Southern Cross Dental - Privacy Policy (August 2018)

This document describes the Privacy Policy of Southern Cross Dental Laboratories Limited, trading as Southern Cross Dental (Company Number 636616) referred to in this document as ‘SCD, ‘we’, ‘us’, ‘our’ or ‘it’ and its related body corporate. By providing your personal information to SCD, through the web site, or otherwise, you understand that the collection, use and disclosure of that information by us shall be in accordance with this Privacy Policy. 

It is important that you read this privacy notice so that you are fully aware of how and why we are using data. This version was last updated on 10 December 2018 and previous versions can be obtained by contacting us.

1. What is this policy about?

This policy is about how we manage your personal information. It aims to answer the questions you might have about how we collect and use your personal information. This policy may be revised from time to time, including as new features are added to the site or the legislation changes. Please check back periodically for changes, updates and additions. If you do not agree to the Privacy Policy, please do not use the website or provide us with your information.

Controller/Processor

Subject to the next paragraph, we are the controller and responsible for your personal data. If you have any questions about this privacy notice (including any requests to exercise any of your legal rights) please contact us by emailing [email protected]

We are, from time to time, appointed to use (or otherwise process) personal data on behalf of other organisations. Such appointments will be made in accordance with relevant data protection legislation. Whenever we are appointed as processor, we will be restricted in the manner and purpose for which we can use personal data and will be subject to other obligations under that legislation. We will apply the same security and data handling processes to the personal data which we have been provided with by the controller as we do to personal data over which we are the controller.

Third Party links


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. While we strive to protect our website users’ information and privacy, we cannot guarantee the security of any information you disclose online and you do so at your own risk.

2. What information do you collect and hold about me?

We collect and hold information that is provided to us by you or a third party. This includes information that we have been provided with by your employer or your dental healthcare provider.

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about individuals which we have grouped together as follows:

Identity Data includes first name, last name, online username or similar identifier, title, date of birth and gender;
Contact Data includes email address, physical address and telephone numbers;
Financial Data includes payment method;
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 our website;
Usage Data includes information about how you use our website and services;
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
Health Data includes details about individuals’ race or ethnicity, sexual orientation, information about health and genetic and biometric data, such as the reason why our products or services are required and medical notes and details of health conditions which we need to know to deliver our services or products.

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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Your duty to inform us of changes

It is important that the personal data we hold about you or otherwise provided by you is accurate and current. Please keep us informed if any such personal data changes during your relationship with us.


3. HOW DO WE COLLECT AND USE YOUR PERSONAL DATA?

We use different methods to collect personal data (including data from and about you) including through:

Process of Collection Types of Data Collected

A. During direct interactions whenever you provide the personal
data in person, by post, by phone, via our website, by email,
via social media or otherwise.

Identity Data
Contact Data
Financial Data
Marketing and Communications Data
Health Data
B. As you interact with our website and we may use
cookies, server logs and similar technologies.
Technical Data
Usage Data
Marketing and Communications Data
C. From third parties including your employer,
analytics providers (advertising networks),
electronic payment providers or data aggregators.
Contact Data
Financial Data
Technical Data
D. From publicly available sources (like Companies
House, the Electoral Register and social media).
Identity Data
Contact Data
E. During recruitment campaigns from third party
recruitment service providers or from you.
Employment Data
Health Data
F. From our clients (including dental practices,
specialist clinics, dental hospitals, dental schools
and other dental or healthcare professionals) in
order to provide services or products to them or
their customers.
Identity Data
Contact Data
Health Data

 

Some of our manufacturing partners and service providers are located overseas, which means we are likely to disclose your personal information overseas, including to the United States.

How we use personal data

We will only use personal data when the law allows us to. Most commonly, we will use personal data under the following conditions:

• Where we need to perform a contract we are about to enter into, or have entered into, with the individual;
• Where it is necessary for our legitimate interests (or those of a third party) and the individual’s interests and fundamental rights do not override those interests;
   or
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing personal data other than where expressly asked for separately than in this notice, in relation to certain cookies and if necessary for sending third party direct marketing communications via email or text message (and recipients have the right to withdraw consent to marketing at any time by contacting us).

