This policy was last updated on 14th March 2019
3C Wheelchair and Seating Service Limited (‘3C’, ‘we’, ‘us’, and ‘our’) take data protection very seriously and we are committed to protecting your personal information.
This policy explains what information we gather about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information, how long we keep it and who you can contact for more information.
It is our policy to collect only the minimum information required from you. If you believe we have collected excessive information about you, or indeed have any other question in relation to this policy, then please contact us using the details at the end of this document to raise any concerns you may have.
Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information, goods or services you want from us.
What is personal information?
Personal information is anything that enables you to be identified or identifiable, such as your:
- First and last names
- Postal and email addresses
- Telephone numbers
- Identity documents (e.g. passports & driving licence)
- Identity numbers (e.g. National Insurance and Bank accounts)
- Digital photography, audio recordings and video
Your personal information is sometimes called “personal data”. We collectively refer to handling, collecting, protecting or storing your personal information as ‘processing’.
Collecting personal information
Below are just some examples of how you may provide personal information to us:
- Asking us to provide goods or services to you or someone else
- During a consultation when we assess your needs (this will include taking digital photographs, audio recordings and video)
- Contacting us, including via our website
- Submitting CVs or work history information to us
- Providing us with business cards or other contact information
Our main business activity is the provision of custom wheelchairs and seating for people with neurological and spinal injuries. This involves us collecting medical information, and data on ranges and measurement of movement. We appreciate that this information is sensitive and will keep it secure and confidential. We will only use it to provide our product / service to you, although this may involve sharing some details with others involved as described below under sharing personal information.
Using personal information
When you provide personal information to us, we may use it for any of the purposes described below or as stated at the point we collect it from you (or as may obvious to you from the context of collection), including:
- To provide a customised wheelchair / seating to you that you have requested or has been requested on your behalf
- To secure funding for the provision of your wheelchair / seating from the original referrer
- To contact you to arrange appointments including for agreed servicing or clinical review follow-ups
- To consider whether to offer someone employment with us
- To conduct quality and risk management reviews.
We will always seek consent from you or your legally-appointed representative before we use your personal data for any other purpose. A good example would be for a case study on our website.
We do not collect personally identifying information for sale to third parties.
Legal grounds for processing personal information
We rely on one or more of the following processing conditions:
- To perform our contractual obligations to you; and/or
- To satisfy any legal and regulatory obligations to which we are subject; and/or
- To satisfy our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (where this does not interfere with your rights); and/or
- When you have agreed to us processing your personal information, e.g. we ask for your consent to collect medical information and ranges of movement measurements from you or your legally-appointed representative at the start of our assessment process to identify your needs.
Please be aware that if this consent is not given, or data is withheld, we will not be able to provide you with a customised wheelchair or seating product.
Security of personal information
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.
Only authorised persons are provided access to personally identifiable information we have collected, and such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure.
We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Sharing personal information
For service users, we will need to share information collected from you with third parties (other organisations or individuals) involved in the provision of your customised wheelchair / seating. This will include:
- Other medical professionals involved with your care
- Referrers (those that originally contacted us about your needs) where they are involved in the funding of the service requested or are otherwise involved in your ongoing care
- Manufacturers of wheelchair / seating components (although care will be taken to anonymise information whenever this is feasible)
We do not use your data for any other purpose than the provision of the product / service requested or share or sell this information with anyone else.
For all data subjects, we may need to share information for the purposes listed above under ‘Using personal information’.
We also may transfer share or disclose personal data to third party service providers of data backup, security and storage services.
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation.
International transfers of personal information
Your personal information will not normally be transferred by us outside the European Economic Area (EEA).
However, some manufacturers of wheelchair/seating components are based outside of the EEA (including New Zealand and the USA). When dealing with these manufacturers we will use our best endeavours to anonymise your personal information by using a transaction number rather than your name or contact details. We may though need to share photographs or video recordings, from which you may be recognised, in order to achieve the correct prescription.
Retention of personal information
We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law.
For service users, we do retain personal data collected in order to monitor changes over time and to provide modifications or new equipment as requested. This information is deleted following a period of 5 years without any contact or on notification that the service user is deceased.
We do not undertake any form of direct marketing activity.
Rights in relation to your information
You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:
- Request a copy of personal information we hold about you;
- Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
- Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
- Object to our processing of your personal information; and/or
- Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
If you would like to exercise these rights or understand if these rights apply to you, please contact us using the contact details at the end of this document.
We do not intend to collect special category (also known as sensitive) personal information through our website. Examples of special category information are: race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records.
We ask that you do not include this information when contacting us via the website or by email. We appreciate though that you may need to include some basic health information in your enquiry. We ask that you keep this to the minimum and bear in mind the risks involved in any data transfer using the internet or email.
If you have any questions or complaints about the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us by one of the following means:
Post: 3C Wheelchair and Seating Service
331 Milton Road
You also have the right to lodge a complaint with your local data protection regulator, which in the UK is the Information Commissioner Office (ICO). The ICO can be contacted by the following means:
Telephone: 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers). If you’re calling from outside the UK please call +44 1625 545 700.
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
We may update this Privacy notice at any time by publishing an updated version here. So that you know when we make changes to this Privacy statement, we will amend the revision date at the top of this document. The new modified or amended Privacy notice will apply from that revision date. Therefore, we encourage you to review this Privacy notice periodically to be informed about how we are protecting your information.