Waterstone Clinic is committed to ensuring that your privacy is protected. We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This statement sets out the basis on which any personal data we collect from and about you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This statement is being provided to you in line with our obligations from 25 May 2018 under the General Data Protection Regulation (GDPR).
Waterstone Clinic is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you would like to contact us with any queries or comments in relation to your personal data, please:
Send an e-mail to firstname.lastname@example.org
Send a letter to Waterstone Clinic, Lotamore House, Tivoli, Cork, Ireland, T23 N4A7
Call us on 0818 333310
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
The types of information we collect about you include:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, fax, text, patient portal, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping, and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Patient Data that includes data that you provide to us to facilitate us providing you with our services. The personal data that you give us may include, but is not limited to, your name, address, e-mail address, phone number, photograph, passport/driving licence or other identification documents, medical records, PPS number, medical insurance or medical card number. We process this data to supply services to you and for record keeping purposes. Our lawful ground for this processing is the performance of a contract between you and us.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Patient Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We collect Sensitive Data about you but only for the purposes of providing you with fertility services. Sensitive data refers to data that includes details about your medical and genetic data, race or ethnicity, sex life and sexual orientation.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by sending us emails or obtained during conversations). We may receive data from third parties such as analytics providers such as Google based outside the EU, suppliers of ours who have passed your information on to us as we are the distributor for your territory. We may also receive data from publicly available sources.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you do not provide personal data to us and this would prevent us from performing the contract we have or are trying to enter into with you, or place us in breach of the law, we may have to cancel our contract. We will notify you if this is the case.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. We may then use your personal data to send you marketing communications from us if you have requested information from us or have been a patient of ours or if you provided us with your details when you entered a competition or registered for a newsletter.
We will get your express opt-in consent before we use your personal data for any other marketing purpose. We do not, nor will not sell or share your personal data with any third party for their own marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of you being a patient of the clinic.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers
- Government and regulatory bodies that require us to report processing activities
- GP’s, Medical consultants, Pharmacists, third party fertility clinics, testing laboratories
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Please be advised that promotional photographs and videos may be taken at our clinics, including during patient information events. We will however, avoid identifiable images of patients & non employees, unless specifically photographing the patient or individual. They are for use on our website, social media, in the press, and for marketing materials. By entering our clinics, you consent to Waterstone Clinics photographing and using your image and likeness.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
We may have occasion to transfer your personal data to clinic’s and service providers who are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data 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.
We will retain your medical records for as long as we are obliged to by law. You can ask us about the retention periods for different aspects of your personal data by contacting us at email@example.com
In some circumstances we may 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
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at www.dataprotection.ie. If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
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 or refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Data Protection Commissioner’s Office (DPC). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
VISITORS TO OUR WEBSITE
If we want to collect personally identifiable information through our website, we will be up front about this, such as booking an appointment or completing a form.
When someone visits our website, we may use a third-party service to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We may record your session using Hotjar analytics; no personal information such as payment details, email address, address, or name will be displayed or recorded.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our website may include links to third-party websites, plug-ins and applications. 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.
CHANGE OF PURPOSE
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law. However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.