Last updated 25th May 2018
“You”, “Your”, “Patient” means a customer that has purchased hearing aids from us. And is the person whose personal information we collect, use and process. This will also include persons who contact us in connection with the products and services we provide or who interacts with us on our websites www.rjdhearingcare.co.uk, www.rjdonnanhearingcare.co.uk, www.nottinghamhearing.co.uk, www.trusthearing.co.uk, www.hearingaidparts.co.uk, www.yorkhearing.co.uk, www.trusthear.org, www.earwaxnottingham.co.uk, www.beestonhearing.co.uk, www.holistichearing.co.uk, www.retfordhearing.co.uk, www.audiologymanager.co.uk, www.hearingaidreview.org.uk www.chesterfieldhearing.co.uk or in any of our practices.
“Our”, “Us” means THE HEARING PRACTICE GROUP.
“Review” means an article (may also include photographs, videos) or photograph voluntarily submitted by you.
“Please tick to accept the use and storing of your data (i.e. your audiogram, associated case history and service notes and the hearing aid receipt)
This will help THE HEARING PRACTICE GROUP* look after you as a hearing aid user.
*This includes R J Donnan Hearing Care Ltd, The Nottingham Hearing Practice Ltd, Trust Hearing (Oswaldtwistle) and The York Hearing Practice Ltd, all who share the same patient diary system.
We will delete your data if we do not have contact with you for 6 years.
You can withdraw your consent by emailing STOP CONSENT to firstname.lastname@example.org
I accept the use of data as above
Appointment Reminders: I accept you will text me appointment reminders
Quarterly News Letters: I accept you emailing me newsletters
Once annually, telephoning to book a hearing aid appointment: I accept you telephoning me”
Furthermore, if you leave us a REVIEW, we will seek further SPECIFIC PERMISSIONS on the use of his review. You will be asked to tick and sign a document like this:
“Please tick to accept the use and storing of your review by THE HEARING PRACTICE GROUP*
*This includes publishing on websites managed by R J Donnan Hearing Care Ltd, The Nottingham Hearing Practice Ltd, Trust Hearing (Oswaldtwistle) and The York Hearing Practice, and our associated Facebook, Twitter and Google Pages.
You can withdraw your consent by emailing STOP REVIEW to email@example.com
I accept the publishing of my review as above.”
We will not disclose your data / information to third parties EXCEPT to gain an opinion on your ear health or hearing loss and where strictly necessary or unavoidable – see below**.
The Hearing Practice Group
The Hearing Practice Group is the name used to describe all hearing aid companies owned wholly or partly by Robert J Donnan. At the point of writing, these are THE YORK HEARING PRACTICE Ltd., THE NOTTINGHAM HEARING PRACTICE Ltd., TRUST HEARING (A trading style of) DISCOUNT HEARING AND MOBILITY Ltd. and R J DONNAN HEARING CARE Ltd. These are all registered individually with Companies House and with the Information Commissioner’s Office as data controllers. They all share the same encrypted diary system, AMS.
The personal information we may collect and process:
Your name, contact telephone number details (including mobile), your email and postal addresses and personal identifiers (such as date of birth and NHS number).
Your relevant current and previous general ear health history, your family medical history, and any relevant signs or symptoms of hearing loss or associated ear health issues you tell us about.
Details of hearing instruments prescribed for you.
Details of examinations and healthcare procedures, checks and treatments we provide, including ear wax removal, tympanometry, speech audiometry, pure tone audiometry, otoscopy, real ear measurements.
Your past and present employment, lifestyle & hobbies that are relevant to an audiologist, such as noisy activities.
Information relevant to your continued care from other people who care for you or know you well, such as other health professionals and relatives.
Your payment method, details, plan.
Information you provide by filling in contact forms on our websites.
Details of your visit to our websites and any transactions you carry out on our websites.
Any other information voluntarily provided by you.
This information is generally collected from you as you have voluntarily provided it to us. Where lawful to do so, we may also collect information from other sources such as the NHS, other health care providers, from individuals authorised to provide information (e.g. relatives, parents and legal guardians), financial institutions and government, tax or law enforcement agencies.
Why we collect and process your personal data and how is it used?
The information we collect about you is for the primary purpose of ensuring we provide you with the very best and appropriate hearing health care advice, products and services that you’ve ordered.
To confirm your identity and address.
To respond to queries from you.
To remind you when your next appointments are due and to book them.
To send / email you our newsletter (no more than quarterly).
To ask your feedback on the products and services we have provided in order to make continual improvements.
