Privacy Policy
The practice aims to meet the requirements of the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the guidelines on the Information Commissioner’s website ICO as well as our professional guidelines and requirements.
The data controller is Rosa Cicero.
This privacy Notice is available if you contact [email protected] or by calling the practice on 0207 060 0086.
The categories of data we process are:
- Personal Data for the purposes of staff and self-employed team member management
- Personal data for the purposes of direct mail, email, text or marketing
- Special category data including health records for the purposes of the delivery of healthcare
- Special category date including the health records and details of the criminal record checks for managing employees and contracted team member
We never pass your personal details to the third party unless we have a contract for them to process data on our behalf and will otherwise keep it confidential. If we intend to refer a patient to another practitioner or to secondary care such as a hospital we will gain the individual’s permission before the referral is made and the personal data is shared.
- [Personal Data Is stored in the [EU] whether in digital or hard copy format]
- [Personal data is stored in the US in digital format when the data storage company is certified with the EU-US Privacy Shield]
- Personal data is obtained when a patient joins the practice, when a patient is referred to the practice and [when a patient subscribes to an email list]
The lawful basis for processing special category data such as patients’ and employees’ health data are:
- Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services based on Union or Member State Law or a contract with a health professional.
The lawful basis for processing personal data such as name, address, email or phone number is:
- Consent of the data subject
- Processing is necessary for the performance of a contract with the data subject to or to take steps to enter into a contract
The retention period for special data in patient records is a minimum of 10 years and may be longer for complex records to meet our legal requirements. The retention period for staff records is 6 years. The retention periods for other personal data is 2 years after it was last processed. Details of other retention periods are available in the Record Retention procedure available from the practice.
You have the following personal data rights:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (clinical records must be retained for a certain time period)
- The right to restrict processing
- The right to data portability
- The right to object
Further details of these rights can be seen in our Information Governance Procedures or at the Information Commissioner’s website. Here are some practical examples of your rights:
- If you are a patient of the practice you have the right to withdraw consent for important notifications, newsletters, surveys or marketing. You can inform us to correct errors in your personal details or withdraw consent from communication methods such as telephone, email or text. You have the right to obtain a free copy of your patient records within one month.
- If you are not a patient of the practice you have the right to withdraw consent for processing personal data, to have a free copy of it within one month, to correct errors in it or to ask us to delete it. You can also withdraw consent from communication methods such as telephone, email or text.
Comments, suggestions and complaints
Please contact Rosa Cicero at the practice for a comment, suggestion or a complaint about your data processing at [email protected] or by writing to or visiting the practice at 86 Harley Street, London, W1G 7HP. We take complaints very seriously.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO). Our membership number is ZA342297. Their telephone number is 0303 123 1113. You can also visit their website for information of how to make a data protection complaint.
Dated: 23.05.18
To be reviewed: 23.05.19
Cookie Policy
What are website cookies?
As is common practice with almost all professional websites, this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need tostore these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or break certain elements of the sites functionality. For more general information on cookies see the Wikipedia article on HTTP Cookies at https://en.wikipedia.org/wiki/HTTP_cookie
How we use cookies
We use cookies for a variety of reasons detailed below. Unfortunately, in most cases, there are no industry standard options for disabling cookies without completely disabling thefunctionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not, in case they are used to provide a service that you use.
Disabling cookies
You can prevent the setting of cookies by adjusting on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The cookies we set
To provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page which is affected by your preferences.
What are the different types of cookies?
Different cookies are used to perform different functions. We detail below our use of cookies. You do have choices about how cookies are used.
We use cookies that are essential and first party; they are set by the web server of the visited page and share the same domain. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as filling in forms.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. Third Party Cookies for advertising and performance; in some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
Here at The Harley Street Eye Clinic we use Google Analytics cookies which is one of the most widespread and trusted analytics solutions on the web. These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. For more information on Google Analytics cookies, see the official Google Analytics page (https://support.google.com/analytics/answer/6004245).
Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.
They do not store directly personal information but are based on uniquely identifying your browser and interest devices. If you not allow these cookies, you will experience less targeted advertising.
We also use social media buttons and/or plugins on this site that allow you to connect with your social media network in various ways, such as sharing pages or links. For these to work the following social media sites (if available) Facebook, Instagram, Twitter, YouTube, Google+ will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
For SEO (search engine optimisation) purposes, from time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the site, whilst ensuring we understand which optimisations our users appreciate the most.
How to refuse or opt out of cookies
Most browsers and websites automatically accept cookies but provide controls that allow you to block or delete them. This site has an implied consent policy for these cookies, which assume the user has set their cookies on their browser to active. A cookies policy banner is visible until the user acknowledges it and accepts the banner (they can also click on it to read more).
If you wish to block cookies from your browser software, please check the browser help menu for relevant instructions. Take care to ensure that you select the correct type and version of your browser software.
Unfortunately, if you choose to decline cookies, some of the interactive features and some functionality of our websites and our services may not be available to you. We advise regular users of our websites and services to accept cookies from us.
How to change your browser settings to disable cookies
Microsoft Internet Explorer 6,7,8 (Windows XP/Vista)
1. Select Tools from the main task bar, then Internet Options
2. Click the Privacy tab
3. Choose the settings you want
4. Click OK
Microsoft Internet Explorer 8,9 (Windows 7)
1. Click on the Settings cog icon (top right)
2. Click on the Internet Options
3. Click on the Privacy and choose your options
4. Click Apply and then OK
Firefox 3.0+, 4.0+, 5.0+, 6.0+
1. Choose Tools from the main task bar, then options
2. Click the Privacy tab
3. Choose the settings you want
4. Click OK
Google Chrome
1. Click the menu icon and select Settings from the list
2. Click the Show the advance settings
3. Click Content Settings in the Privacy section
4. Choose the settings you want
5. Click X to close
Mobile Devices iOS
1. From the home screen, choose Settings
2. Select Safari
3. Click Accept Cookies
4. Choose your preferred settings
Android
1. Start the browser application
2. Click the Menu button
3. Select the More option, then Settings
4. Tick or clear Accept cookies
Windows Phone 7
1. From the home screen, click on the right arrow
2. Scroll down to Settings
3. Swipe across and select Internet Explorer
4. Tick or clear Accept cookies
More information
By using our site, as per the EU Cookie Law (http://ec.eurpoa.eu/ipg/basics/legal/cookies/index_en.htm) you are agreeing to these cookies being stored by your browser and their data being shared with the aforementioned services.
If there is something that you arent sure whether you need or not, its usually safer to leave cookies enables in case it does interact with one of the features you use on our site.
However, if you are still looking for more information then you can contact us at email address: [email protected]
Last reviewed 23.05.18
Next review 23.11.18