Privacy Policy

GDPR & Privacy Policy

Ridge Referrals Ltd

What happens to your personal information when your pet is referred to us?

GDPR

The General Data Protection Regulations (GDPR) came into force in the UK on 25th May 2018 and replaces the Data Protection Act 1998 (DPA). The GDPR are important because it increases the regulatory burdens and obligations of organisations like ourselves to protect your personal data and strengthens the rights of individuals (like you the client). Our privacy policy below demonstrates our commitment to and compliance with these regulations in respect of protecting your personal data.

Ridge Referrals Limited is committed to protecting and respecting your privacy. We want you to understand how we collect and use information about you.

The privacy notice describes to you

Who we are
What personal data we collect and store about you, and how we collect it
Why we collect personal data and what we do with it
The categories of third parties with whom we share your personal data
How we retain your information and keep it secure
Your rights and how to exercise them
How to contact us

1. Who are we?

For the purposes of data protection law, the “controller” is Ridge Referrals Limited, a company incorporated and registered in England and Wales under company number 7879796 and having its registered office address Calyx House, South Road, Taunton, Somerset, TA1 3DU, United Kingdom (from now on referred to as “Ridge Referrals”, or as “we” and related words such as “us” and “our”). Our registered VAT number is 976711876.

As controller we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.

If you would like to contact us about this notice, including if you wish to receive further information about any aspect of it, our details are as follows:

E-mail: surgery@ridgereferrals.co.uk

Post: Data Privacy, Ridge Referrals Ltd, Jubilee Barn, Dawlish Water, Dawlish, Devon, EX7 0QW, UK.

Telephone: 01626 862094

2. What information do we collect from you?

In the course of our business, which is providing a referral orthopaedic veterinary service, we collect the following personal data when you or your referring veterinary surgeon (or another third party involved in the care of your pet) provide it to us:

personal details, such as
name and title
contact data, such as
your address
e-mail address
home telephone and mobile number(s)
any other personal information you provide
Pet insurance information
policy number
name and address of policy holder
terms and conditions of your policy

Very rarely we may need to store some “special category” or sensitive personal data.

This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.

An example of this may be that you disclose to us some information about your own personal health as that information has an impact on the decisions we need to make during the treatment your pet. You will have consented to provide us with this information and it will be treated in strictest confidence and will not be shared without your prior consent. We would only ever document sensitive personal data if it was important and relevant to the care programme that we are providing for your pet.

We also do not collect information about criminal convictions or offences.

3. How do we collect personal data?

We obtain personal data from sources as follows:

directly from you when you interact with us, for example when you
contact us by telephone
contact us by email
write to us
from your current first opinion veterinary practice when you have consented to be referred to us - we may receive this information by post, email, fax or telephone.
from other organisations that may previously have been involved in the care of your pet eg. Previous veterinary practices (including other referral practices), physiotherapists, hydrotherapists, behaviourists, laboratories or other third parties that may have been involved providing care plan for your pet.

4. How do we use your personal data?

Introduction

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

to perform a contract we are about to enter into or have entered into with you (a referral to us from your primary care vet).
where we need to comply with a legal or regulatory obligation.

Lawful processing

In order to process personal data, we must have a lawful reason (sometimes called a lawful basis). We always ensure that this is the case, and we set out our lawful bases below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests.

We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.

Please contact us if you would like more information on this, and on situations in which more than one lawful basis applies.

Contractual Necessity

When you are referred to us and therefore enter into a ‘contract’ with us we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide a service to you:

to identify you (and your pet)
to respond to your inquiries
to provide our products and services to you and your pet before during and after your pet has been referred to us from your primary care vet.
to carry out billing and administration activities, including refunds and credits

Of course, you are not obliged to provide us with any of this information, but if you chose not to, we may be not be able to accept a referral from your primary care vet.

Legitimate Interests

We process your personal information for our legitimate business purposes, which include the following:

to conduct and manage our business and ultimately to provide treatment to your pet.

Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.

Compliance with laws

We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).

Consent

We will never contact you for marketing purposes, you will have been referred to us by your primary care vet and any contact we will have with you will only be regarding the veterinary care that we are currently giving, have already provided or are due to provide to your pet. Therefore there are no ‘marketing consents’ for you to opt in/out of.

5. Do we share your personal data?

We may provide your personal data to the following recipients for the purposes set out in this notice:

Your primary care veterinary practice
We will liase with your primary care vet before, during and after your referral to us to ensure that your pets clinical notes are shared to enable both parties to treat your pet to the best of their abilities.
Other service providers involved in the care of your pet (this will have been discussed with you and agreed before arrangements are made).
For example, we may recommend that your pet has further treatment with a physiotherapist, acupuncturist or behaviourist.
We may need to refer your pet to another veterinary practice for further treatment or tests eg. MRI scan or to visit a neurologist.
We may need to send away samples from your pet to an external laboratory for analysis in which your pet would need to be identified with some of your personal details eg. Your surname and your pets name, breed, age & sex.
Sometimes we use external companies who will manufacture a bespoke piece of equipment aimed for use specifically with your pet eg.3D drill guide made from CT images of your pet or a orthotic splint system made from a cast taken from your pet. For identification purposes some of your personal details will be submitted alongside your pets name when these orders are placed eg.your surname.
CT, x-ray, ultrasound or arthroscopy images taken from your pet may be shared with a third party eg. ‘Vet Oracle’ if their clinical opinion is required to aid further treatment of your pet, some of your personal data eg. your surname may be shared along with your pets details for identification purposes when these images are submitted.

Future veterinary practice requests

In the future if you choose to move your pets care to another veterinary practice, the new practice may contact us to ask for a copy of your pets clinical history, we are obliged by the Royal College Of Veterinary Surgeons (RCVS) to provide this information so an informed treatment plan can be put in place for your pet – We will contact you when we receive this request to get your consent.

merger or acquisition partners, to the extent that sharing your personal data is necessary.
law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety.
any other parties, where we have your specific consent to do so.

6. Do you have to provide personal data – and, if so, why?

To form a contract with you and accept the referral request for treatment of your pet, we will need some or all of the personal data described above so that we can complete the contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the required data, the contract could not be performed.

7. How long will your personal data will be kept for?

We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data and our indemnity insurers historically advise clinical records are retained for 7 years (6 years is the maximum limitation period for most civil claims plus one year).

Our preference would be to hold your pets clinical history (and therefore your personal data that goes alongside this) for the duration of your pets life so that we are always able to provide information in the future about the treatment we provided to your pet and to give you piece of mind that this information will always be available during your pets lifetime should you require it.

If your pet is deceased and the treatment that we provided was carried out more than seven years ago, please feel free contact us and we will arrange for all of your pets clinical data and your attached personal data to be destroyed (we will require a written request) should that be your wish.

8. Do we transfer personal data outside the EEA?

No.

9. How do we keep your personal data secure?

Ridge Referrals has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorised Ridge Referrals employees and trusted third parties processing data on our behalf have access to your personal data.

All Ridge Referrals employees who have access to your personal data are required to adhere to the Ridge Referrals Privacy Notice and General Data Protection Regulations.

The security measures we have in place include:

regular reviews of information collection, storage and processing practices to protect against unauthorised access
restriction of access to personal information which is stored on our veterinary practice management system.
monitoring of systems storing and processing your information

We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us by email or post.

Please contact us using the details in section 1 of this notice if you would like more information about this.

10. Your information rights

We draw your attention to your following rights under data protection law:

right to be informed about the collection and use of your personal data
right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us; please also update us in the event this information changes.
right of erasure – in certain circumstances you have the right to have personal data that we process about you blocked, erased or destroyed
the right to object to, or restrict:
processing of personal data concerning you for direct marketing
decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you
in certain other situations, to our continued processing of your personal data
the right of portability of your data in certain circumstances.

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.

Please contact us using the details in section 1 of this notice if you would like to exercise any of these rights or know more about them.

These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/

11. Changes to this privacy notice

We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.

12. What should you do if you have a complaint?

We hope that you will be satisfied with the way in which we approach and use your personal data.