Banking, payment and order details to fulfil an order, deal with queries or refund request and collect regular payments for Gold+ Card membership.
To notify you about changes to our products and service.
To manage insurance claims.
To maintain records for legal, regulatory, tax and other corporate purposes.
We only use RELEVANT information in order to carry out our function as hearing aid audiologists.
Special category data for medical examination records and appointment reminders.
Meeting a legitimate interest to inform you of hearing health products and services which may be relevant to you.
Fulfilling our service contract obligation we have with you by endeavouring to have regular appointments with you.
Fulfilling a legal obligation to look after you and your hearing aids (re. our being members of The Health and Care Professions Council).
You having agreed to our specific communication methods at the point of purchase.
How long is your information kept for?
Your personal information will be retained by The Hearing Practice Group for as long as reasonably necessary (and as defined by health, legal and tax laws and regulations) for us to continue to provide you with products and services. We are also required to maintain records for legitimate purposes to satisfy tax and other legal requirements, to help us respond to queries or for other reasons (responding to requests from regulators and to protect and defend against claims). In any case, if we have had no contact from you for 6 years or more, we will delete all data held about you*.
How we hold and share your personal data
We process your personal data in the strictest confidence. We keep your personal data securely in our patient filing paper copy in each local branch, and on our secure, encrypted electronic system (AMS). Patient records are only accessible to the hearing healthcare professionals working with the required permissions (Registered hearing aid audiologists, Nurses, Data Controllers, Managers) and those under their supervision.
We will usually keep any personal data we hold about you for 6 years after our last contact with you before we delete it. If we collected the data when you were under 18 years of age, we will keep it until your 25th birthday. *In exceptional cases we may need to retain your personal data for a longer period, and will explain our reasons for doing so on request.
In the course of processing your personal data, in exceptional circumstances, we may SHARE it with:
**External healthcare professionals, where a professional opinion is sought, related to you (hearing loss, symptom, and photograph of ear canal / ear drum).
Your GP, NHS audiologist, NHS ENT consultant and other healthcare providers and commissioners, and suppliers of hearing appliances or similar products, in connection with your ongoing healthcare treatment.
Our IT manager and our AMS designer so that we can keep patient records up to date and secure.
The police, for the prevention and detection of fraud and criminal activities.
Our insurers in the event a claim is made or could be made against any business in The Hearing Practice Group.
Transferring your information overseas
We do not transfer your data to any agency or person overseas.
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You have certain legal rights under the UK Data Protection Legislation in respect of the personal data we hold about you. The rights that are most relevant to the way in which we use your personal data include:
You have the right of access. If you ask us for the personal data we hold about you, we will provide it within 30 days, free of charge (unless we have already provided it to you, in which case we may have to charge you the administrative cost of providing it again).
The right to rectification – if you ask us to correct personal data about you that is inaccurate or incomplete, we will do so within 30 days. It is important to keep us up to date with your latest contact details.
The right to object – if you object to us processing your data for product information purposes, or for legitimate hearing healthcare interests (see ‘why we collect and process your personal data’, above), we will then stop doing so, unless we are processing the data in respect of a legal claim or can otherwise show that our legitimate interest in processing the data overrides your rights and interests.
The right to erasure, also known as the ‘right to be forgotten’. If you ask us to delete your personal data, we will do so if there is no compelling reason to continue processing that data. We will not usually delete healthcare data before our usual time limit of 6 years where we have a duty to keep accurate records – for example, to comply with a legal obligation, or in connection with a legal claim. If you ask us to delete such data we will discuss this with you.
Updating your contact details and preferences
To ensure we can continue to provide you with the best hearing healthcare, we are required to send you ‘clinically necessary’ information such as appointment reminders and notify you repaired hearing aids, consumables, and parts that are ready to collect.
You can easily update your contact details and personal preferences for communications from us by EMAILING US AT firstname.lastname@example.org
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. We store a concise paper record in each branch and our SQL-based diary system backs up to a secure location every day. In addition, we limit access to your personal data to those persons stated above 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.
Modern physical and electronic security systems are not entirely secure and we cannot guarantee the complete security of our database. The transmission of information through the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee the security of your contact data transmitted to our websites through the internet. Any such transmission is at your own risk. Once we have received your information, we will use our strict procedures and security features to prevent unauthorised access.
We have 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.
Contacting us and the ICO about your personal data
Please speak to us first if you have any questions or concerns about the way in which we process personal data. You can contact / send a letter to us at: The Data Protection Manager, The Hearing Centre, 1 Dewsbury Road, Cleckheaton, BD19 3RS or email email@example.com, or by telephone: 01274 862623.