This Privacy Notice sets out details of the information that Brows and Beauty and the aesthetician responsible for your treatment, as well as administration staff may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully. This notice explains the types of information gathered, how it is collected, stored, and used by us when you use this website, contact us electronically, visit our treatment facility, or contact us by direct mail and telephone. This Policy Notice aims to inform you also of your privacy rights, how the law protects you, and how personal data can be to corrected or changed.
At Brows and Beauty we take the privacy of our clients very seriously, and the security of your personal information is extremely important to us. We commit to protecting all information given to us. Personal information is collected, stored, and used in accordance and compliance with the General Data Protection Regulations (EU 2016/679), the UK Data Protection Act 1998, and the Privacy and Electronic Communications Regulations 2003.
In this Privacy Notice we use “we” or “us” or “our” or “Brows and Beauty” to refer to the business who is using your personal information, and the aesthetician who provides your treatment. For the purpose of the General Data Protection Regulation (EU 2016/679), the Data Controller (DC) is: Amanda Salisbury, 119 High Street, Shoeburyness, Essex, SS3 9AU, Tel: 01702 304700, E-mail: firstname.lastname@example.org, website: https://browbeautybyamanda.co.uk.
The Data Protection Officer (PDO) for Brow Beauty is Amanda Salisbury. You can contact our DPO by Post: 119 High Street, Shoeburyness, Essex, SS3 9AU; by phone:07738 347235, by e-mail: email@example.com.
We take all necessary steps to ensure that all data given to us is:
- Lawfully processed, in accordance with the subject’s rights
- Securely held
- Accurate at all times
- Relevant and comprehensive without being excessive
- Processed for limited purposes
- Not kept longer than necessary
- Not transferred to non-EEA countries without sufficient protection
We will not share your data with any third party except for administrative purposes relating to the services we provide and where we may be required to do so by law.
What personal data we collect and why we collect it
We only collect, store and use data that is relevant to the service that Brows and Beauty provides. Personal data, or personal information, means any information about an individual from which that person can be identified. This may include some or all of the following details:
- Personal Identification Data: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Details: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account and payment card details (encrypted).
- Transaction Data details about payments to and from you and other details of products and services you have purchased from us.
- Treatment Details: information about the treatment you enquire about, you receive from us and any previous treatments. This information could include self-disclosed ‘health data’, lifestyle information, next of kin and GP details, treatment notes and digital images of before and after treatment- we take extra steps to ensure treatment details are adequately protected.
How and why we collect your data
We collect data from and about you through direct interactions where you by fill in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services
- fill in our contact form on our website to send us an enquiry
- subscribe to our service, newsletters and publications on this site and on our social platforms
- request marketing to be sent to you
- enter a competition, promotion or survey
- give us some feedback and reviews
- fill in registration forms and consent forms in our clinics
Data given to us via website, platforms, paper documentation, digital images and during visits to the Brows and Beauty treatment facility, are collected and used for the purpose of providing you with services and information that you have requested about treatments, products, and services from Brows and Beauty. All of this data is collected through the website contact form, via e-mail, social platforms, on the online booking site, and on written client forms.
If you wish to contact us using our contact form on the website contact page during your visit to our website, you will be asked to enter personal details such as your name, telephone number and email address, and we require specific consent via an opt-in tick box to collect and store these details. We will not use your data except to fulfill a request you make when disclosing those details. Our reply to your email and further contact may take the form of email, telephone or other text message. Your personal details will only be stored and archived in our secured e-mail file to allow our staff to contact you for quality assurance purposes with regards to monitoring communication and response times and, of course, for the whole range of administrative needs and purposes and will not be shared with anyone else.
Our website contains a direct link to our Appointment Booking Page. To book an appointment, you will have the option to create a profile by supplying your personal details, which are your Name, Address, E-mail and telephone number. You will be asked to opt in by entering your details in order to receive an e-mail confirmation of your appointment and a text message reminder 24hrs prior to your appointment. Your details will be stored in the secure booking site under your client profile to enable you and the administration team to access information, reminders, and to rebook. We do not use those data for any other purpose than in order to liaise with you about your appointment, your treatments and your aftercare. Your data is not shared with anyone else at any point, and is only accessed by an authorised person. You have remote access with you own password and you can at any point access, check and edit your details to ensure they are always up-to-date and accurate. You can also at any point remove /delete your profile and exercise your right to be “forgotten”.
Consultation and treatment files
During your initial consultation and during treatment appointments, you will be asked to provide us personal identification details, such as name, address, telephone number, e-mail. You will also be asked to complete medical a questionnaires, marketing and medical consent forms and contracts for us to contact you, to use for your consultation, treatment planning and for medical accountability, record keeping, auditing, quality assurance and insurance purposes.
We use a third party provider, Fresha, to deliver our e-newsletters and some other communications. We gather statistics around email opening and clicks using industry standard technologies including web beacons to help us monitor and improve our e-newsletter and communications. We do this with specific consent or subscription for e-mail communication and If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
We sometimes use a third party provider to manage our social media interactions. If you send us a private or direct message via social media, the message will not be shared with any other organisations.
