Last updated: London, 17 April 2024
Privacy Policy
Introduction
Welcome to betterview’s Privacy Policy. In this Privacy Policy we give details about how we process your personal data as one of our patients. This includes processing your personal data when:
- Assisting you with enquiries.
- Booking and attending appointments.
- The provision of treatment to you.
- Providing you with information and offers in respect of our products or services.
- Maintaining our records in accordance with applicable laws and regulations.
In this Privacy Policy we use “we” or “us” or “our” or “betterview” to refer to our company whose details are set out below. This is the company that processes your personal data, and includes its surgeons, nurses and other employees who provide and assist in the provision of our services to you.
Our contact details
Name: Betterview Britain Limited
Address: 1 Ariel Way, London, England, W12 7SL
Phone Number: +44 20 3695 9547
E-mail: [email protected]
The type of personal information we collect
Enquires
If you make an enquiry with us, we will use your personal for the following purposes and lawful basis:
| Personal Data | Purpose for processing | lawful basis |
|---|---|---|
| Contact details including name, email address, residential address, and telephone number. | To allow us to contact you regarding your enquiry or booking and possible Treatment. | To potentially enter into a contract with you to provide our services. |
| Communications we may receive personal data from you throughout our communications with you. | To maintain a record of our communications with you to potentially provide our services to you. | To potentially enter into a contract with you to provide our services. |
| Cookie information for full details of our cookie policy see Cookie Policy. | To enhance your use of our website. | With your consent and/ or legitimate interests. |
| Marketing Preferences, which you can withdraw at anytime by contacting us using the contact details at the beginning of this Privacy Policy | To maintain a record of your marketing choices and to send marketing communications to you. | With your consent and/ or legitimate interests. |
Appointments
If you have an appointment with us at one of our clinics, we will use your personal for the following purposes and lawful basis:
| Personal Data | Purpose for processing | lawful basis |
|---|---|---|
| Contact and identification details including name, email address, date of birth residential address, and telephone number. | To communicate with you regarding your appointment. | Necessary to perform our contract with you. |
| Occupation details about your job. | To ensure you receive the correct advice regarding your treatment as is relevant to your occupation | Necessary to perform our contract with you. |
| Health Data this includes details about your eye prescription, biometry, any existing health conditions, medications. | To ensure you receive the correct advice regarding your treatment | Necessary for our contract with you. Necessary to meet a Legal Obligation Article 9: Necessary for the provision of healthcare |
| Ethnic Origin | To provide you with the relevant advice and treatment. (some conditions run in families and can affect your suitability for treatment) | Necessary for our contract with you Article 9: Necessary for the provision of healthcare |
| Payment details, including card details | To receive payment from you for our services | Necessary to perform our contract with you also as necessary to meet a Legal Obligation |
| CCTV | To protect our premises and staff | Legitimate Interests |
| Communications we may receive personal data from you throughout our communications with you. | To maintain a record of our communications with you in order to potentially provide you with a service | Necessary to perform our |
| contract with you. |
When receiving treatment
If you have an appointment with us at one of our clinics, we will use your personal data for the following purposes and lawful basis:
| Personal Data | Purpose for processing | lawful basis |
|---|---|---|
| Contact details including name, email address, residential address, and telephone number. | To communicate with you regarding your treatment, aftercare and post-treatment appointments. | Necessary to perform our contract with you. |
| Health Data includes details about your eye prescription, biometry, any existing health conditions, medications. | To ensure you receive advice and treatment | Necessary for our contract with you. Necessary to meet a Legal Obligation Article 9: Necessary for the provision of healthcare |
| Ethnic Origin | To provide you with the relevant advice and treatment. (some conditions run in families and can affect your suitability for treatment) | Necessary for our contract with you Article 9: Necessary for the provision of healthcare |
| Payment details e.g. bank details for direct debit | So that we may take payment for our services and/ or products | Necessary for our contract with you Necessary to meet a Legal Obligation |
| Communications we may receive personal data from you throughout our communications with you, including customer feedback (CSAT, NPS, Google Reviews) | To maintain a record of our communications with you in order to potentially provide you with a service | Necessary for our contract with you |
Financial
If you have utilise any finance options to pay for your treatment, we process use your personal data for the following purposes and lawful basis:
| Personal Data | Purpose for processing | lawful basis |
|---|---|---|
| Contact details including name, email address, residential address, and telephone number. | When communicating with you in relation to Finance. To verify your ID and to contact you in relation to your finance agreement. | Necessary to perform our contract with you. |
| Employer details | To assess if you are eligible for credit | Necessary to perform our contract with you. |
| Financial information | To assess if you are eligible for credit | Necessary to perform our contract with you. |
NHS Referrals
If you have been referred under an NHS contract for treatment with us, we process your personal data for the following purposes and lawful basis:
| Personal Data | Purpose for processing | lawful basis |
|---|---|---|
| Contact details including name, email address, residential address, and telephone number. | To contact you regarding consultation, treatment or follow up care | Necessary to perform our contract with you. |
| Health Data includes existing health conditions, medications, allergies, records related to treatment provided | To provide you with the relevant treatment or healthcare service | Necessary for our contract with you. Article 9: Necessary for the provision of healthcare |
| Communications Information we may learn about you from emails, calls, letter between us. (Calls to customer services are recorded) | To maintain a record of our communications with you in order to potentially provide you with a service | Necessary to perform our contract with you. |
| Employer details | To assess if you are eligible for credit | Necessary to perform our contract with you. |
| Financial information | To assess if you are eligible for credit | Necessary to perform our contract with you. |
How we receive your personal data
Most of the personal data we process is provided to us directly by you and or from health professionals, third party referrals, such as the NHS, and Finance providers relevant to your treatment.
Third parties
We may use third parties (as data processors) as required to deliver certain aspects of our services, including software providers, confidential waste disposal, records storage, email and postal distribution. These third parties include:
- Salesforce
- Jotform
- Pandadoc
- Chrysalis
- Bank of London
- Meta
- Topcon
- Zeiss
- betterview AG Switzerland
- TUG Agency
We require all third parties to enter a contract with us to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party providers to process your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.
International Transfers
Transfers between offices within the betterview Group
We share your personal data within the betterview Group. This may involve transferring your personal data outside the UK to our overseas offices in Switzerland. Switzerland has been recognised by the EU and UK supervisory authorities to offer an adequately level of protection to personal data (known as an adequacy decision).
Transfers outside the UK to an organisation outside the betterview Group
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
- we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; and/or
- we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, these include International Data Transfer Agreements and the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
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 third parties on a “need to know” basis. They will only process your personal data on our instructions.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
If you are interested in receiving laser treatments with us, we will request that you attend one of our clinics for an appointment to assess your suitability for surgery. At the consultation, we will gather personal data from you including your contact details, information relating to your health and lifestyle to assess your suitability for surgery and complete an eye examination (sight test). Information we collect during your laser treatment will be retained for a minimum period of 10 years and up to 20 years where necessary.
Your data protection rights
Under UK data protection law, you have rights including:
- Your right of access - You have the right to ask us for copies of your personal data.
- Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. To exercise these rights, please contact us via the details provided at the top of this Privacy Policy
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at via the details provided at the top of this Privacy Policy.
You can also complain to the ICO if you are unhappy with how we have used your personal data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk