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At Garden Vets at Keele and Keele Veterinary Referrals, we take your privacy seriously. This policy outlines how we collect, use, and protect your personal data in compliance with the UK GDPR and the Data Protection Act 2018. Key points include:
For full details, please read the full policy below.
Legal Basis for Processing Personal Data
We process your personal data under the following legal bases as defined in the UK GDPR:
Data Retention Periods
We retain client records in accordance with veterinary regulatory requirements and industry best practices:
Data Sharing Practices
We do not share your personal data with third parties for marketing or unrelated business purposes. However, we may share data when legally required, such as:
We ensure all data processing partners adhere to high data protection standards.
Cookies and Website Tracking
Our website uses cookies for essential functionality and analytics:
You can manage your cookie preferences in your browser settings.
Data Protection Officer (DPO)
If you have any privacy concerns or wish to exercise your rights under UK GDPR, you can contact our Data Protection Officer: Daren Williams
Email: info@gardenvets.com
1. Information About Us
The Garden Vets Hospital Programme is the programme for establishing a veterinary hospital at the Harper Keele Vet School at Keele University.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.
| Data Collected | How we Collect the Data |
|---|---|
| Identity Information including name, title, qualifications, offices held, gender and gender reference preferences, date of birth, address, email address, social media ids, identity registration data such as passport number or other unique identification data, other data we describe and maintain securely in our Digital Hub, and only with your prior consent and in accordance with our general obligations and Garden Vets Hospital policies which meet or exceed such standards and obligations. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Contact information including address, email address, telephone number, social media id, instant message services id, other electronic means. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Business information including business names, directorships and other official offices (whether regulated or otherwise), job title, profession, professional qualifications. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Payment information including bank details, bank card details, other payment information (such as international payment identifiers) needed to process financial transactions. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Profile information including personality and psychometric profiles (by consent only), preferences, roles and interests, personal and professional aspirations, purchasing preferences. Profile information will extend to systems identities, roles, permissions, clearances, configurations, logging data and activity monitoring. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Data from third parties including credit reference agencies, formal agencies, regulated bodies, professional associations. | Directly, electronically, indirectly and through official registration bodies (such as companies house, bank or financial institution and HMRC, for example). We do not purchase or sell any personal data under any circumstances. |
| Data from CCTV, Audio and other systems generated information | Directly, electronically, indirectly and through internal systems and services (such as AI enabled CCTV, Audio & application enabled solutions) We do not purchase or sell any personal data under any circumstances. |
Under the Data Protection Legislation, we must always have a lawful basis for using personal data (legitimate interest). The following table describes how we use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Administering our business. | Personal data, systems profile data, systems configuration, security and authentication data. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
| Supplying our products and services to you. | Personal data, systems profile data, systems configuration, security and authentication data. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
| Managing payments for our products and services. | Business or personal banking and payments data, and authentication and identification data. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
| Personalising and tailoring our products and services for you. | Personal data, systems profile data, systems configuration, security and authentication data [if applicable]. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
| Communicating with you. | Personal data, systems profile data, systems configuration, security, identification and authentication data. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
| Data Gathering, including video, audio and other analytics data. | Personal data, systems profile data, audio recordings, video recordings, systems configuration, security and authentication data. | Fulfilling our obligations in the design, delivery and operation of business solutions and/or systems and platforms. |
You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with any party for any reason.
We use a range of automated system for carrying out certain kinds of decision-making and/or decision support. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact me to find out more using the details in Part 11.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Category of Data | Retention Period | Legal / Regulatory Basis |
|---|---|---|
| Client and Pet Medical Records | 7 years after the last treatment or interaction | RCVS professional guidelines; Limitation Act 1980 |
| Financial Records (Invoices, Payments, VAT) | 6 years from the end of the financial year in which the transaction occurred | HMRC requirements (Taxes Management Act 1970) |
| Insurance Claims and Related Correspondence | 7 years | Legal and insurance dispute resolution |
| Marketing and Communications Data | 2 years from last contact or until consent is withdrawn | UK GDPR (consent/legitimate interest) |
| Job Applicant Data | 6 months after end of recruitment unless extended with consent (up to 12 months) | Equality Act 2010, UK GDPR |
| Employee Records | 6 years after employment ends | Employment Rights Act 1996; Limitation Act 1980 |
| Health and Safety Incident Records | 3 years after the incident (or until the individual turns 21 if under 18) | RIDDOR, Limitation Act 1980 |
| CCTV Recordings (including audio if applicable) | Research and Innovation, process and performance improvements, an active investigation or training archive. | UK GDPR (legitimate interest, public interest); industry best practice |
| Educational and Training Footage (incl. anonymised patient images) | Retained only with appropriate consent or where anonymised; otherwise deleted after 24 months | UK GDPR (consent, public interest in education, legitimate interest) |
| Significant Event Reports (SERs) | 10 years (to support audit, learning, and compliance) | VDS/VetSafe guidance, legal defence, clinical governance |
We will only store your personal data OR store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
AND
We will only store your personal data OR store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
AND
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 11 for further information about the particular data protection safeguard[s] used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for purposes of delivering our obligations under these HOTs and the Service Agreement and any other agreement we might enter into from time to time. This includes subsidiaries in the UK and EU, our holding company and its subsidiaries.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will normally respond to your subject access request within one month, and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@gardenvets.com
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.