Customer Privacy Notice
What’s Included In This Privacy Notice?
DTR Medical Ltd is a multi-award-winning company, specialising in the highest quality Sterile Single-use instruments that deliver both patient and clinical value through maintaining exceptional service across a range of different specialities. You can find out more information about us here: www.dtrmedical.com.
This document (our “privacy notice”) sets out information relating to how we use personal information relating to individuals we have dealings with, including customers, subscribers and website users. It also sets out information about what rights individuals have in relation to their personal information and various other matters required under data protection law.
In particular, this privacy notice provides information to individuals about how they can object to our use of their personal information (see here), how they can withdraw any permissions they have given to us to enable us to process their personal information (see here) and how they can make a complaint (see here).
This privacy notice contains the following sections:
Section Heading |
Page Number |
Who Does This Privacy Notice Apply To? | 3 |
What’s Our Approach To Privacy? | 4-5 |
How Will We Use Your Personal Information? | 6-14 |
When Will We Use Your Personal Information For Direct Marketing? | 15 |
When Will We Share Your Personal Information With Others? | 16-19 |
Circumstances In Which We Will Send Your Personal Information Outside The EEA | 20 |
How Do We Keep Your Personal Information Secure? | 20 |
What Rights Do You Have Under Data Protection Law? | 21-23 |
When and How Can You Withdraw Your Consent? | 24 |
How Can You Get In Touch With Us and Who Is Our Data Privacy Manager? | 25 |
How Can You Complain About Our Use Of Your Personal Information? | 25 |
How Will We Notify You Of Any Changes To Our Privacy Notice? | 25 |
Who Does This Privacy Notice Apply To?
This privacy notice applies to:
- our customers;
- individuals who use our website;
- individuals who access our premises or the surrounding areas and who may be recorded on our CCTV system;
- individuals who subscribe to our updates;
In the sections below, when referring to the individuals listed above, we use the terms “you” or “your”.
What’s Our Approach To Privacy?
We take your privacy extremely seriously and want you to feel confident that your personal information is safe in our hands.
We will only use your personal information in accordance with data protection law applicable to England and Wales from time to time.
Under data protection law, when we use your personal information, we will be acting as a data controller. Essentially, this means that we will be making decisions about how we want to use your personal information and why.
Below, we summarise the main rules that apply to us under data protection law when we use your personal information:
1. | We must be upfront about how we intend to use your personal information and must use your personal information fairly. Providing privacy information to individuals (such as in this privacy notice) is one aspect of using personal information fairly. |
2. | We must only use your personal information if we have a legal basis to do so under data protection law. These legal bases include:
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3. | We are only permitted to share your personal information with others in certain circumstances and if we take steps to ensure that your personal information will be secure. |
4. | We must only use your personal information for the specific purposes we have told you about. If we want to use your personal information for other purposes, we need to contact you again to tell you about this. |
5. | We must not hold more personal information than we need for the purposes we have told you about and must not retain your personal information for longer than is necessary for those purposes (this is known as the “retention period”). We must also dispose of any information that we no longer need securely. |
6. | We must ensure that we have appropriate security measures in place to protect your personal information. |
7. | We must act in accordance with your rights under data protection law. |
8. | We must not transfer your personal information outside the European Economic Area (“EEA”) unless certain safeguards are in place. |
How Will We Use Your Personal Information?
How we will use your personal information, the legal bases we will rely upon, how long we will keep your personal information and other details will depend upon who you are and why we need your personal information in the first place.
In this section, we provide specific privacy information relating to the different categories of individuals that this privacy notice applies to.
OUR CUSTOMERS
What personal information we will use |
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How we will obtain the personal information |
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What purposes we will use the personal information for |
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The legal bases for processing we rely upon |
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How long we retain the personal information and why |
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Consequences of not providing/permitting us to obtain personal information |
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INDIVIDUALS WHO CONTACT US WITH ENQUIRIES
What personal information we will use |
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How we will obtain the personal information |
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What purposes we will use the personal information for |
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The legal bases we rely upon |
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How long we retain the personal information and why |
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INDIVIDUALS WHO USE OUR WEBSITE
What personal information we will use |
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How we will obtain the personal information |
We use cookies to:
If users disable cookies in their browser:
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What purposes we will use the personal information for |
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The legal grounds we rely upon |
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How long we retain the personal information and why |
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Consequences of not providing/permitting us to obtain personal information |
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INDIVIDUALS CAPTURED ON OUR CCTV SYSTEM
What personal information will we use? |
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How we will obtain it? |
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What purposes we will use it for and what legal bases will we rely upon to do so? |
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Individuals Who Subscribe To Our Newsletters or Updates
What personal information we will use |
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How we will obtain the personal information |
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What purposes we will use the personal information for |
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The legal grounds we rely upon |
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How long we retain the personal information and why |
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Consequences of not providing/permitting us to obtain personal information |
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When Will We Use Your Personal Information For Direct Marketing?