Purposes for, and legal basis on, which we will use personal data

We have set out below a description of all the ways we may use personal data, and which of the legal bases we rely on to do so (including a description of the legitimate interest pursued). Note that we may process personal data for more than one basis depending on the specific purpose for which we are using your data, but will only rely on the “performance of a contract” basis whenever the contract is with the individual to whom the personal data relates.

Purpose/Activity Legal Basis for Processing including Basis of
Legitimate Interest
To register an individual as a new customer. (a) Performance of a contract with the individual.
To manage our relationship with you, which may
include notifying you about changes to our terms
or privacy notice.
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep
our records updated and to study how customers
use our products/services).
To administer a contract with an organisation you
are associated with (e.g. your employer or your
referring body).
(a) Necessary for our legitimate interests (to
establish and perform a contractual relationship,
including processing payments and all ancillary
services).
To administer and protect our business and our
website (including troubleshooting, data analysis,
testing, system maintenance, support, reporting
and hosting of data).
(a) Necessary for our legitimate interests (for
running our business, provision of administration
and IT services, network security, to prevent fraud
and in the context of a business reorganisation or
group restructuring exercise).
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and
advertisements to you and measure or understand
the effectiveness of the advertising we serve to
you.
(a) Necessary for our legitimate interests (to study
how customers use our products/services, to
develop them, to grow our business and to inform
our marketing strategy).
To use data analytics to improve our website,
products/services, marketing, customer
relationships and experiences.
(a) Necessary for our legitimate interests (to define
types of customers for our products and services,
to keep our website updated and relevant, to
develop our business and to inform our marketing
strategy).
To make suggestions and recommendations
to you about goods or services that may be of
interest to you.
(a) Necessary for our legitimate interests (to
develop our products/services and grow our
business).
To manage the recruitment process, including
setting up and conducting interviews, evaluating
the results and as otherwise needed in the
recruitment and hiring process.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to solicit,
evaluate and select applicants for employment)
(c) Necessary to comply with a legal obligation.
To manufacture, or arrange for the manufacture
of, bespoke products and tailored services for the
purposes of our clients and their patients.
(a) Necessary for our legitimate interests (to
provide products and services) and necessary for
the provision of health care or treatment.

 

Note:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

 

4. RECEIVING MARKETING INFORMATION FROM SCD.

SCD strives to offer the best products and services to you, so we like to keep you up to date with any new products, offers and services. Unless you’ve specifically asked us not to (and only from time to time) we may communicate with you regarding current products, special offers, invitations to events, offers for services, new product previews, updates to our products, press releases and announcements concerning the products we provide, contests and our rewards program, as well as important changes in our Terms of Use and this Privacy Policy. If at any time you decide for any reason that you no longer wish to receive such communications, you may “opt out” of receiving them by using one of the following methods:

• Use the ‘Unsubscribe’ link on the email sent to you;
• Email us on [email protected]
• Calling (042) 934 3043

Please be aware that when you opt out of receiving communications, it will not affect administration and transaction related communications.


5. DISCLOSURES OF PERSONAL DATA.

We recognise the trust you place in us when you give us your personal information. Other than disclosure as required by law (for example, disclosure to various Government departments or to courts) or to the extent necessary to fulfil any order for goods placed by you (including to our manufacturing partners and service providers), in the event of a sale of all or part of our business or for another purpose specified in this document, our policy is that we do not give your personal information to other organisations unless you have given us your consent to do so or we are otherwise permitted by relevant data protection legislation to do so.

We may have to share personal data with the parties (all established in the European Union unless otherwise stated) set out below for the purposes set out in the table in paragraph 3 above:

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.


• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;


• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services;


• Other members of our group of companies, who may be based within the European Union, New Zealand, Australia or Hong Kong, in order to manufacture, or contribute to the manufacture of, our products or to provide assistance to our business such as IT storage or back-ups;


• Service providers acting as processors, including (as at the date noted above and who may be updated from time to time) a data destruction company based in Northern Ireland engaged to securely dispose of redundant data.

We require all third parties to respect the security of the personal data we share with them 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.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA) other than to certain other members of our group of companies. For these recipients, we ensure that a similar degree of protection is enforced as is required within the EEA. We will transfer the data if the recipient countries have been deemed to provide an adequate level of protection by the European Commission or if we consider that the transfer is necessary for the performance of a contract concluded in the interest of the individual.

7. DATA SECURITY

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify the individuals concerned and any applicable regulator of a breach where we are legally required to do so. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions. SCD has security measures in place to protect  personal information from loss, misuse, interference and from unauthorised access, modification or disclosure.

8. DATA RETENTION

We will only retain 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. SCD has security measures in place to protect personal information from loss, misuse, interference and from unauthorised access, modification or disclosure.

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, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements. We are also under regulatory requirements to retain data, and will retain the data for at least as long as those requirements state.

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.

9. INDIVIDUALS’ LEGAL RIGHTS

Under certain circumstances, individuals have rights under data protection laws in relation to their personal data, such as the right to:

Request access to personal data (commonly known as a “data subject access request”). This enables individuals to receive a copy of the personal data we hold about them.


Request correction of the personal data that we hold about the individual. This enables the individual to have any incomplete or inaccurate data we hold about them corrected, though we may need to verify the accuracy of the new data provided to us.


Request erasure of personal data. This enables individuals to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where exercising the right to object to processing is successful (see below), where we may have processed information unlawfully or where we are required to erase personal data to comply with local law. Note, however, that we may not always be able to comply with a request of erasure for specific legal reasons which will be notified to the individual, if applicable, at the time of request.


Object to processing of personal data where we are relying on a legitimate interest (or those of a third party) and there is something about the individual’s particular situation which makes them want to object to processing on the ground of it impacting on fundamental rights and freedoms. Individuals 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 information which overrides individual’s rights and freedoms.


Request restriction of processing of personal data. This enables individuals to ask us to suspend the processing of their personal data in the following scenarios: (a) to establish the data’s accuracy; (b) where our use of the data is unlawful but the individual does not want us to erase it; (c) to hold the data even if we no longer require it as the individual needs it to establish, exercise or defend legal claims; or (d) where the individual has objected to our use of the data but we need to verify whether we have overriding legitimate grounds to use it.


Request the transfer of personal data to the individual or to a third party. We will provide to the individual, or a nominated third party, their personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which the individual initially provided consent for us to use or where we used the information to perform a contract with the individual. 

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

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

The individual will not have to pay a fee to access their personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

What we may need

We may need to request specific information from the individual to help us confirm their identity and ensure the right to access relevant personal data (or to exercise any 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 the individual for further information in relation to their request, to speed up our response.

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 the request is particularly complex or a number of requests are made. In this case, we will notify the individual and keep them updated.

Supervisory Authority Contact

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. HOW CAN I ACCESS OR SEEK TO CORRECT THE INFORMATION YOU KEEP ABOUT ME?

You may request us to provide access to your personal information or to request its correction by calling us on (042) 934 3043 or email us on [email protected].We aim to respond to most requests within 14 days, or if the request is more detailed, within 30 days. SCD may recover from you its reasonable cost of supplying you with access to your personal information.

11. WHAT TO DO IF YOU HAVE A PROBLEM, QUESTION OR COMPLAINT?

If you have any further queries relating to our Privacy Policy, or you have a problem or complaint, please call us on (042) 934 3043, or email us on [email protected] We will review your query, problem or complaint and we will endeavour to issue a reply as soon as reasonably practicable (and in any event, usually within 30 days). If we need more information from you, we will contact you and let you know. If it is a complaint and you are not satisfied with our response, you may make a complaint to a supervisory authority.