Introduction

We are Optegra UK Limited, a company registered in England under number 05846041. Our registered office is at 7 The Technology Park, Colindeep Lane, London NW9 6BX.

This Privacy and Cookies policy (the “Policy”) describes how Optegra UK Limited (“Company”, “we”, and “our”) collect, use and share personal data when you visit this website: optegra-infopack.co.uk.  “the Site” and other Optegra UK webpages accessible from our Site. Please read this Policy carefully, to understand our views and practices regarding your personal data and how we will treat it.

As above, we encourage you to read the Policy in full. However, to summarise, we will:

• Always use your data within relevant UK data protection law;
• Never sell your data; and
• Always respect your wishes about how you would like to be contacted.

Updates to this Privacy and Cookies Policy

We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, ie that could materially affect your privacy rights, we will post a notice on our Site prior to such changes(s) taking effect. In the event that such a change could materially affect your privacy, you will be notified without delay by appropriate means.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at DPO@Optegra.com or write to our Data Protection Team at the following address:

Optegra UK Head Office
Optegra Eye Health Care
7 The Technology Park
Colindeep Lane, London NW9 6BX

Why do we collect your data?

Optegra UK current / former employees, contractors and agency workers, please select here.

Prospective / existing patients:

• We obtain and use your personal details and financial details in order to establish and deliver our contracted services to you.
• Where you access our service through your health insurance provider we will need to share your personal and medical information, including with your health insurance provider, with your explicit consent.
• Where you access our service through the NHS, we will need to share personal information including medical information with the NHS with your explicit consent.
• We obtain and use your medical information as this is necessary for medical purposes, including medical diagnosis and treatment.
• We also store your medical information / records, such as notes from appointments and consultations, for regulatory compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council ‘GMC’; Medical and Healthcare products Regulatory Agency ‘MHRA’; and Care Quality Commission ‘CQC’; Private Health Information Network ‘PHIN’ , Information Commissioner’s Office ‘ICO’ or as otherwise required by law or regulation.
• We use details about you, including your email address; postal address and telephone number to send you occasional updates and marketing messages where you have given your consent or where you have not opted out, based on our legitimate interest in marketing our services to you, and subject to your right to opt out at any time).
• We use your telephone number and other relevant details about you, to communicate with you and our professional advisers, about appointment bookings and resolving queries and / or complaints or claims.
• Where you decline to provide information we have requested from you, please bear in mind that this may affect our ability to treat you or provide you with our services and it is likely that we will decline to treat you or provide you with our services.

Information we may collect from you

Optegra UK current / former employees, contractors and agency workers, please select here.

Prospective / existing patients

Information you provide

Personal details – Basic information about yourself that you provide by filling in forms in person, at our clinics and hospitals, or on our Site or by speaking to us on the telephone. ‘Basic details’ include but are not limited to your name, age, gender, date of birth, postal / email address and telephone numbers.

Medical information – This information forms part of your health record and is ‘special category’ data within Article 9 (1), UK GDPR. This information includes details about your symptoms, consultations, medications and procedures. We will process your ‘special category’ personal data ‘within the rules’ for ‘special category’ personal data (see ‘Using your personal data and the legal basis for processing’ below).

Financial information – We do not collect or store credit or debit card details. But when you make any payments using your credit / debit card, these details are processed directly by a third – party processor that will store all payment information and transactions details. We will only retain limited details of the transactions on secure servers located in the UK.

Insurer funded – Where your access to our service is funded by an insurance provider, with your consent, we will need to let your insurance company know your name; email address; policy number; demographic information; appointment and procedure details.

Passive information collection and use

As you navigate through the Site, certain information can be passively collected (that is, gathered without you actively providing that information) using various technologies and means, such as Internet Protocol addresses; cookies; internet tags and navigational data collection.

Please read our Cookies Policy and review the Cookie Settings for detailed information about cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any of disabling each specific cookie / tracking technology. If you do not disable any cookies or tracking technologies we will infer your consent to their use.

