We are Brunlea Surgical Supplies Limited a company registered in England and Wales (Company No. 07964805) with its registered office at 7 Eskdale Close, Burnley, BB10 2SH (“we”, “our”, “us”, “the Company”). We are a “Data Controller” for the purposes of the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and Data Protection Act 2018, whilst undertaking our business services.
We are committed to protecting and respecting your privacy. This Privacy Notice applies to all users of our website (at www.brunleasurgical.co.uk), (the “Website“), our patients and other people who interact with or do business with us (such as our suppliers and service providers). It sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully as it contains important information on our practices regarding your personal information and how we, as a data controller, will treat personal information you provide to us, what we do with the information you provide to us and who we may share your information with.
2. Data Protection Principles
We will comply with data protection law and principles, which means that your information will be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about; and
- Kept securely.
3. The type of information we collect about you
If you purchase products from us, register for our prescription service, communicate with us, visit our Website or do business with us, this will result in us collecting personal information about you. We will collect, store, and use the following types of personal information about you:
- Contact details such as the name, address, email, fax and telephone number of business contacts, customers and patients;
- Bank and transaction details such as details about payments to and from you and other details of products and services you have purchased from us;
- Technical information such as includes 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;
- Records of your correspondence with us;
- Information about how you use our Website, products and services;
We may also collect, store and use the following more sensitive types of personal information:
- Information about your health including any medical condition, disability and treatment you are receiving.
4. How is your personal information collected?
We collect your personal information through different methods including:
- Direct interactions with you by telephone, our Website, e-mail, phone or otherwise;
- Through the service that we provide to you, or that you provide to us;
- Automated technologies or interactions. As you interact with our Website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. For further details please see our Cookies Policy.
5. How we will use your personal information
We will only use your personal information in accordance with the law. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (whether an employment or a business contract);
- 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. (in which case we will carry out a legitimate interests assessment);
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you electronically. You have the right to withdraw consent to any such marketing at any time.
6. Purposes for which we use your personal information
We need all the categories of information in the list above (see “The type of information we collect about you” above) primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
- To register you as a patient or a supplier;
- To register you for our prescription service;
- Where you agree, to provide you with information, products or services that you request from us or which we feel may interest you;
- To operate and improve the Website;
- To perform our contract with you, including processing payments;
- To answer any queries you send through the Website, or any other means;
- To manage our relationship with you, including notifying your about changes to our contract or services or asking you to provide us with feedback;
- To administer and protect the business and this Website;
- To address any complaints or legal claims; and
- To make suggestions or recommendations to you about similar products or services that may be of interest to you.
If you fail to provide personal information
If you fail to provide certain personal information (or to update any personal information we are already using) when requested, or required by law, or under the terms of a contract we have with you, we may not be able to perform or enter into the relevant contract (whether employment or business). In this case, we may have to cancel your job application or a contract you have with us. We will notify you if this is the case at the time.
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.
7. How we will use your health information
“Special categories” of particularly sensitive personal information, such as information about your health, requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when using such sensitive information. We may process special categories of personal information in the following circumstances:
- For the provision of health care or treatment; or
- With your explicit consent.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests and you are not capable of giving your consent, or where you have already made the information public.
Sharing your personal information
We will not ordinarily share your information with anyone else. However, there are certain circumstances where we will be required to share your information with organisations as part of the service we provide to you or where we are required to do so by law. We will comply with the GDPR and the DPA 2018 when making this disclosure.
Where it is required or necessary we may share information with:
- Your GP;
- Your Stoma Nurse;
- Our suppliers or service providers;
Our contracts with all third parties include provisions to protect your personal information. Third parties only have access to personal information necessary to perform the described purposes, and may not use it for other purposes. Third parties are also required to comply with data protection law in their own capacity and will provide you with their own privacy notices.
9. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
10. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different categories of your personal information are available in our retention policy, which you can request from us by contacting us using the details shown below.
11. What rights do you have?
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 business relationship with us.
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 information, or request that we transfer a copy of your personal information to another party, please contact us using the details below. Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request
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.
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 contact Cath Bullock, Managing Director using the details below. 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.
We take any complaints we receive about the collection and use of personal information very seriously. We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by contacting us (see contact details section below).
If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the ICO at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
13. Contact us:
You can e-mail us at firstname.lastname@example.org or write to us at the following address: Unit 10 Balderstone Close, Burnley BB10 2TA. Tel: 0800 834712