Introduction
Dental Partner respects your privacy and is committed to protecting your personal data. Our Privacy Policy will help you to understand what information we collect and process using this Dental Partner website, how we protect and use it, and what choices you have about your personal data.
When we refer to “Dental Partner” within this Privacy Policy, we are referring to Dental Partner a trading name for Doctor.co.uk (Sales) Limited with its main office at The Old Coach Houses, Cranes Close, Turvey, MK43 8EN, the organisation which provides this website, and any services or features which may be made available to you from this website.
Data Protection Framework
Doctor.co.uk (Sales) Limited is based within the United Kingdom, and as such is registered with the Information Commissioner’s Office (ICO) as a Data Controller under the UK Data Protection Act of 1998 registration number ZA336382. We have also aligned our Privacy Policy with the EU General Data Protection Regulation (“GDPR”), which comes into effect on 25th May 2018, under the supervision of the ICO within the UK.
Doctor.co.uk (Sales) Limited has completed applicable Privacy Impact Assessments (also known as Data Protection Impact Assessments under GDPR) for activities related to this website where they meet the necessary criteria, and these are available upon request from the Dental Partner’s Data Protection Controller (see Section 12).
Purpose of this Privacy Policy
This privacy notice aims to give you information on how Doctor.co.uk (Sales) Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete the enquiry and contact forms.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 data.
Data Controller
Doctor.co.uk (Sales) Limited is the controller and responsible for your personal data (collectively referred to as “Dental Partner”, “we”, “us” or “our” in this privacy notice).
We have appointed a dedicated contact who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection controller using the details set out at the end of this document.
1 Customer and Citizen Data
You may decide to send us your personal information via this website if you are seeking more information about our services, signing up for our newsletter or for other similar purposes. Your decision to disclose your personal data is entirely voluntary, and by doing so, you are taking an affirmative action by providing us with specific consent to use your personal data only for the purposes for which you have disclosed it to us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
1.1 How data is collected
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name last name, title;
- Contact Data includes address, email address and telephone numbers;
- 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;
- Usage Data includes information about how you use our website, products and services;
- Purchase Data includes information about your practice; and
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We use different methods to collect data from and about you including through:
1.1.1 Direct interactions
You may give us your Identity and Contact Data by filling in online forms or by corresponding with us by phone, email, or otherwise. This includes personal data you provide when you:
- Request information;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey;
- Purchase a product or service; or
- Give us some feedback.
1.1.2 Automated technologies or interactions
As you interact with our website, we may 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
1.1.3 Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google based outside the EU;
- Search information providers based both inside and outside the EU.
1.2 How we use your personal data
Dental Partner will only use your personal data when the law allows us to and only for the specified purpose for which you have submitted it to us.
Most commonly, we will use your personal data in the following circumstances: (a) provide information to you, (b) make contact with you, (c) provide contracted services to you, (d) perform the contract between us, (e) 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 (f) where we need to comply with legal and regulatory obligations or (g) maintain the operations and security of the website and services we provide to you.
You will receive marketing communications from us if you have:
- Requested information from us or purchased products and services with us;
- If you have provided us with your details and confirmed you want to receive marketing communications
You have the right to withdraw consent to marketing at any time by contacting us at DPO@dentalpartner.com, writing to us at the address below or by clicking the un-subscribe link (opt-out) in our emails.
Whatever preference you may affirm or change from time to time, GDPR permits us to send communications where a legal requirement arises or legitimate interest prevails.
1.3 Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of specific interest to you. This is how we decide which products, services and offers may be relevant for you under the basis of contract or legitimate interest (we call this marketing).
1.4 Data Storage
We will, at all times, handle and store your personal data in accordance with industry best practice for information security. This includes the activities and procedures undertaken by our own personnel and authorised third parties (see Section 5), and the technical controls which we have implemented to prevent unauthorised access, compromise or theft of information from our applications, supporting computer systems and premises.
With regard to the Dental Partner website, these include removal of all personal data from the local and staging website, removal of data migration plugin, password prompts to access the staging site and two-factor authentication and email verification to access the back-end of the site. User access is limited. Information sent between your browser and our website is encrypted using SSL (Secure Sockets Layer).
We have put in place procedures to deal with any suspected data breach including disaster planning and will notify you, and any applicable regulator, of a breach where we are legally required to do so.
We limit, where possible, access to your personal data to employees and third parties including data processors, who have a business need to know such data. They will only process your data on our instructions and are subject to a processing agreement duty of confidentiality.
In some circumstances you can ask us to delete your data, please see Section 4 below.
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.
2 Sensitive Personal Data
GDPR specifies a set of personal data categories which are “sensitive”, and which require special consideration by Data Controllers. This website, and any services available from this website, do not knowingly collect or process any sensitive personal data.