Should you find it necessary, you have a right to raise a concern with the information regulator, the Information Commissioner’s Office:https://ico.org.uk/

However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 1 above, so that we have an opportunity to resolve it.

Privacy Notice – CCTV

This Privacy Notice applies to all employees and visitors to the Ridge Referrals premises at Jubilee Barn, Dawlish Water, Dawlish, EX7 0QW.

HOW WE OBTAIN YOUR PERSONAL DATA

Our CCTV monitors the Front carpark area and entrance doors, side carpark in front of the stable block and the rear yard 24 hours a day, this data is continuously able to be viewed live but is not always being recorded.

Camera locations are chosen to minimise the capture of images which are not relevant to the legitimate purposes of the monitoring.

Live feeds from CCTV cameras are monitored only where this is reasonably necessary, for example to protect health and safety or for site security.

Ridge Referrals will ensure that live feeds from cameras and recorded images are only viewed by approved members of its staff whose role requires them to have access to such data. This may include Ridge Referrals staff involved in disciplinary or grievance matters.

No surveillance cameras are placed in areas where there is an expectation of privacy.

Ridge Referrals does not carry out covert monitoring or surveillance (that is, where you are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, Ridge Referrals reasonably believes there is no less intrusive way to tackle the issue.

Any covert monitoring or surveillance will be carried out for a limited and reasonable period of time consistent with the objectives of the monitoring or surveillance and will relate only to the specific suspected criminal activity or extremely serious malpractice.

THE TYPES OF PERSONAL DATA WE USE AND HOW WE USE THEM

The types of personal data we collect and use, the purposes for which we use your personal data, and the lawful bases we rely on to allow us to use your personal data in that way are set out in the table below.

Where the lawful basis is our legitimate interests or the legitimate interests of a third party, we have also indicated what those interests are.

We may have more than one lawful basis for using your personal data.

TYPE OF PERSONAL DATA	HOW WE USE THAT DATA	THE LAWFUL BASIS FOR OUR PROCESSING THAT DATA
Images of individuals and their vehicles on and around Jubilee Barn.	To prevent crime and protect buildings and assets (of Ridge Referrals, of other occupants of the building and of their respective staff and visitors) from damage, disruption, vandalism and other crime	The legitimate interests of staff and visitors and of Ridge Referrals and other occupants of the building in protecting the building and their assets
	For the personal safety of staff and visitors (of Ridge Referrals and of other occupants of the building) and other members of the public and to act as a deterrent against crime	The legitimate interests of staff and visitors in being safe and the legitimate interests of Ridge Referrals and other occupants of the building in keeping their staff and visitors safe
	To support law enforcement bodies in the prevention, detection and prosecution of crime	The legitimate interests of staff and visitors to Ridge Referrals and other occupants of the building in preventing crime and helping to detect and prosecute crime
	To assist in the day-to-day management, including ensuring the health and safety of staff and visitors (of Ridge Referrals and of other occupants of the building) To assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings with staff (of Ridge	The legitimate interests of Ridge Referrals and other occupants of the building in managing their businesses and ensuring the health and safety of their staff and visitors The legitimate interests of Ridge Referrals and other occupants of or visitors to the building in resolving disputes which arise in
	Referrals or of other occupants of or visitors to the building)	the course of disciplinary or grievance proceedings
	To assist in the defence of any civil litigation, including employment tribunal proceedings (involving Ridge Referrals or other occupants of or visitors to the building)	The legitimate interests of Ridge Referrals other occupants of the building and visitors to the building in bringing or defending any civil litigation proceedings

Where images from our CCTV system are relevant to other occupants of the building or any individual (for instance if they show that their car has been broken into), Ridge Referrals may share them with those other occupants/individuals if it considers that this is reasonably necessary for any of the purposes set out above.

Ridge Referrals is not responsible for the use other occupants or individuals make of those images. You are advised to consult other occupants of the building about how they use your personal data.

Ridge Referrals may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.

Ridge Referrals will keep a record of all disclosures of CCTV footage.

Any stored video images will be deleted after 6 months unless needed for an ongoing investigation.

THANK YOU FROM THE RIDGE REFERRALS TEAM

Royal College of Veterinary Surgeons (RCVS)