Privacy Policy - Crowthrone Dental

Privacy Notice

Information about Crowthorne Dental Centre

In this privacy notice, ‘we’, ‘us’ and ‘our’ mean Crowthorne dental. Visit https://www.crowthornedental.co.uk/privacy-policy/ to find out more.

Depending on which of our products and services you ask us about, buy or use, different companies within our organisation will process your information. Visit https://www.crowthornedental.co.uk/privacy-policy/ to find out more about the companies that handle your information based on the products and services you access or use.

Scope of our privacy notice

This privacy notice applies to anyone who interacts with us about our products and services (‘you’, ‘your’), in any way (for example, by email, through our website, by phone, through our app). We will give you further privacy information if necessary for specific contact methods or in relation to specific products or services. For example, if you use our apps we may give you privacy notices which apply just to a particular type of information which we collect through that app.

If you have any questions about this, please contact us at email@crowthornedental.co.uk

How we collect personal information

We collect personal information from you and from third parties (anyone acting on your behalf, for example, brokers, health-care providers and so on). Please see below for more information.

Where you provide us with information about other people, you must make sure that they have seen a copy of this privacy notice and are comfortable with you giving us their information.

We collect personal information from you:

through your contact with us, including by phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes), by email, through our websites, through our apps, by post, by filling in application or other forms, by entering competitions, through social media or face-to-face (for example, in medical consultations, diagnosis and treatment).

We also collect information from other people and organisations.

For all our customers, we may collect information from:

your parent or guardian, if you are under 18 years old;
a family member, or someone else acting on your behalf;
doctors, other clinicians and health-care professionals, hospitals, clinics and other health-care providers;
any service providers who work with us in relation to your product or service, if we don’t provide it to you direct, such as providing you with apps, medical treatment, dental treatment or health assessments;
organisations who carry out customer-satisfaction surveys or market research on our behalf, or who provide us with statistics and other information (for example, about your interests, purchases and type of household) to help us to improve our products and services;
fraud-detection and credit-reference agencies; and
sources which are available to the public, such as the edited electoral register or social media.

If we provide you with insurance products and services, we may collect information from:

the main member, if you are a dependant under a family insurance policy;
your employer, if you are covered by an insurance policy your employer has taken out;
brokers and other agents (this may be your broker if you have one, or your employer’s broker if they have one); and
other third parties we work with, such as agents working on our behalf, other insurers and reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies (including health-insurance counter-fraud groups), regulators, data-protection supervisory authorities, health-care professionals, other health-care providers and medical-assistance providers.

If we provide you with health-care, dental or care-home services, we may collect information from:

your employer, if you are covered by a contract for services your employer has taken out or if we are providing occupational health services;
brokers and other agents (this may be your broker if you have one, or your employer’s broker if they have one); and
those paying for the products or services we provide to you, including other insurers, public-sector commissioners and embassies.

Categories of personal information

For all our services , we process the following categories of personal information about you and (where this applies) your dependants:

standard personal information (for example, information we use to contact you, identify you or manage our relationship with you)
special categories of information (for example, health information, information about your race, ethnic origin and religion that allows us to tailor your care; and
information about criminal convictions and offences (we may get this information when carrying out anti-fraud or anti-money-laundering checks, or other background screening checks to prevent crime).

For more information about these categories of information, see below.

Standard personal information includes:

contact information, such as your name, username, address, email address and phone numbers;
the country you live in, your age, your date of birth and national identifiers (such as your National Insurance number or passport number);
information about your employment;
details of any contact we have had with you, such as any complaints or incidents;
financial details, such as details about your payments and your bank details;
the results of any credit or any anti-fraud checks we have made on you;
information about how you use our products and services, such as insurance claims; and
information about how you use our website, apps or other technology, including IP addresses or other device information (please see our Cookies Policy for more details).

Special category information includes:

information about your physical or mental health, including genetic information or biometric information (we may get this information from application forms you have filled in, from notes and reports about your health and any treatment and care you have received or need, or it may be recorded in details of contact we have had with you such as information about complaints or incidents, and referrals from your existing insurance provider, quotes and records of medical services you have received);
information about your race, ethnic origin and religion (we may get this information from your medical or care-home preferences to allow us to provide care that is tailored to your needs).

What we use your personal information for and our legal reasons for doing so

We process your personal information for the purposes set out in this privacy notice. We have also set out some legal reasons why we may process your personal information (these depend on what category of personal information we are processing). We normally process standard personal information if this is necessary to provide the services set out in a contract, it is in our or a third party’s legitimate interests or it is required or allowed by any law that applies. Please see below for more information about this and the reasons why we may need to process special category information.

By law, we must have a lawful reason for processing your personal information. We process standard personal information about you if this is:

necessary to provide the services set out in a contract − that is, to provide you and your dependants with our products and services);
in our or a third party’s legitimate interests − details of those legitimate interests are set out in more detail in the ‘Legitimate Interest’ section below. or
required or allowed by law.

We process special category information about you because:

it is necessary for the purposes of preventive or occupational medicine, to assess whether you are able to work, medical diagnosis, to provide health or social care or treatment, or to manage health-care or social-care systems (including to monitor whether we are meeting expectations relating to our clinical and non-clinical performance);
it is necessary for an insurance purpose (for example, advising on, arranging, providing or managing an insurance contract, dealing with a claim made under an insurance contract, or relating to rights and responsibilities arising in connection with an insurance contract or law);
it is necessary to establish, make or defend legal claims (for example, claims against us for insurance);
it is necessary for a purpose designed to protect the public against dishonesty, malpractice or other seriously improper behaviour (for example, investigations in response to a safeguarding concern, a member’s complaint or a regulator (such as the Care Quality Commission or the General Medical Council) telling us about an issue);
it is in the public interest, in line with any laws that apply;
it is information that you have made public; or
we have your permission. As is best practice, we will only ask you for permission to process your personal information if there is no other legal reason to process it. If we need to ask for your permission, we will make it clear that this is what we are asking for and ask you to confirm your choice to give us that permission. If we cannot provide a product or service without your permission (for example, we can’t manage and run a health trust without health information), we will make this clear when we ask for your permission. If you later withdraw your permission, we will no longer be able to provide you with a product or service that relies on having your permission.

We may process information about your criminal convictions and offences (if any) as a result of anti-fraud and anti-money-laundering checks or to check other unlawful behaviour or carry out investigations with other insurers and third parties for the purpose of detecting fraud. We do this if it is necessary to prevent or detect a crime.

Legitimate Interest

We process your personal information for a number of legitimate interests, including managing all aspects of our relationship with you, for marketing, to help us improve our services and products and in order to exercise our rights or handle claims. More detailed information about our legitimate interests is set out below.

Taking into account your interests, rights and freedoms, legitimate interests which allow us to process your personal information include:

to manage our relationship with you, our business and third parties who provide products or services for us (for example, to check that you have received a service that you’re covered for, to validate invoices and so on);
to provide health-care services on behalf of a third party (for example, your employer);
to make sure that claims are handled efficiently and to investigate complaints (for example, we may ask your treatment provider for information to make sure we receive accurate information and to monitor the quality of your treatment and care);
to keep our records up to date and to provide you with marketing as allowed by law;
to develop and carry out marketing activities and to show you information that is of interest to you, based on our understanding of your preferences (we combine information you give us with information we receive about you from third parties to help us understand you better);
for statistical research and analysis so that we can monitor and improve products, services, websites and apps, or develop new ones;
to contact you about market research we are carrying out;
to monitor how well we are meeting our clinical and non-clinical performance expectations in the case of health-care providers;
to enforce or apply our website terms of use, our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property or safety;
to exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with; and
to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part of crowthorne dental centre.

Marketing and preferences

We may use your personal information to send you marketing by post, by phone, through social media, by email and by text.

We can only use your personal information to send you marketing material if we have your permission or a legitimate interest as described above.

If you don’t want to receive emails from us, you can click on the ‘unsubscribe’ link that appears in all emails we send. If you don’t want to receive texts from us you can tell us by contacting us at any time. Otherwise, you can always contact us by email to update your contact preferences.

You have the right to object to direct marketing and profiling (the automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests) relating to direct marketing. Please see the section about your rights for more details.

Processing and automated decision making

Like many businesses, we sometimes use automation to provide you with a quicker, better, more consistent and fair service, and marketing information we think will be of interest to you (including discounts on our products and services). This will involve evaluating information about you and, in some cases, using technology to provide you with automatic responses or decisions (automated decisions). You can click below for more information about this.

You have the right to object to direct marketing and profiling relating to direct marketing. You may also have the right to object to other types of profiling and automated decision-making set out below. In these cases, you have the right to ask us to make sure that one of our advisers reviews an automated decision, to let us know how you feel about it and to ask us to reconsider the decision. You can contact us to exercise these rights.

By law, we must tell you about:

automated decision-making (making a decision using technology, without any person being involved); and
profiling (automated processing of your information to help us evaluate certain things about you, for example, your personal preferences and your interests).

This is because you have certain rights relating to both automated decision-making and profiling. You have the right to object to profiling relating to direct marketing. If you do this, we will no longer carry out profiling for direct marketing purposes. You also have the right to object to profiling in other circumstances set out below.

When we make decisions using only automated processing which produce legal effects which concern you or which have a significant effect on you, we will let you know. You then have 21 days to ask us to reconsider our decision or to make a new decision that is not based only on automated processing. If we receive a request from you, within 21 days of receiving your request, we will:

consider the request, including any information you have provided that is relevant to it;
meet your request; and
let you know in writing what we have done to meet your request, and the outcome.

You can contact us to ask about these rights. For more information on all your rights, please read the ‘Your rights’ section below.

Profiling and automated decision-making

The processes set out below, which only apply to our insurance products and services, involve both profiling and automated decision-making.

Depending on the type of health-insurance product that you want to benefit from, to help us decide what level of cover we can offer you, we will ask you to provide information about your medical history. We may use software to review this information to find out whether you have any previous or existing health conditions which we cannot cover you for and which will be excluded from your policy.
We may use software to help us calculate the price of products and services based on what we know about you and other customers. For example, our technology may analyse information about your claims history and compare it with the information we hold about previous claims to evaluate how likely you are to need to make a claim. We may also evaluate your age, where you live and other details relating to your health (such as existing health conditions and whether you smoke) to calculate prices for community-rated products which are based on predefined groups with similar risk profiles.

Profiling

For all our services, the processes set out below involve profiling.

In order to improve outcomes and be more efficient, and allow us to offer advice about different treatment paths (for example, alternatives to surgery or other invasive treatments), we may use software to evaluate medical history and information about the general population in an area to identify customers who are likely to need that advice most.
When your policy is due for renewal, our software tells us this and may also evaluate your payment and claims history, other information you have given us about yourself, and other information we have received from third parties, to automatically provide you with a renewal quote and to decide what incentives we can offer you and the marketing messages you will receive.
We ask other organisations to carry out some of our consumer and market analysis to improve our marketing processes. This involves sharing personal information relating to our customers with third parties who specialise in profiling and segmenting people (putting people into groups of different types of customer, based on different kinds of information collected about them, to help us to better target our products to them). These companies match the information we give them with information they get from other sources to improve the accuracy of their analysis. We use the results of this analysis to help us target marketing and offers.
We may use information about the products you have bought, and information about what other customers who have bought the same products you have bought, to make sure we send you information about the products you are most likely to be interested in.
We may share your personal information (including your name, date of birth, sex and the country you live in) with third-party companies who carry out fraud checks. We will review any matches from this process. (We will not use automated decision-making for this.)

Sharing your information

We share your information within Crowthorne Dental Centre , with relevant policyholders (including your employer if you are covered under a group scheme), with funders arranging services on your behalf, with people acting on your behalf (for example, brokers and other agents) and with others who help us provide services to you (for example, health-care providers and medical-assistance providers) or who we need information from to allow us to handle or confirm claims or entitlements (for example, professional associations). We also share your information in line with the law. For more information about who we share your information with, please see below.

We sometimes need to share your information with other people or organisations for the purposes set out in this privacy notice. The exact information we share depends on the reason we are sharing it. For example, if we need to share information in order to provide health care, we will share special categories of information, such as medical details, with the treatment provider.

For all our customers, we share your information with:

other members of the Crowthorne Dental Centre ’ in order to provide our products and services to you;
other organisations you belong to, or are professionally associated with, in order to confirm your entitlement to claim discounts on our products and services;
doctors, clinicians and other health-care professionals, hospitals, clinics and other health-care providers so that they can provide treatment;
suppliers who help deliver products or services on our behalf;
people or organisations we have to, or are allowed to, share your personal information with by law (for example, for fraud-prevention or safeguarding purposes, including with the Care Quality Commission);
the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order;
organisations that carry out surveys on our behalf;
if we (or any member of theCrowthorne Dental Centre) sell or buy any business or assets, the potential buyer or seller of that business or those assets; and
a third party who takes over any or all of the Crowthorne Dental Centre
‘ assets (in which case personal information we hold about our customers or visitors to the website may be one of the assets the third party takes over).

If we provide insurance or manage a health-care trust, we share your information with:

the policyholder or their agent if you are not the main member under an individual policy (we will send them all membership documents and confirmation of how we have dealt with a claim, and all people who are insured on the policy may have access to correspondence and other information we provide through our online portal);
your employer (or their broker or agent) for product or service administration purposes if you are a member or beneficiary under your employer’s group scheme;
your broker or agent (or both);
other third parties we work with to provide our products and services, such as agents working on our behalf, other insurers and reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies (including health-insurance counter-fraud groups), regulators, data-protection supervisory authorities, health-care professionals, health-care providers and medical-assistance providers; and
organisations who provide your treatment and other benefits, including travel-assistance services.

If we provide health-care, dental and care-home services, we share your information with:

your employer, if your employer is paying for the services we are providing;
our insurance partners, for example, brokers, reinsurers, actuaries, auditors, solicitors, translators and interpreters, tax advisers, debt-collection agencies, credit-reference agencies, fraud-detection agencies, regulators, data-protection supervisory authorities;
those paying for the products or services we provide to you, including insurers, public-sector commissioners and embassies;
those providing your treatment and other benefits;
current or former Crowthorne Dental Centre
consultants involved in legal proceedings (for example, those relating to negligence or malpractice);
national registries such as the Cancer Registry;
national screening databases, such as the NHS Cervical Screening recall system; and
government authorities and agencies, including the Health Protection Agency (for infectious diseases such as TB and meningitis).

If we share your personal information, we will make sure appropriate protection is in place to protect your personal information in line with data-protection laws.

Anonymised and combined information

We support ethically approved clinical research. We may use anonymised information (with all names and other identifying information removed) or information that is combined with other people’s information, or reveal it to others, for research or statistical purposes. You cannot be identified from this information and we will only share the information in line with legal agreements which set out an agreed, limited purpose and prevent the information being used for commercial gain.

Transferring information outside the European Economic Area (EEA)

We deal with many international organisations and use global information systems. As a result, we transfer your personal information to countries outside the EEA (the EU member states plus Norway, Liechtenstein and Iceland) for the purposes set out in this privacy notice. Not all countries outside the EEA have data-protection laws that are similar to those in the EEA and if so, the European Commission may not consider those countries as providing an adequate level of data protection.

We take steps to make sure that, when we transfer your personal information to another country, appropriate protection is in place, in line with data-protection laws. Often, this protection is set out under a contract with the organisation who receives that information. For more information about this protection, please contact us at email@crowthornedental.co.uk

How long we keep your personal information

We keep your personal information in line with set periods calculated using the following criteria.

How long you have been a customer with us, the types of products or services you have with us, and when you will stop being our customer.
How long it is reasonable to keep records to show we have met the obligations we have to you and by law.
Any time limits for making a claim.
Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations.
Any relevant proceedings that apply.

If you would like more information about how long we will keep your information for, please contact us at email@crowthornedental.co.uk

Your rights

You have the right to access your information and to ask us to correct any mistakes and delete and restrict the use of your information. You also have the right to object to us using your information, to ask us to transfer information you have provided, to withdraw permission you have given us to use your information and to ask us not to use automated decision-making which will affect you. For more information, see below.

You have the following rights (certain exceptions apply).

Right of access: you have the right to make a request for details of your personal information and a copy of that personal information
Right to rectification: you have the right to have inaccurate information about you corrected or removed
Right to erasure (‘right to be forgotten’): you have the right to have certain personal information about you deleted from our records
Right to restriction of processing: you have the right to ask us to use your personal information for restricted purposes only
Right to object: you have the right to object to us processing (including profiling) your personal information in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your information for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.
Right to data portability: you have the right to ask us to transfer the personal information you have given us to you or to someone else in a format that can be read by computer.
Right to withdraw consent: you have the right to withdraw any permission you have given us to handle your personal information. If you withdraw your permission, this will not affect the lawfulness of how we used your personal information before you withdrew permission, and we will let you know if we will no longer be able to provide you with your chosen product or service.
Right in relation to automated decisions: you have the right not to have a decision which produces legal effects which concern you or which have a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this. We will let you know if we make automated decisions, our legal reasons for doing this and the rights you have.

Please note: Other than your right to object to us using your information for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute. This means they do not always apply in all cases, and we will let you know in our correspondence with you how we will be able to meet your request relating to your rights.

If you make a request, we will ask you to confirm your identity if we need to, and to provide information that helps us to understand your request better. We have 21 days to respond to requests relating to automated decisions. For all other requests we have one month from receiving your request to tell you what action we have taken.

In order to exercise your rights please contact email@crowthornedental.co.uk

Data protection contacts

If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact our Privacy Team at email@crowthornedental.co.uk . You can also use this address to contact our Data Protection Officer.

