1. IMPORTANT INFORMATION AND WHO WE ARE
Queens Dock Business Centre
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2. THE DATA WE COLLECT 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, passport number, date of birth, gender and other similar identity data.
- Contact Data includes home address, email address, telephone numbers and other similar contact data.
- Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services and may include information about your destination of travel, clinic location booked, number and type of tests booked.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect the following Special Categories of Personal Data about you:
- Health and medical data includes medical information including your test results (such as whether or not you have Covid-19) and vaccination status.
- Swab sample data is collected when you attend one of our test centres and take a Covid-19 test. We will collect a swab of fluid from the back of your throat and/or nostril and carry out tests on that sample to identify the SARS-CoV-2 virus.
- Data revealing racial or ethnic origin We use this data as part of our reporting to Public Health England, such as the reporting of positive test results.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Payment Data when you book an appointment to attend one of our test centres, create an account on our website or by corresponding with us in some other way, including by post, phone, email or otherwise.
Third parties or publicly available sources. We will receive personal data about you from various third parties For example, we may collect Technical Data from analytics providers such as Google based outside the UK and other third-party sources based inside or outside of the UK, such as public databases, data service companies, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal obligation.
- Where you have provided your consent.
Where we rely on consent as a legal basis for processing your personal data, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out in Schedule 1, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in Schedule 1.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list. However, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may access your account settings and update preferences.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
- Third party service providers who act as processors, including:
- Invoice and Billing: Stripe
- Web and Mobile Analytics: Google Analytics
- Our third party partners, who we work with in order to provide you with Covid-19 test services, such as our test centres operated by third parties.
- Other companies in the DAM Group for our general business, reporting to management, authorisations/approvals from relevant decision makers, and where systems and services are used or provided on a shared basis.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, Public Health England and other regulators and authorities who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
In the normal conduct of our business processes your information will be stored and processed in the UK, EU/ EEA.
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data..
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK..
If you use our services whilst you are outside the UK, your information may be transferred outside that territory in order to provide you with the services you have requested.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. YOUR LEGAL RIGHTS
Individuals have certain legal rights, which are briefly summarised at Schedule 2, in relation to any of their personal data which we hold.
If you wish to exercise any of your rights please contact us in the first instance.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer and to process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us||(a) Identity(b) Contact(c) Payment||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To provide you with Covid-19 testing services (including receiving and processing your Covid-19 test)||(a) Health and medical data(b) Swab sample data||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to perform Covid-19 tests)(c) Necessary for reasons of public interest (public health)|
|To process Covid-19 test results, including reporting to Public Health England and returning your test results to you.||(a) Identity(b) Contact(c) Health and medical data(d) Swab sample data(e) Data revealing racial or ethnic origin||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to perform Covid-19 tests)(c) Necessary for reasons of public interest (public health)(d) Necessary to comply with a legal obligation|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications||(a) Consent(b) Necessary for our legitimate interests (to develop our products/services and grow our business)|
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.