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Privacy Notice

The Campbell academy privacy notice

 
WHAT IS THE PURPOSE OF THIS DOCUMENT?  

The Campbell Academy is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use your personal information, in accordance with the General Data Protection Regulation (GDPR).

The Campbell Academy is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. 

This notice applies to current and former patients of The Campbell Academy. This notice does not form part of any contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.  A copy of the full GDPR Policy and Procedure is available for review at the Practice/Entity.

 

1.    DATA PROTECTION PRINCIPLES  

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

 

2.    THE KIND OF INFORMATION WE HOLD ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We will collect, store, and use the following categories of data;

  1. Personal contact details such as name, gender, title, addresses, telephone numbers, occupation, and personal email addresses.
  2. We collect usage data about you whenever you interact with our services. This may include which web pages you visit, what you click on, when you performed those actions, and so on.
  3. The Campbell Academy collects data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
  4. If you arrive at a The Campbell Academy website from an external source (such as a link on another website or in an email), we will record information about the source that referred you to us.

This list is not exhaustive.

 

3.         HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about you directly from you as a result of attending one of our courses or events, through subscribing to Colin Campbell’s blog, or we will collect additional personal information in the course of marketing activities carried out by The Campbell Academy. We may also collect information directly from third parties.

 

4.         HOW WE WILL USE INFORMATION ABOUT YOU   

We will only use your personal information when the law allows us to. Generally, we use the information collected in connection with providing our services to you. Most commonly, we will use your personal information in the following circumstances.

  1. To process bookings at one of our courses or events.
  2. To contact you for marketing purposes only if you have consented to our contacting you for this purpose.
  3. To contact you if you make an enquiry through our website.
  4. To contact you with Colin Campbell’s blog only if you have consented to receiving this blog.
  5. Where we need to comply with a legal obligation.
  6. 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.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest or for official purposes

 

5.         IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing dentistry services or providing any other associated benefit), or we may be prevented from complying with our legal obligations (such as health and safety).

 

6.         CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

7.    DO WE NEED YOUR CONSENT?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of health and safety law.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

 

8.  HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION  

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards, which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations or exercise rights in connection with providing our services.
  • Where it is needed in the public interest, such as Government Department monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about patients or former patients in the course of legitimate business activities with the appropriate safeguards.

  • Details regarding your personal identification such as your physical condition. This includes x-ray imaging, genetic and biometric data.
  • Information concerning your medical history, including physical and/or mental condition and your oral health or condition.
  • Information about discussions undertaken and agreements reached on treatment options, including costs of any proposed treatment.
  • Information about the treatment that is planned, is being undertaken or has been provided.
  • Information about family members and personal circumstances supplied by you or others.
  • The amount that was paid for treatment, the amount owing, or the fact that the patient is a debtor to The Campbell Clinic Limited.

 

10.   AUTOMATED DECISION-MAKING  

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
  2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

 

11.  DATA SHARING  

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to deliver a service to you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

Hotjar - We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy here - https://www.hotjar.com/legal/policies/privacy

HubSpot – We use the HubSpot service to build webpages that our customers can visit to learn more about our business. HubSpot processes our customers' information as we direct and in accordance with our agreements with our customers. HubSpot stores it on their service providers' servers, but they do not have control over its collection or management. HubSpot’s agreement with us prohibits them from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Privacy Policy, and as required by law. For more information please see https://legal.hubspot.com/privacy-policy

JotForm – We use JotForm to deliver your details using the contact form you submit to us. Your information will remain within JotForms database for as long as we continue to use JotForms services for our contact forms. For more information, please see https://www.jotform.com/privacy/

Google Analytics – We use Google Analytics to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you. Google Analytics also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this.

Disabling cookies on your internet browser will stop Google Analytics from tracking any part of your visit to pages within this website.

Read Google's overview of privacy and safeguarding data

Read Google Analytics use of cookies - Google’s developer guides

Yelloveedub – We use Yelloveedub as our marketing agency. Yelloveedub assists The Campbell Academy with our website and our digital marketing. For further details, please see Yelloveedub’s privacy policy in the footer of their website here - https://www.yelloveedub.com

Stripe – We use Stripe to receive payments over the internet as they provide the technical, fraud prevention, and banking infrastructure required to operate on-line payment systems. Stripe collects data about our customers when they make a payment on our website. For more information, please see https://stripe.com/gb/privacy

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

What about cookies?

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We may also use trusted third-party services that track this information on our behalf.

Most web browsers allow some control of most cookies through the browser settings. Every browser is different, look at your browser's Help Menu to learn the correct way to modify your cookies. If you turn cookies off, some features may be disabled.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

 

12.        DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information by other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention  

How long will you use my information for?

We will store your usage data until such time when you withdraw your consent for us to do so. All other data as listed under point ‘2’ will be retained for as long as is necessary for the purpose(s) for which we originally collected it. We may also retain information as required by law.

 

13.     RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

13.1 YOUR DUTY TO INFORM US OF CHANGES

 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

 

13.2 YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Tom Reason, General Manager of The Campbell Academy in writing or email at tom@campbellacademy.co.uk.

14.      NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

15.     WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

16.     RIGHT TO WITHDRAW CONSENT  

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent please contact Tom Reason, General Manager of The Campbell Academy - tom@campbellacademy.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. You can unsubscribe from receiving marketing information or Colin Campbell’s at any time.

 

17.     DATA PROTECTION OFFICER  

We have appointed Tom Reason as our Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

 

18.     CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

19.     INFORMATION PUBLISHED BY THE CAMPBELL ACADEMY LIMITED

Health and care research should serve the public interest, which means that we have to demonstrate that our research serves the interests of society as a whole. We do this by following the UK Policy Framework for Health and Social Care Research.

We use personally-identifiable information to conduct research to improve health and care. As a dental education provider, we have a legitimate interest in using information relating to your health and care for research studies, when you agree to take part in our research studies. This means that we will use your data, collected and stored in our research database, in the ways needed to conduct and analyse research studies. Your rights to access, change or move your information are limited, as we need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw your consent, we will keep the information about you that we have already obtained. To safeguard your rights, we will use the minimum personally-identifiable information possible. Processing of your data for research purposes has been approved by a Research Ethics Committee, and this is reviewed annually.

When you agree to take part in a research study (research database), the information about your health and care may be provided to researchers running other research studies in this organization and other organisations. These organisations may be universities, NHS organisations or companies involved in health and care research in this country or abroad. Your information will only be used by organisations and researchers to conduct research in accordance with the  UK Policy Framework for Health and Social Care Research.

This information will not identify you and will not be combined with other information in a way that could identify you. The information will only be used for the purpose of health and care research and cannot be used to contact you or to affect your care. It will not be used to make decisions about future services available to you, such as insurance.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO).

 

If you have any questions regarding our Privacy Notice please do get in touch.
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