We and our third – party service providers may passively collect and use information in a variety of ways, including:

Through your browser –  Certain information is collected by most browsers, such as your Media Access Control ‘MAC’ address; computer type (Windows or Macintosh); screen resolution; operating system version and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.

IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

Using pixel tags, web beacons, clear GIFs, or other similar technologies – These may be used in connection with some Site pages and HTML – formatted e-mail messages to, among other things, track the actions of Site users and e -mail recipients; measure the success of our marketing campaigns and compile statistics about Site usage and response rates.

Online behavioural advertising –  The use of cookies, pixel tags, web beacons, clear GIFs, or other similar technologies allows our third – party vendors to deliver advertisements about our products and services when you visit the Site or other web sites or web properties across the Internet.  These vendors may place pixel tags, web beacons, clear GIFs, or similar technologies on the Site and other websites or web properties, and also place or recognize third – party cookies when you visit the Site or other sites or web properties.  They may use information about your visits to the Site and other web sites or web properties to provide advertisements about goods and services that may be of interest to you.

Device Information – We may collect information about your mobile device, such as a unique device identifier.

Third Party Sites and Services

This Privacy Policy does not address, and we are not responsible for, the privacy; information; or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.

Social Media and Sharing Tools

On some pages, we may also feature embedded ‘Share’ buttons or widgets that enable you to share content with friends through a number of popular social networking sites (eg Twitter and Facebook etc).

These sites may set cookies which can identify you as an individual when you are also logged in to their services. This means they may be collecting information about what you are doing online, including on our Sites. We do not control these cookies and you should check the relevant third – party website to see how your information is used and how to opt out.

Telephone and Video Consultations

We may offer you a consultation via telephone or video conferencing. By accepting the invitation and entering the consultation you are consenting to this. Your personal / confidential patient information will be safeguarded in the same way it would with any other consultation and any risks explained to you before the consolation begins.

How we use your data

Data Protection Consent

In this section “Data Protection Law(s)” means the UK General Data Protection Regulations ‘UK GDPR’, the Data Protection Act ‘DPA’ 2018, the Privacy and Electronic Communications (EC Directive) Regulations ‘PECR’ 2003 and any other Applicable UK Law relating to the processing, privacy or use of Personal Data. “Applicable UK Law(s)” / “Data Protetion Law(s)” shall mean all applicable statutes, regulations, orders, regulatory requirements, by laws, ordinances, rules, subordinate legislation and other UK laws, including any judicial or administrative interpretation of them, in force from time to time in any applicable jurisdiction.

In this section, “Personal Data” shall have the meaning given to it in the “Applicable Law(s)”, with Personal Data including ‘special category’ data or Sensitive Personal Data.

Optegra UK is committed to protecting and respecting patient privacy and to comply with Data Protection Laws and medical confidentiality guidelines. Very strict rules and procedures are in place to ensure that your information is kept safe, and that your Personal Data is kept confidential at all times. Please tick each of the boxes below if you agree to Optegra UK and your doctor processing and sharing your Personal Data (whether obtained by Optegra UK or your doctor and whether obtained at an Optegra UK clinic or hospital or another hospital or surgery) in the way described alongside the relevant box. If you change your mind at a later date, or would like further information on how your personal data is processed please contact: DPO@Optegra.com.

Please note that you can opt out at any time from any of the data processing and data sharing initiatives described below (although this will not affect the lawfulness of any processing of your Personal Data up to that point). If you change your mind at a later date, please contact: DPO@Optegra.com.

Research

From time to time Optegra UK is involved in research projects for eye conditions and new technologies. We may share details about the progress of your treatment with your nominated contacts from time to time when we have the legal right to do so under Applicble Law(s) / Data Protection Laws supported by different regulations. If no such legal right exists, we will separately ask you for your consent.

Data Protection – Agreement & Declaration

(1) We will disclose your medical information to those involved with your treatment or care at Optegra UK or any other hospital. We consider that this disclosure is in your interests.