In addition to data protection law, if we use your personal information for direct marketing purposes, we may also be subject to additional rules that regulate direct marketing. The term “direct marketing” essentially means directing marketing material or advertising at a particular individual.
To ensure compliance with both data protection laws and the specific rules relating to direct marketing, we will only use your personal information to tell you about our latest offers or to inform you of products and services which we think may be of interest to you in the circumstances outlined below:
Direct marketing by email, text or other forms of electronic communication |
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Our legal bases for such processing under data protection law will either be your consent or reliance upon our legitimate interests in developing our business.
We will retain your personal information unless and until you inform us that you no longer wish to receive direct marketing information from us. You can ask us to stop sending direct marketing to you at any time by contacting us on info@dtrmedical.com or by clicking “unsubscribe” on any of our communications with you.
When Will We Share Your Personal Information With Others?
Sometimes, we will need to share your personal information with others. This section sets out details of who we will share your personal information with and why. It also tells you about our legal basis for doing so under data protection law and steps we will take to protect your personal information.
OUR SERVICE PARTNERS
Who are our service partners? |
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Why we need to share your personal information with them |
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The legal bases we rely upon when sharing your personal information |
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What precautions do we take? |
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OUR MARKETING PARTNERS
Who are our marketing partners |
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Why we need to share your personal information with them |
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The legal bases we rely upon when sharing your personal information |
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What precautions do we take? |
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PROVIDERS OF INFORMATION TECHNOLOGY SERVICES
Who will we be sharing your personal information with? |
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Why we need to share your personal information with such providers |
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The legal bases we rely upon when sharing your personal information |
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What precautions do we take? |
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OTHER THIRD PARTIES
We may also need to share your personal information with others in the following circumstances:
If we sell, transfer or merge parts of our business or our assets | As we continue to develop our business we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. During any such process, we may need to disclose your personal information to other parties (such as potential purchasers or investors). Where we do so, we will be relying upon our legitimate business interests.
However, we will only share your personal information in this way if the third parties in question agree to keep your personal information safe and private. Also, if, for example, a merger happens, the purchaser will only be able to use your personal information in the ways set out in this privacy notice. |
Legal or regulatory requirements | On occasion, we may be required to disclose your personal information to organisations such as the courts or the police to comply with legal obligations we are subject to and/or to prevent fraud or crime. |
Protecting our business | From time to time we may need to disclose your personal information in connection with steps we need to take to protect our business interests or property. |
Professional advice and legal action | We may need to disclose your personal information to our professional advisers (for example, our lawyers and accountants) in connection with the provision by them of professional advice and/or the establishment or defence of legal claims. |
Circumstances In Which We Will Send Your Personal Information Outside The EEA
We will only send your personal data outside the EEA in the following situations:
- To our US based cloud storage and secure file sharing platform Dropbox
If we do transfer your personal data outside the EEA, we will use one of these safeguards to make sure it is protected:
- Dropbox has signed up to a special agreement between the UK/EU and the USA known as the Privacy Shield.
HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We take various steps to protect your personal information while it is in our possession, including:
- Implementation of appropriate security measures to protect our IT infrastructure;
- Secure password access;
- Encryption of personal information;
- Implementation of internal data security policies and training for members of staff in relation to such policies, including cyber security awareness training;
- Regular reviews of data security measures implemented by service providers who may handle your personal data;
- Offsite backups are encrypted and stored in ISO accredited data centres;
- Different levels of user access permissions so that users only have access to certain data.
You can help us to protect your personal information by adhering to the following security measures:
- When creating a password, do not use words such as your name, date of birth or other personal data;
- Change your password regularly. Do not reuse passwords, these should be at least 8 characters including upper- and lower-case letters, numbers and symbols.
- Passwords are kept private and do not write these down.
- Try and keep a clean work-space and any sensitive data is not left on desks
- Do not use the same password for different services i.e. Dropbox, Facebook, Twitter etc.
What Rights Do You Have Under Data Protection Law?
Under data protection law, you have a number of different rights relating to the use of your personal information. The table below contains a summary of those rights and our obligations. More information about your rights and our obligations can be found on the ICO website https://ico.org.uk/.
Your rights | What this involves | What our obligations are |
A right of access | This is a right to obtain access to your personal data and various supplementary information. | We must provide you with a copy or your personal information and the other supplementary information without undue delay and in any event within 1 month of receipt of your request;
We cannot charge you for doing so save in specific circumstances (such as where you request further copies of your personal information). |
A right to have personal data rectified | This is a right to have your personal information rectified if it is inaccurate or incomplete. | We must rectify any inaccurate or incomplete information without undue delay and in any event within 1 month of receipt of your request;
If we have disclosed your personal information to others, we must (subject to certain exceptions) contact the recipients to inform them, that your personal information requires rectification. |
A right to erasure | This is a right to have your personal information deleted or removed.
This right only applies in certain circumstances (such as where we no longer need the personal information for the purposes for which it was collected). We have the right to refuse to delete or remove your personal data in certain circumstances. |
If this right applies, we must delete or remove your personal information without undue delay and in any event within 1 month of receipt of your request;
If we have disclosed your personal information to others, we must (subject to certain exceptions) contact then recipients to inform them that your personal information must be erased. |
A right to data portability | This is a right to obtain and re-use your personal information for your own purposes;
It includes a right to ask that your personal information is transferred to another organisation (where technically feasible). This right only applies in certain limited circumstances. |
If this right applies we must provide your personal information to you in a structured, commonly used and machine reasonable form
Again, we must act without undue delay and in any event within 1 month of receipt of your request; We cannot charge you for this service. |
A right to object | This is a right to object to the use of your personal information.
The right applies in certain specific circumstances only. You can use this right to challenge our use of your personal information based on our legitimate interests; You can also use this right to object to use of your personal information for direct marketing |
If you object to us using your personal information for direct marketing, we must stop using your personal information in this way as soon as we receive your request.
If you object to other uses of your personal information, whether we have to stop using your personal information will depend on the particular circumstances. |
A right to object to automated decision making | This is a right not to be subject to a decision which is made solely on the basis of automated processing of your personal information where the decision in question will have a legal impact on you or a similarly significant effect. | Where such a decision is made, you must be informed of that fact as soon as reasonably practicable;
You then have 21 days from receipt of the notification to request that the decision is reconsidered or that a decision is made that is not based solely on automated processing; Your request must be complied with within 21 days. |
A right to restrict processing | This is a right to ‘block’ or suppress processing of your personal information.
This right applies in various circumstances, including where you contest the accuracy of your information). |
If we are required to restrict our processing of your personal information, we will be able to store it but not otherwise use it.
We may only retain enough information about you to ensure that the restriction is respected in future. If we have disclosed your personal information to others, we must (subject to certain exceptions) contact them to tell them about the restriction on use. |
If you wish to exercise any of your rights, you can make a request by contacting us using the details set out here: info@dtrmedical.com.
If you request the exercise of any of your rights, we are entitled to ask you to provide us with any information that may be necessary to confirm your identity.
Your Right To Withdraw Consent
If you have given us your consent to use any of your personal information, you can withdraw your consent at any time. To do so, please contact us using the details set out here: info@dtrmedical.com.
How Can You Get In Touch With Us and Who Is Our Data Privacy Manager?
You can get in touch with us in the following ways:
Postal address | DTR Medical Limited,
17 Clarion Court, Enterprise Park, Swansea, United Kingdom, SA6 8RF |
Email address | info@dtrmedical.com |
Phone number
Fax Number |
+44 1792 797910
+44 1792 797955 |
We have appointed a Data Privacy Manager to oversee our compliance with data protection law and this privacy notice. His details are as follows esheppard@dtrmedical.com. If you have any questions about this privacy notice, how we handle your personal information or if you wish to make a complaint, please contact our Data Privacy Manager.
Right To Complain To The Information Commissioner’s Officer
If we are unable to deal with a complaint to your satisfaction or if you are unhappy with the way we are using your personal data, you also have the right to make a complaint at any time to the UK’s supervisory authority for data protection issues, the Information Commissioner’s Office.
Changes To Our Privacy Notice
We may update this privacy notice from time to time. If we make any substantial updates, we will provide you with a new privacy notice. We may also notify you in other ways from time to time about the processing of your personal information.