee Eye Care is a trading name of Duncan & Todd Limited. Duncan & Todd limited is the Data Controller and responsible for your Personal Data (collectively referred to as “Duncan & Todd”, "we", "us" or "our" in this Privacy Policy) for the purposes of relevant data protection law.

Duncan & Todd Limited is registered with the Information Commissioners Office as a Data Controller registration number Z8311243.

We have appointed a data protection officer (DPO), who is responsible for overseeing and responding to any questions which you may have in relation to this Privacy Policy or how we deal with your Personal Data. If you have any questions about this Privacy Policy or how we deal with your Personal Data, including any requests to exercise your legal rights as a Data Subject and as referred to below, please contact our DPO using the details provided.

Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our DPO in the following ways:

DPO: Amicis Data t/a Clinical DPO

E Mail Address: [email protected]

Telephone: 0203 411 2848

Full name of legal entity: Duncan & Todd (Group) Limited

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (via their website at www.ico.org.uk/concerns or by telephone on 0303 123 1113) if you have any concerns or are unhappy about how we have dealt with your or Personal Data. We would, however, appreciate the chance to deal with any concerns before you approach the ICO so please contact us in the first instance.

Changes To This Privacy Policy And Your Duty To Inform Us Of Any Changes

We keep our Privacy Policy and any other fair processing information provided when you book an appointment or become a customer under regular review. This version was last updated on 30 November 2021.

It is important that the Personal Data which we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or practices. When you leave our website via clicking on any third-party link, we encourage you to read the Privacy Policy of every website you visit.

2. Data Protection Principles

In dealing with your Personal Data we adopt the six core principles of data protection law, which are:

• Lawfulness, Fairness And Transparency - we process Personal Data lawfully, fairly and in a transparent manner in relation to you as a Data Subject;
• Purpose Limitation - we only collect Personal Data for specific, explicit and legitimate purposes. We clearly state what these purposes are in this Privacy Notice, and we only collect Personal Data for as long as necessary to complete those purposes;
• Data Minimisation - we ensure that any Personal Data which we process is adequate, relevant and limited to what is necessary in relation to our stated purposes for such processing;
• Accuracy - we take every reasonable step to update or remove Personal Data that is inaccurate or incomplete as soon as possible.
• Storage Limitation - we delete Personal Data when we no longer need it. Further information on relevant retention periods is set out below.
• Security, Integrity and Confidentiality – We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have also put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Any Personal Data which we collect is stored within the SEE hub. We hold ISO 27001 (Information Security Management) Certification and as part of our own due diligence, our Data Protection Officer has reviewed our data security processes.

In the unlikely event that we lose any Personal Data, or a device upon which Personal Data is stored, or it is accessed by someone unauthorised to do so (a Personal Data Breach), we may have a duty to inform you immediately. If a Personal Data Breach has the potential to cause a serious risk to your rights and freedoms we will also report it to the Information Commissioners’ Office in accordance with our wider data protection obligations.

3. The Personal Data Which We Collect

For the purposes of data protection law and this policy, “Personal Data” means any information about an individual from which that person can be identified. It does not include data where identity information has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you either through this website, via our booking system, by telephone or when you attend at any of our locations, which we have grouped together as follows:

· Identity Data includes [first name, maiden name, last name employee number].

· Contact Data includes [email address and telephone numbers].

· Transaction Data includes [details about vouchers assigned and any products and services you have received from us].

· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

· Profile Data includes [purchases or orders made by you, your interests, preferences, feedback and survey responses and general lifestyle information relating to you.

· Usage Data includes [information about how you use our website, products and services].

· Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data, but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with Personal Data so that it can directly or indirectly identify a specific individual, we treat that combined data as Personal Data which will be used in accordance with this Privacy Policy.

If You Fail To Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). In this case, we may have to cancel any product or service you receive from us (or any appointment) but we will notify you if this is the case at the time.

4. How Is Personal Data Collected?

We use different methods to collect data from and about you, including through:

· Direct Interactions Relating To Our Products And Services. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

· enquire about our products or services;

· request marketing to be sent to you about our products or services;

· enter a competition, promotion or survey;

· provide us with a review of our products or services;

· raise a query, complain or provide other feedback about our products or services; or

· contact us for any other reason.

· Automated Technologies Or Interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

5. How We Use Personal Data

We will only use your Personal Data when the law allows us to do so. Most commonly, we will use Personal Data in the following circumstances:

· Where we need to perform the contract we are about to enter into or have entered into with you.

· Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

· Where we need to comply with a relevant legal obligation.

More information about the types of lawful basis that we will rely on to process your Personal Data is set out below. Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Personal Data

We have set out below, in a table format, a description of all the ways in which we plan to use your Personal Data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using it. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

6. International Transfers

We wont transfer your personal data outside of the UK or EEA.

7. Data Retention

How Long Will You Use Personal Data For?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of Personal Data, the purposes for which we process Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your Personal Data: please see the section Your Legal Rights below for further information.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you or them.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

You have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you or they provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with a relevant legal requirement. Note, however, that we may not always be able to comply with a request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

· If you want us to establish the data's accuracy.

· Where our use of the data is unlawful but you do not want us to erase it.

· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

· You have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent on your own behalf. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time at which consent is withdrawn.

If you wish to exercise any of the rights set out above on your own behalf, please contact our DPO using the details set out above.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if a request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Last updated: November 2021