(2) Optegra UK will share your non – medical information (or where applicable, your Guarantor or Sponsor’s) in relation to billing, processing, payment or collection of accounts, or credit referencing information. This extends to any person or organisation
these activities may involve in order to achieve this. Optegra UK will employ appropriate measures to protect your personal data where
this is the case.

3) Optegra UK has regulatory and / or compliance obligations to share certain clinical data with various governmental and
regulatory bodies (for example the General Medical Council ‘GMC’, the Medical and Healthcare products Regulatory  ‘MHRA’ and the Care Quality Commission ‘CQC’, or as otherwise required by
law or regulation. This may include any personally identifiable clinical information, including your NHS patient identification number or its
equivalent.

(4) Optegra UK has legal obligations to share certain personal data with the Private
Healthcare Information Network ‘PHIN’ for further information please visit  PHIN at https://www.phin.org.uk/.

5) We may need to share your data with our third – party service providers who provide services such as: website hosting,
moderating, mobile App, hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services,
customer service, e – mail and direct mail delivery services, credit card processing, auditing services, and other services, in
order to enable them to provide services on our behalf and continually improve overall care.

6) Optegra UK participates in national clinical audits and submits data to national registries. These data sharing initiatives are
aimed at improving the quality of patient care, medical treatments and outcomes across the healthcare industry.

For further information on how your information is used, how we maintain the security of your information and your rights
to access that information, please contact: DPO@Optegra.com.

COVID – 19 Data Protection Statement

During these unprecedented times, Optegra UK’s main priority is the health and safety of our patients, colleagues and the wider community as well as supporting the NHS in responding to the COVID – 19 pandemic.

As a result of these unique circumstances, Optegra UK Ltd may need to share personal data with the NHS and other regulatory and government bodies for the purpose of supporting the response to the COVID – 19 pandemic. Each of our hospitals is working in collaboration to ensure we can provide the right help, exactly where and when it is needed and this may involve personal data being shared with us by the local healthcare organisations. This will be done in accordance with data protection laws and will include any amendments to legislation made by the Secretary of State. We will also consider any guidance provided by the Information Commissioner’s Office ‘ICO’.

Data Subject’s Rights

Due to the current circumstances, if you submit a Subject Access Request ‘SAR’ or other Data Subject Rights request, please be aware that you may experience a delay in us responding to your request. This is because we will be diverting resources to help with other challenges and ensuring the ongoing healthcare and treatment of our patients.

At this current time we are limited to collect any correspondence sent via post. If you need to get in touch regarding a SAR or other information request, please contact us via email at DPO@Optegra.com.

Sharing of your Personal Data during the Covid – 19 pandemic

During the Covid – 19 pandemic your personal data may also be shared for the following purposes:

• Understanding Covid – 19 trends and risks to public health and controlling and preventing the spread of Covid – 19;
• Identifying and understanding information about patients or potential patients with or at risk of Covid – 19 including patient exposure to Covid-19;
• Management of patients with or at risk of Covid – 19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self -isolation, fitness to work, treatment, medical and social interventions and recovery from Covid – 19;
• Understanding capacity and availability information about patient access to health services and adult social care services
• Monitoring and managing the response to Covid – 19 by health and social care bodies and the Government including providing information (including workforce details) to the public about Covid – 19;
• Delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid – 19; and
• Research and planning in relation to Covid – 19.

We will regularly review this privacy statement and its applicability throughout the Covid – 19 outbreak. We may also notify you in other ways from time to time about the processing of your personal information.

Using your personal data and the legal basis for processing

We will process your personal data under Article 6 (1) (b) and Article 9 (2) (h) of the UK General Data Protection Regulation. In addition, OPTEGRA UK LTD will rely one or more of the following basis when sharing personal data as part of our support work with the NHS during the COVID – 19 pandemic:

• Legal obligation: the processing is necessary for compliance with a legal obligation to which we are subject: Article 6 (1) (c); *
• Vital interests: the processing is necessary to protect someone’s life: Article 6 (1) (d);
• Public interest: the processing is necessary to perform a task in the public interest: Article 6 (e); and
• Legitimate interests: the processing is necessary for Optegra UK’s legitimate interests or the legitimate interests of a third party: Article 6 (1) (f).

When processing ‘special category’ personal data for the purposes of:

• Employment, social security and social protection: Article 9 (2) (b);
• Vital interests of the Data Subject: Article 9 (2) (c);
• Substantial public interest: Article 9 (2) (g);
• Provision of health or social care: Article 9 (2) (h); and
• Public interest in the area of public health such as protecting against serious cross border threats to health: Article 9 (2) (i).

* This includes the Notice by Secretary of State under Reg 3 (4) of Health Service (Control of Patient Information) Regulations issued on 1st April 2020 (Coronavirus (COVID-19): notification to organisations to share information – GOV.UK (www.gov.uk)), allowing healthcare providers to share personal data and any other such notice that may be issued to support efforts against Covid – 19.

We use your personal data to support the provision of your healthcare in the following ways:

• To support the provision of your healthcare;
• To decide how best to provide treatment to you;
• To take steps at your request during the course of your treatment; and
• To keep your records up to date.

Security

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this Privacy Policy.

Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section of the Site.

Cross – Border Transfers

Personal information that consists of medical data, ie ‘special category’ data, will generally be stored within the European Union ‘EU’ / European Economic Area ‘EEA’. Transfers of personal data to this region are protected by UK adequacy regulations, which ensure that this region provides an adequate level of protection to personal data.

Personal information other than medical data will also generally be stored within the European Union ‘EU’ / European Economic Area ‘EEA’. However, on occasion, this personal information other than medical data may be processed or stored via destinations outside the European Economic Area, for example the United States, where there may be no UK adequacy regulation / decision (but there would be other legislation, offering protection for personal data).

But if we do transfer your personal data to these areas, we will always make the transfer in accordance with UK data protection law and subject to strict safeguards.

For example, in one situation, we work with third parties to use their software platforms to send communication emails to our users. If this situation involved transfers outside the EU / EEA, we would use appropriate safeguards to increase the level of protection of the personal data we transfer. These safeguards may include eg data sharing agreements and other related data protection documentation; standard contractual clauses; binding corporate rules ‘BCRs’ and technical / organisational measures.

How do we use your data?

We use and disclose information you provide to us as described to you at the point of collection.

We also use information from or about you:

• To respond to your enquiries and fulfil your requests, such as to send you documents you request or e – mail alerts.
• To send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies and / or other administrative information.
• For our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our products and services, identifying Site usage trends, personalizing your experience on the Site by presenting products and offers tailored to you and determining the effectiveness of our promotional campaigns.

We may also disclose information collected through the Site:

• To our third – party service providers who provide services such as website hosting and moderating, mobile App, hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, e – mail and direct mail delivery services, credit card processing, auditing services and other services, in order to enable them to provide services on our behalf;
• To our affiliates for the purposes described in this Privacy Policy;
• To a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
• Sub – processors. We may share information with sub – processors who assist in providing us with key services. An up – to – date list of our sub – processors is located here.

Data Retention

We retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy, as well as our Health Records Management Policy, unless a longer retention period is required or allowed by law or to otherwise fulfil a legal obligation.

Use of Site by Minors

This site is applicable to adults. It is not applicable to individuals under the age of 16 and we request that these individuals do not provide personal information through this Site.

Your rights

You have the right to:

Access the personal data which the Company holds about you. This is called a Subject Access Request ‘SAR’ and must be made to the Data Protection Manager using the details in the “Contact Us” section.

You may use this process to exercise your right to:

• Have your personal data rectified if it is inaccurate or incomplete;
• Request that we erase information we hold about you;
• Restrict the processing of your personal data, for example ask us not to contact you;
• Object to the processing of your data for specific purposes such as communications or direct marketing; and
• Ask for the transfer of your data electronically to be provided to a third party (data portability).

You also have the right to lodge a complaint with the Information Commissioner’s Office:

Address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Telephone: 0303 123 1113 (local rate).

Website: https://ico.org.uk/global/contact-us/