Privacy Notice

Who we are?

Bayfields Group Limited, Bayfields Y ltd and Bayfields Z Ltd is a group of private independent Opticians and Audiologists, trading as Bayfields Opticians and Audiologists, operating from multiple sites across the UK, with our registered address being Unit E, Home Farm Business Park, The Avenue, Esholt, BD17 7RH. A full list of our practises can be found here. We are registered with the Information Commissioners Office as Data Controllers, registration numbers ZA315304, Z3581090, ZA111404.

Your Privacy

This notice provides detailed information on when and why we collect your personal information, how we use it and the very limited conditions under which we may disclose it to others.

Your privacy matters to us and we are committed to the highest data privacy standards, patient confidentiality, and adherence with the Data Protection Act 2018 and UK GDPR. We adopt the core principles of data protection.

Collection of your Personal Data

Where you provide personal data to us, we will become responsible for it as the data controller.

We will only collect data that is necessary for us to deliver the best possible service and ensure that you are reminded about appointments or information relevant to your ongoing care.

We collect your personal information directly from you, for example, when you visit our practice, get in touch with us by telephone or email, use our booking system or when you visit our website.

We may also collect it from other sources if it is legal to do so. This includes from the NHS or other healthcare providers, institutions, or people you have authorised to provide information on your behalf (for example, parents or guardians), third-party service providers, government, tax or law-enforcement agencies, and others.

Who we are?

Main Categories and Type of Personal Data Collected and processed.

Processing Activity	Personal Data Required/Held	Retention Time	Reason to hold Data
Optical service and products	Name, date of birth, telephone numbers, address, and email. Current and past health and medication information, family history, your examination results, and lifestyle information. Data received from other healthcare professionals as part of your ongoing care	10 years after last contact or until age 25, whichever is later	Contract – in order to provide the service or products you have requested. Where health data is processed, we do so for the provision of healthcare
Hearing care service and products	Name, date of birth, telephone numbers, address and email Current and past health and medication information, family history, your examination results, and lifestyle information. Data received other healthcare professionals as part of your ongoing care	10 years after last contact or until age 25, whichever is later	Contract – in order to provide the service or products you have requested. Where health data is processed, we do so for the provision of healthcare.
Reminders	Name, email address, address, telephone numbers Where recall communications are sent by email, we may collect information regarding the date and time that booking links contained within these emails are selected.	10 years after last contact or until age 25, whichever is later or until asked to stop by you Email engagement information is retained for up to 45 days	Contract – In order to provide the ongoing service appointment reminders are sent Legitimate Interests – to understand the effectiveness of our clinical recall communications, improve patient engagement with appointments, and ensure our communications are operating effectively.
Marketing	Name, email address, address, telephone number	Until asked to stop by you or until consent withdrawn by you	Legitimate interests – we will provide information which we believe is of genuine interest to you. Consent – you have given consent to receive information about products or services that are of interest to you
Credit/Debit card payments	Cardholder name, card number, security number	Duration of the transaction	Contract – you have agreed to provide these details to pay for the service or products ordered
CCTV footage	Images	30 days	Legitimate interests – Prevention and detection of crime. Protection of our colleagues and visitors. Investigation of accidents, incidents, criminal activities, and breaches of our policies.
Collection of online identifiers for analytical purposes (Cookies)	Cookie information IP address Device ID Session ID Interaction history Website feedback	See Cookie Policy	Consent – Ensuring visitors get the best experience.

We treat all personal data as sensitive but acknowledge that we also process special category data including health data and children’s data.

Sharing of Personal Data

We share your personal data within our group of companies.

During the delivery of our service to you, we will share your data with other companies who are essential for the provision of our service to you. They are under contract with us and have provided sufficient guarantees that they will process your data only as per the terms of that contract and throughout processing activities will ensure your data is protected using appropriate technical and organisation measures.

We use a third-party email delivery provider to send recall communications. Where these emails are sent, information relating to link clicks may be processed on our behalf for the purposes described in this notice.

Where necessary we may disclose your information to health care professionals including the NHS where we have a duty of care or to fulfil our legal obligations. We are compliant with the national data opt-out. For more details and to opt out see: https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/

It may also be necessary, where the latest technology allows us to do so, to use your information and health data to facilitate digital consultations and diagnoses. We will always do this with your security in mind.

We may also pass information to external agencies and organisations, including the police, for the prevention and detection of fraud and criminal activity. Should any claim be made, we may pass your personal information to our insurers and, if our business is wholly or partially transferred to a third party, your personal information may be one of the transferred assets.

Our operations are based in the UK, and your personal information is generally processed within the UK and countries within the European Economic Area (EEA). In some instances, we may transfer your personal information to third countries, for example, where our suppliers or cloud service providers are situated outside the UK and EEA.

If the recipient is situated in a third country that has not received an adequacy decision from the relevant regulator, we will ensure additional safeguards are in place including the use of applicable standard contractual clauses.

A full list of processors is available from our Data Protection Officer.

Securing and Processing of your Personal Data

To provide and manage our services your electronic data is stored and processed by Optix Software Ltd within their UK facilities, certified to ISO27001, which has appropriate security processes in place.

Your data is also stored within our own IT systems, which are secured to prevent access or intrusion by anyone who is not authorised to have access to your data. Our practices are operated to ensure that all records and equipment holding your personal data are physically protected.

In the unlikely event that we lose your data, or a device on which your data resides, or it is accessed by someone unauthorised, we will inform you if the loss or unauthorised access of your data has potential to cause you harm. We will notify the Information Commissioners Office (ICO) of any reportable data breaches.

Your rights in relation to personal data

Under UK data protection law, you have following rights which you can exercise by emailing our Data Protection Officer on [email protected]

Right	Explanation
Right to be Informed	This means that we have to be transparent in how we collect and use your personal data
Right of Access	You have the right to access your personal data.
Right to Rectification	If the information we hold about you is inaccurate or incomplete, you can request that we correct this
Right to Erasure	You can request that we delete or remove personal data in certain circumstances
Right to Restrict Processing	You have the right to request that we cease processing your data if: you consider it inaccurate or incomplete and/or you object to the reason we're processing your data We will review the validity of your request and respond to you with our decision
Right to Data Portability	Where you have consented to our processing your data or where the processing is necessary for us to deliver a contract you can request a copy of that data be provided to a third party
Right to Object	You have the right to object to our processing in certain circumstances. For example, you can object to: direct marketing and processing for the purposes of scientific/historical and statistics
Rights relating to Automated Decision-Making including Profiling	We do not use automated decision-making or profiling. Where automated decision-making is applied, organisations must: give you information about the processing introduce simple ways for you to request human intervention or challenge a decision carry out regular checks to make sure that our systems are working as intended

How to contact us?

For all data protection matters, questions relating to how we manage your data, or if you are concerned about how your data is being handled, you can contact our Data Protection Officer:

Data Protection Officer: Clinical DPO

Phone Number 0203 411 2848

Email: [email protected]

For complaints, please include the following where possible:

Your name and contact information,

A description of your concern or the data protection issue,

Any relevant supporting information.

Complaints will be acknowledged within 30 days, and we aim to respond fully and resolve the matter without undue delay. If your issue requires more time or clarification, we will keep you informed throughout.

If you are dissatisfied in how we have handled your data, you have the right to complain to the UK Information Commissioner's Office (ICO):

• Website: https://ico.org.uk/make-a-complaint/

• Phone: 0303 123 1113

• Address: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF