The clinics of Binsina Ltd. group may have to collect and process personal information about people with whom we work. These include our clients, employees, suppliers and vendors and those who visit our website, purchase from our online shop, and referred to as relevant individuals in this policy document (you, your). This policy sets out the terms and the process by which your personal information is collected and used by the member clinics of the Binsina Ltd. group, (us, we, our), who is responsible for collecting your personal information.
We regard the lawful and correct treatment of personal information as very important to our successful business operation and to maintaining confidence between us and those with whom we work and serve in the course of our business. We will ensure that we treat personal information lawfully and correctly, regardless of how it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We do not intentionally collect any information on children and those below the age of 18. Parents and guardians must inform us to remove such information if it has been collected unintentionally.
We fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR), which applies to the processing of personal data in manual and electronic records kept by us in connection with our business. This policy also covers our response to any data breach and other rights under the GDPR.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier (IP address), etc.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3.Data Protection Principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles.
In accordance with these principles, we will ensure that:
- processing will be fair, lawful and transparent
- data will be collected for specific, explicit, and legitimate purposes
- data collected will be adequate, relevant and limited to what is necessary for the purposes of providing you with suitable aesthetic treatments and skincare products, marketing activities and human resources function.
- data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
- we will comply with the relevant GDPR procedures for international transferring of personal data, if that becomes necessary.
4. Types of Data Collected
We collect and hold minimum amount of personal data on our clients, employees and suppliers in order to carry out safe and effective aesthetic treatments, provide products and marketing material, perform human resource functions and business support operations. We hold this data on paper and in electronic format.
Generally, we will collect the following types of data:
a) Clients: we only seek data that will help us identify the appropriate aesthetic treatments and skincare products for you. This information is collected via the consultation form and is likely to include:
- personal details such as name, date of birth, contact details, emergency contact/next of kin,
- medical history and GP contact details,
- previous skincare treatments and products that you may have used,
- a digital photograph for skin analysis if needed,
- any additional information that you may choose to share with us with the aim of assisting us in providing you with safe and suitable aesthetic treatments and skincare products, and
- a record of dates/times, treatments and skincare products purchased by you
b) Employees (including those interviewed but not hired): information gathered via the recruitment process such as that entered into a CV, a CV cover letter or our employment application form, for the purpose of providing you with appropriate employment opportunities. This may, include:
- name, date of birth, contact details, and next of kin contact details
- academic and vocational qualifications (institutions and dates attended),
- employment and salary history, and references from former employers,
- details relating to pay administration such as National Insurance numbers, bank account details and tax codes,
- medical or health information
- information relating to employment with Binsina Clinics, including:
- job title, job description and salary
- wider terms and conditions of employment
- details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
- internal and external training modules undertaken
c) suppliers/Vendors: Individuals representing companies that supply us with equipment, equipment maintenance services, skincare products and consumable items. Data collected is confined to contact details.
d) CCTV footage: clients, employees and vendors who visit our premises. We use CCTV for safety and security of our business, clients, employees and supplier/vendors, etc. This information is held on for a short time period and automatically erased with the passage of time.
e) Website users: some data is automatically collected through cookies when you visit our website for information or use our online shop for purchasing products. This may include your IP address, frequency of your visits, the times and dates of your visits and your preferences for the products and aesthetic services.
*Note: these lists are not exhaustive.
5. How Do We Collect Your Personal Data
We may collect your personal data through various channels:
- communication via phone, email and social media
- fill out forms during the consultation process
- make appointments
- take part in our promotions
- visit our website, make appointments or use our online shop
- Recruitment process including information you give us and that obtained from third parties.
- Record of employment with us
- Communication via phone, email and social media
6. Data Sharing and Third Party Processing
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain our commitment to protecting data. Specifically, we will share only relevant data with the following external parties for the purpose expressed therein:
- Our accountants: for employee payroll processing and invoice processing
- Lloyds Cardnet: client credit/debit card transaction processing, PCI DSS Compliant
- Electronic appointments diary (contact details and cord of treatments and skincare products purchased) with Salon Iris, GDPR Complaint.
- Regulatory bodies: to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.
- Consultants, doctors, and IT professionals, where necessary, for the performance of their relevant functions.
7. What Do We Use Your Personal Data For
We provide aesthetic treatments and skincare products at our clinics. In this regard, we may use your personal data to:
- respond to your queries about our products and services
- provide you skincare consultation, treatments and products relevant to you
- book your appointments and subsequently send you appointment reminders
- provide customer support and follow-up on your questions
- process payments and refunds
- inform you about special offers on our products and services
- send you marketing material
- share information with law enforcement authorities and regulatory bodies for the prevention of fraud, crime and tax collection.
- Use your feedback to improve our products and services to make them more relevant to your needs and requirements.
8. Your Rights
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below;
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
- the right to restrict the processing of data;
- the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
9. Our Responsibilities
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.
We have also appointed employees with responsibility for reviewing and auditing our data protection systems.
10. Lawful Bases For Processing Personal Data
We acknowledge that processing of personal data may only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity. We may process your personal data should you, as a client attend consultation and treatment appointments with us, visit our website to make appointments and purchase products from our online shop; as a present, past or prospective employee who has approached us for a job; as a supplier/vendor who provides us with a business support function, products or services.
Where no other lawful basis applies, we may seek to rely on your consent in order to process data.
However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
11. Access To Data
As stated above, you have a right to access the personal data that we hold on you. To exercise this right, you should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the relevant person making the request. In these circumstances, a reasonable charge will be applied.
12. Data Security
Our employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that they are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc. when unattended. No information of a confidential nature is left where they can be accessed by unauthorised people.
Where data is computerised, it is password protected both on a local hard drive and on a network drive that is regularly backed up. Authorised employees use passwords provided to access the computer system. While we make every effort to safeguard and protect personal data entrusted to us by relevant persons, we cannot fully guarantee its safety as electronically stored data is always vulnerable to interception by hackers, which is beyond our control. By using our website, you also consent to hold harmless the Binsina Ltd. group clinics, their management, employees and agents from any defamatory, derogatory or offensive material on our website or on linked websites and the consequences of any decisions you may make based on this information.
13. Special Categories Of Personal Data
Binsina Ltd. Group does not collect Special Categories of Personal Data
14. International Data Transfer
Binsina Ltd. Group does not transfer personal data to any recipients outside of the EEA.
Cookies are small text files that are lodged on your computer when you visit our website or open our emails or electronic marketing material. These files allow us to gather certain information about you for marketing purposes. This information may include, for example, your preferences or requirements for aesthetic treatments, skincare products, the general area you live in, IP address, the frequency and manner with which you browse our website, etc.
16. Requirement To Notify Breaches
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
17. Data Protection Compliance
Our Data Protection Officer (DPO) ensures that the GDPR guidelines on personal data protection.com are complied with. Any questions related to your data should be addressed to our DPO at firstname.lastname@example.org
Last updated April 2019