If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process information about you, please contact our Privacy Team at email@crowthornedental.co.uk. You can also use this address to contact our Data Protection Officer.

You also have a right to make a complaint to your local privacy supervisory authority. Our main establishment is in the UK, where the local supervisory authority is the Information Commissioner:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire, United Kingdom

SK9 5AF

Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

You can also make a complaint with another supervisory authority which is based in the country or territory where:

you live; you work; or the matter you are complaining about took place.

Cookies

When you use our sites, we and third-party companies collect information by using cookies and other technologies such as pixel tags (for simplicity we refer to all such technologies as ‘cookies’). A cookie is a text file containing small amounts of information which a server may download to your computer, mobile or tablet when you visit a website or use an app. A pixel tag (sometimes called a web beacon) is an invisible image with a line of code which is placed within an email message or on a web page.

There are different types of cookies which are used to do different things. These include letting you navigate between different pages on a website efficiently, remembering preferences you have given and helping us to identify ways to improve your overall site experience. Others are used to provide you with advertising, which is more tailored to your interests, or to measure the number of site visits and the most popular pages. To find out more about cookies visit aboutcookies.org or allaboutcookies.org.

To help you understand the different types of cookies we use on this website and what they do, we have grouped cookies into four categories as described in the ‘Cookies used on our sites’ section below. To see the cookies used on this site that fall into these categories, to control the types of cookies used and to see how long the cookies last, please use our cookies management tool.

Information collected via cookies and other technology

The cookies used on this site do not collect directly identifiable personal information such as name, address, email address etc. However, certain cookies may collect information which relate to a unique ID or another identifier which, when combined with other information, allow a profile to be created. This profile is used to target adverts to your interests. This ad personalisation is explained more detail in the section below.

Cookies used on our sites

We have grouped the cookies used on our sites into four categories as set out below. As well the cookies we use, we work with third-party companies who place cookies on your device. For a list of third parties we use, please see our cookies management tool. Please note that the data they collect may also be subject to their privacy policies.

When working with third-party companies we take steps to protect your data. For example, we place contractual limits on how data collected about people using our services is used and we regularly audit our sites to make sure only cookies we have authorised are being used.

1. Necessary cookies

These cookies let you move around the website and use essential features such as accessing secure areas of the website and identifying you as being logged in. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet. As these cookies are necessary for the correct functioning of our website, you are unable to control their use from within the cookies management tool.

2. Analytics cookies

These cookies collect information about how visitors use our websites including details of the site where the visitor has come from (e.g. referring domains, search engines, marketing campaigns), pages viewed, the site path of the visitor, which content visitors are clicking on, which products visitors are interested in and purchase and the total number of times a visitor has been to our website.

We use the information to improve our website and enhance the experience of its visitors. We may share this information with analytics and search engine providers that assist us in the improvement and optimisation of our site.

3. Functionality cookies

These cookies allow our websites to remember choices you make (such as your username, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

4. Advertising cookies

These cookies are used to collect information about your browsing habits to deliver advertising more relevant to you and your interests. The personalisation of ads may be based on data collected about your use of our services (for example what pages you visit) and other data attributed to you by the ad platform. These include data points such as interests, age, gender and similar statistical characteristics inferred from internet browsing or marketing data that an advertiser holds about you.

To personalise our advertising and web experiences, unique identifiers such as an ID stored by a Cookie, or a Mobile Ad ID are used to help create an ad profile. These are unique codes set on your device’s mobile operating system. Data that identifies you directly, such as name, mobile number or email address is not collected by the cookies or used for the purposes of advertising.

We work with carefully selected partners to show both personalised and non-personalised ads. These partners include advertising agencies and tech platforms who perform data analysis to enable personalised ad delivery and tracking. These companies may also use data collected from cookies dropped by other websites you have browsed on your device. This enables the display of ads based on your browsing behaviour, which may mean the ads you see are more relevant to your interests. This can also help to limit the frequency of adverts you see across the internet if you have already seen a particular ad.

These partners may use a process called cookie syncing to process data from other sources, including your browsing of other websites, to infer what type of ad might interest you. This activity is performed by matching the cookie ID assigned to your device with another cookie ID likely attributable to you but held in a different database. To find out more about how ad personalisation works please visit https://www.youronlinechoices.com/

How can you control the use of cookies?

You can control the use of cookies at any time by using our cookies management tool. Alternatively, you can use your browser settings to manage cookies including deleting cookies previously stored and blocking cookies from being set.