The Hearing Care Centre (THCC) is an independent hearing care specialist. You can learn more about us here. THCC is committed to protecting your data privacy.
This privacy notice explains what personal data we collect and how it is used. It also explains your rights and how to contact us if you have any further questions.
Personal data or personal information means any information from which that person can be identified. It does not include where the identity has been removed (anonymous data).
We always aim to minimise the amount of personal data we collect. This means the personal data we have will vary based on your relationship with us. Your privacy is important to us.
The information provided by you or that we learn from your hearing test, from any purchase of our products or services or through any other interaction with us will be held in the strictest confidence.
Health care information will be used by THCC to provide you with the best possible care and will be handled at all times in a way that is consistent with Health and Care Professions Council (HCPC) and British Society of Hearing Aid Audiologists (BSHAA) standards. For example we only use regulated Hearing Aid Dispensers that are all trained in the importance of maintaining patient confidentiality.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to carry out the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
The rest of this notice explains in more detail what information we collect, why we collect it and how it is used. It also explains your rights and how to contact us.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity, contact and financial data by filing in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account with us;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Third Parties. We may receive personal data about you from GPs, and other health professionals.
Why do we process your personal data and under what legal basis?
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:
Where we need to fulfil a contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal obligation;
When you provide us with your consent.
If you are a customer we have to keep clear and accurate records about your care. This is part of good health care, and is what the health care regulator expects of our qualified hearing care professionals.
We only keep your health records for as long as necessary. This will vary depending on your specific relationship with us. For example if you are an existing client we will keep all your records to ensure we continue to meet our duty of care, but if you have not seen us for 8 years we will consider securely destroying your records. A link to our data retention policy can be found here.
If you have purchased products from us, or attended one of our local events, but not seen us for any health care, then we will keep the minimum amount of personal data on you. This will be to ensure we provide you with a good customer experience and meet our other obligations. We will not keep this data for longer than necessary. We use the following lawful basis for processing such data: legitimate interest.
If you call us, visit us or enter our website, you might be asked to provide consent for us to collect and process your personal data to send marketing related information that we feel is relevant to you and your hearing. Our consent process is designed to ensure you get to choose whether you want this and you always have the right to withdraw your consent. We use the following lawful basis for processing such data: consent.
In carrying out our services for you we are likely to be processing information relating to your health. This is a special category of personal data which requires us to observe additional data protection requirements. The additional condition which we rely on is that the processing is carried out for the purposes of the provision of healthcare, subject to appropriate safeguards.
Information we might collect depending on your specific relationship with us:
your date of birth
your contact telephone numbers (including mobile)
your email and postal address
your relevant health details including current hearing issues, general health condition, correspondence between audiologist and your GP.
your test results
your payment details
your lifestyle information
details of any hearing instrument recommendation or purchase.
details of your visit to the website and any transactions you carry out on the website.
How we might use your personal data depending on your specific relationship with us:
hearing care treatment
providing our products and services to you
contacting you regarding your ongoing care. For example letting you know when your next appointment is due and reminding you to book a test
we may occasionally conduct customer care surveys. These surveys are optional. We will not share any data provided with third parties
notifying you about changes to our services and products
responding to enquiries received from you
processing and retaining your payment and order details to facilitate your purchase and to deal with any queries or refunds of payment
we may undertake credit checks with your explicit permission
maintaining records for tax, compliance with laws, defence of claims and other corporate purposes
managing and administrating insurance claims
for marketing to potential customers where they have given consent
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out above:
GPs and other Health Professionals
Service providers who provide IT and system administration services
Professional Advisory Services such as lawyers, bankers, auditors and insurers
HM Revenue and Customs, regulators and other authorities
Hearing aid suppliers
We do not transfer your personal data outside the European Economic Area.
We work hard to protect your data from unauthorised access or disclosure and keeping it private and safe. We hold your personal information on a secure server that is protected by multiple passwords, accessed only by authorised staff, firewalled, antivirus, and spyware protected.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Other rights: you have rights to data portability and in relation to automated decision making and profiling. Our current business model means these rights do not apply to the personal data we hold. We will keep this under review and update our privacy notice if our business model changes.
You may exercise any of the above rights by contacting us. We might, depending on the nature of your request, need proof of your identity. This might include a copy of a passport page, ID card or other valid document we can use to identify you.
Our aim is to be clear about what information we collect and your rights. This section explains your rights at a high level. If you have any addition questions please do contact us on the details below or visit us in store.
If you have any questions about this privacy notice or would like to exercise any of your rights please contact our data protection lead Karen Finch, Managing Director.
The Hearing Care Centre Ltd, 11 Upper Brook Street, Ipswich, Suffolk, IP4 1EG
By email: firstname.lastname@example.org
Or telephone: 01473 230330
If you have a concern about the way in we handle your data, you may also wish to contact the Information Commissioner’s Office (ICO), which is the supervisory body for ensuring compliance with data protection regulation in the UK.
We reserve the right to update and change this privacy notice and cookies policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our notice.
This page was last updated on 10 April 2019