We are Optegra UK Limited, a company registered in England under number 05846041. Our registered office is at Oakhill House, 130 Tonbridge Road, Hildenborough, Kent, TN11 9DZ.
- We will always use your data within the law.
- We will never sell your data
- We will always respect your wishes about how you would like to be contacted.
We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify post a notice on our Site prior to such changes(s) taking effect. In the event that such a change could materially affect your privacy, you will be notified without delay by appropriate means.
Optegra UK Head Office
Optegra Eye Health Care
7 The Technology Park
Colindeep Lane, London, NW9 6BX
Why do we collect your data?
- We obtain and use your personal details and financial details in order to establish and deliver our contracted services to you.
- Where you access our service through your health insurance provider we will need to share personal information including medical information with your health insurance provider with your explicit consent.
- Where you access our service through the NHS we will need to share personal information including medical information with the NHS with your explicit consent.
- We obtain and use your medical information as this is necessary for medical purposes, including medical diagnosis and treatment.
- We also store your medical information such as notes from consultations for regulatory compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, Private Health Information Network (PHIN) or as otherwise required by law or regulation.
- We use your email address, postal address and telephone to send you occasional updates and marketing messages where you have given your consent or where you have not opted out, based on our legitimate interest in marketing our services to you, and subject to your right to opt out at any time).
- We use your telephone in order to communicate with you regarding appointment bookings, resolving of queries or complaints.
Information we may collect from you
Information you provide
Personal details – Basic information about yourself that you provide by filling in forms on our Site or speaking to us on the telephone; such as your name, date of birth, physical address and email address, telephone numbers.
Medical information – Information about your symptoms, consultations, medications and procedures.
Financial information – We do not collect or store credit or debit card details. When you make any payments using your credit/debit card, these details are processed directly by a third-party processor that will store all payment information and transactions details. We will only retain limited details of the transactions on secure servers located in the UK.
Insurer funded – Where your access to our service is funded by an insurance provider, with your consent, we will need to let your insurance company know your name, email address, policy number, demographic information, appointment and procedure details.
Passive information collection and use
As you navigate through the Site, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection.
We and our third-party service providers may passively collect and use information in a variety of ways, including:
Through your browser – Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.
IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
Using pixel tags, web beacons, clear GIFs, or other similar technologies – These may be used in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates.
Device Information – We may collect information about your mobile device, such as a unique device identifier.
Third Party Sites and Services
Social Media and Sharing Tools
On some pages, we may also feature embedded ‘Share’ buttons or widgets that enable you to share content with friends through a number of popular social networking sites (e.g. Twitter and Facebook etc).
These sites may set cookies which can identify you as an individual when you are also logged in to their services. This means they may be collecting information about what you are doing online, including on our Sites. We do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt out.
Telephone and Video Consultations
We may offer you a consultation via telephone or video conferencing. By accepting the invitation and entering the consultation you are consenting to this. Your personal/ confidential patient information will be safeguarded in the same way it would with any other consultation and any risks explained to you before the consolation begins.
How we use your data
COVID–19 Data Protection Statement
During these unprecedented times, Optegra’s main priority is the health and safety of our patients, colleagues and the wider community as well as supporting the NHS in responding to the COVID-19 pandemic.
As a result of these unique circumstances, Optegra UK Ltd may need to share personal data with the NHS and other regulatory and government bodies for the purpose of supporting the response to the COVID-19 pandemic. Each of our hospitals is working in collaboration to ensure we can provide the right help, exactly where and when it is needed and this may involve personal data being shared with us by the local healthcare organisations. This will be done in accordance with data protection laws and will include any amendments to legislation made by the Secretary of State. We will also consider any guidance provided by the Information Commissioner’s Office.
Data Subject’s Rights
Due to the current circumstances, if you submit a Subject Access Request (SAR) or other Data Subjects Rights request, please be aware that you may experience a delay in us responding to your request. That’s because we will be diverting resources to help with other challenges and ensuring the ongoing healthcare and treatment of our patients.
At this current time we are limited to collect any correspondence sent via post. If you need to get in touch regarding a SAR or other information request, please contact us via email at DPO@Optegra.com
Sharing of your Personal Data during the Covid-19 pandemic
During the Covid-19 pandemic your personal data may also be shared for the following purposes:
• Understanding Covid-19 trends and risks to public health and controlling and preventing the spread of Covid-19
• Identifying and understanding information about patients or potential patients with or at risk of Covid-19 including patient exposure to Covid-19
• Management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19
• Understanding capacity and availability information about patient access to health services and adult social care services
• Monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information ( including workforce details) to the public about Covid-19
• Delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19
• Research and planning in relation to Covid-19.
We will regularly review this privacy statement and its applicability throughout the COVID-19 outbreak. We may also notify you in other ways from time to time about the processing of your personal information.
Using your personal data and the legal basis for processing
We will process your personal data under Article 6 (1)b; Article 9 (2)h of the General Data Protection Regulations. In addition OPTEGRA UK LTD will rely one or more of the following basis when sharing personal data as part of our support work with the NHS during the COVID-19 pandemic:
• Legal obligation: the processing is necessary for compliance with a legal obligation Article 6 (1)(c) *
• Vital interests: the processing is necessary to protect someone’s life. Article 6 (1) (d)
• Public interest: the processing is necessary to perform a task in the public interest. Article 6 (e)
• Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third party Article 6 (1) (f)
When processing special category data for the purposes of;
• Employment, social security and social protection Article 9 (2)(b)
• Vital interests of the Data Subject Article 9 (2) (c)
• Substantial public interest Article 9 (2) (g)
• Provision of health or social care Article 9 (2) (h)
• Public interest in the area of public health such as protecting against serious cross border threats to health Article 9 (2) (i)
* This includes the Notice by Secretary of State under Reg 3(4) of Health Service Control of Patient Information Regulations issued 1st April 2020 allowing healthcare providers to share personal data and any other such notice that may be issued to support efforts against COVID-19.
We use your personal data to support the provision of your healthcare in the following ways:
• To support the provision of your healthcare;
• To decide how best to provide treatment to you;
• To take steps at your request during the course of your treatment;
• To keep your records up to date
Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section.
Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users.
How do we use your data?
We use and disclose information you provide to us as described to you at the point of collection.
We also use information from or about you:
- To respond to your inquiries and fulfil your requests, such as to send you documents you request or e-mail alerts.
- To send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies and/or other administrative information.
- For our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying Site usage trends, personalizing your experience on the Site by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.
We may also disclose information collected through the Site:
- To our third-party service providers who provide services such as website hosting and moderating, mobile App, hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide services on our behalf.
- To a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
- Sub-processors. We may share information with sub-processors who assist in providing us with key services. An up-to-date list of our sub-processors is located here.
Use of Site by Minors
This site is directed to adults. It is not directed to individuals under the age of 16, and we request that these individuals do not provide personal information through this Site.
You have the right to:
Access the personal data which the Company holds about you. This is called a Subject Access Request (SAR) and must be made to the Data Protection Manager using the details in the ‘Contact Us’ section.
You may use this process to exercise your right to:
- Have your personal data rectified if it is inaccurate or incomplete.
- Request that we erase information we hold about you.
- Restrict the processing of your personal data, for example ask us not to contact you.
- Object to the processing of your data for specific purposes such as communications or direct marketing.
- Ask for the transfer of your data electronically to be provided to a third party (data portability)
You also have the right to lodge a complaint with the Information Commissioner’s Office:
Information Commissioner’s Office
Telephone: 0303 123 1113 (local rate)
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