3 Children’s Personal Data
This website, and any services available from this website, are not directed to children under the age of 13. If you learn that a child under the age of 13 has provided us with their personal information without having parental consent, please contact the Dental Partner’s Data Protection Controller (see Section 9) immediately so that we can take appropriate action.
4 Customer and Citizen Data Rights
As prescribed within data protection regulations, you have specific rights connected to the provision of your personal data to Dental Partner using this website. These include your rights to request we:
- Confirm to you what personal data we may hold about you, if any, and for what purposes
- Change the consent which you have provided to us in relation to your personal data
- Correct any inaccurate or incomplete personal data which we may hold about you
- Provide you with a complete copy of your personal data for you to move elsewhere
- Stop the processing of your personal data, whilst an objection from you is being resolved
- Permanently erase all your personal data promptly, and confirm to you that this has been done
(there may be reasons why we may be unable to do this)
To contact Dental Partner, please see Section 12 below.
4.1 Exercising your rights
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 may refuse to comply with your request in these circumstances.
4.1.1 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.
4.1.2 Time limit to respond
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 and keep you updated.
If Dental Partner does not address your request within one month, or fails to provide you with a valid reason why we have been unable to do so, you have the right to contact the Information Commissioner’s Office to make a compliant. They can be contacted via their website (www.ico.org.uk) or by telephone +44 (0) 303 123 1113.
5 Declaration of Sub-Processing
To make an informed decision on whether to provide your personal data to Dental Partner using this website, we need to make you aware of the following organisations who act as Data Processors for us in the provision of our services to you:
- EVC Marketing, based in the United Kingdom, who processes data for marketing purposes, on behalf of Dental Partner. EVC Marketing is registered with the Information Commissioner’s Office for the UK Data Protection Act with registration number A8253934.
- Campaign Monitor (Sub Processor), based in the United States, a marketing platform that deals with the processing and automated processing of email contact and engagement information, via the Dental Partner website and online forms. Campaign Monitor complies with their requirements under the GDPR. Access to Campaign Monitor is limited and password protected.
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.
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.
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.
Please email us at DPO@dentalpartner.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
The activities within which each of these Data Processors participates will be recorded within the applicable Dental Partner Privacy Impact Assessment records (also known as Data Protection Impact Assessments under GDPR) if required and these will be available upon request from the Dental Partner Protection Controller (see Section 12).
6 Website Cookies
This Dental Partner website uses cookies to record log data. We use both session-based and persistent cookies, dependent upon how you use or interact with this website.
Cookies are small text files sent by us to your computer, and from your computer or mobile device to us each time you visit our website. They are unique to you or your web browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser session. Persistent cookies last until you or your browser delete them, or until they expire.
We use cookies which are not specific to your account but are unique and allow us to undertake website analytics and customization, among other similar things. If you decide to disable some or all cookies, you may not be able to use some of the functions on our website. We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies by visiting their website.
We use cookies to help:
- Make our website work efficiently and smartly
- Save you having to remember login details every time you visit us
- Remember your settings during and between visits
- Improve our site’s speed so it’s quicker to browse
- You share pages on social networks like Facebook
We do not use cookies to:
- Collect any personally identifiable information (without your permission)
- Collect any sensitive information
- Pass data to any advertising networks or third parties
You can view our cookie policy here.
7 External Link
This Dental Partner website may include relevant hyperlinks to external websites not controlled by us.
Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the on-going suitability of external links, nor do we continually verify the safety or security of the contents which may be subsequently provided to you.
You are advised, therefore, that your use of external links is at your own risk and we cannot be responsible for any damages or consequences from your use of them.
8 International Transfers
Dental Partner does not transfer your personal data outside the European Economic Area (EEA).
However, our data processors may use third party services that may transfer your personal data outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever they transfer your personal data out of the EEA, they do their best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- They will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where they use certain service providers, they 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
- Where they use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
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.
Please email us at DPO@dentalpartner.com if you want further information on the specific mechanism used by our data processors when transferring your personal data out of the EEA.
9 Data Security
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 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.
10 Data Retention
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.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we keep basic information about our customers for seven years for tax purposes
Details of retention periods for different aspects of your personal data are available from request from us by contacting us.
11 Changes to this Privacy Policy
We may change this Dental Partner Privacy Policy from time to time, and if we do we will post any changes on this page. If you continue to access this website or use services available from this website after those changes have come into effect, you will have agreed to the revised policy.
This Dental Partner Privacy Policy is version 1.0, and was released on 1st May 2018. You are advised to download or print a copy and retain it for your records.
12 Contacting Dental Partner
If you have any questions about this Privacy Policy, would like to exercise any of your statutory rights, or to make a complaint, please write to:
The Data Protection Controller
Dental Partner
The Old Coach House
Cranes Close
Turvey, MK43 8EN