How we use your data
We take all necessary measures to ensure that any information we collect from initial customers’ enquiries, through to booking appointments, and during your visits to the Brow Beauty treatment facility is collected, recorded, processed and used in full compliance with the Data Protection Act and with GDPR. This means that Brows and Beauty will only use your information within the permissions you give us and the boundaries set out in our policy. All information will remain strictly confidential, and used only for the purpose described at the time of the submission and according to your explicitly given consent. We will only use your personal data when the law allows us to. Most commonly, we will use the collected and stored 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 or regulatory obligation.
We also use your personal data for the purposes of:
- Internal record keeping and day-today administrative procedures
- Auditing and monitoring and quality assurance
- Improving our products and services.
Please find more detail on the purposes for data use in the sections below.
Purposes for data use
In light of the nature of the treatments and services which we provide to our customers, it will often be necessary for us to use information about your health. Even in the broadest sense of the word, ‘health’ information is a special category of personal data which requires us to have an additional lawful basis for using this information. Where we use information about your health for the purpose of providing our services to you (or in preparation for us to provide services to you), the additional lawful basis on which we shall rely will be that such use is necessary in order for us to provide you with health care or treatment.
1: Appropriate business needs
One legal ground for processing personal data is where we do this in pursuit of legitimate interests and those interests are not overridden by your privacy rights.
2: To provide you with aesthetics services
Clearly, the reason you come to us is to provide you with medical aesthetic services and skin care, and so we have to use your personal information for that. Legal grounds are: a) Providing you with healthcare and related services b) Fulfilling our contract with you for the delivery of our services.
3: For account settlement purposes
We will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date. Legal grounds: a) Our providing you with healthcare and other related services b) Fulfilling our contract with you for the delivery of our treatments and services c) Vie Aesthetics having an appropriate business need to use your information which does not overly prejudice you. Additional legal grounds for special categories of personal information: a) We need to use the data in order to provide medical aesthetics services to you b) The use is necessary in order for us to establish, exercise or defend our legal rights.
4: Communicating with you and resolving any queries or complaints
Clients may raise queries, or even complaints with Brows and Beauty, and we take those communications very seriously. It is important that we resolve such matters fully and properly, and so we will need to use your personal information in order to do so. Legal grounds are: a) Our providing you with our services, b) Our having an appropriate business need to use your information which does not overly prejudice you. Additional legal grounds for special categories of personal information: a) The use is necessary for the provision of a treatment pursuant to a contract with our practitioner b) The use is necessary in order for us to establish, exercise or defend our legal rights
5: Complying with our legal or regulatory obligations, and defending or exercising our legal rights
As a provider of medical aesthetics services, we are subject to a wide range of legal and regulatory responsibilities and we may be required by law or by regulators to provide personal information, and in which case we will have a legal responsibility to do so. In cases of complaints and in order to fully investigate and respond to these, it is necessary to access your personal information (although only to the extent that it is necessary and relevant to the subject-matter). Legal grounds: a) The use is necessary in order for us to comply with our legal obligations b) The use is necessary for establishing, exercising or defending legal claims.
6: Managing our business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice)
In order to do this, we will not need to use your special categories of personal information and so we have not identified the additional ground to use your information for this purpose. Legal grounds: a) Our having an appropriate business need to use your information which does not overly prejudice you
7: Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed in the Client Registration Form
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. As a business, we need to carry out marketing but we are mindful of your rights and expectations in that regard. As a result, we will only provide you with marketing which is relevant to our business and only where you have specifically confirmed your consent to do so. Legal grounds: a) Our having an appropriate business need to use your information which does not overly prejudice you, b) You have provided your consent. If you no longer wish to receive marketing emails sent by us, you can click on the “unsubscribe” link that appears in all of our emails, otherwise you can always contact us using the details set out in section 2 to update your contact preferences.
You may receive marketing communications and newsletters from us via e-mail, if you have requested information from us or purchased goods or services from us, or if you provided us with your details when you opted in either online or on paper. You can ask us or third parties to stop sending you marketing messages at any time by unsubscribing and following the opt-out links on any marketing message sent to you or by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. If you are a registered Facebook user, you may also receive targeted adverts from Brows and Beauty. You can read about how Facebook works by following this link https://en-gb.facebook.com/policies/cookies/
Disclosures of your personal data
We may have to share your personal data with third parties, that may be
- IT: Service providers acting as processors who provide IT and system administration services.
- Advisors: Professional advisers including accountants. lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Authorities: HM Revenue & Customs, regulators and other 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.
We do not transfer your personal data outside the European Economic Area (EEA).
We are committed to ensuring that your information is secure and we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an un-authorised way, altered or disclosed. These include physical, electronic and managerial procedures to safeguard and secure the information. For this purpose, 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 will never sell, trade, or loan your personal information to another party.
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. We are required by law to report any security breaches involving personal data to the ICO. We use the data collected to record the breach, to make decisions about the action we take, and as relevant, in order to carry out those actions. We retain personal information only for as long as necessary to carry out these functions, and in line with our retention schedule. This means that logs and breach reports will be retained for two years from receipt, and longer where this information leads to regulatory action being taken.
How long we retain your data
We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations. Any personal information will then be archived or destroyed, unless we need to retain it for legal, accounting, regulatory, or auditory requirements or to protect the company’s interests.
If you would like further information regarding the periods for which your personal information will be stored, please contact our DPO for further details. We will only store your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 un-authorised 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 requirements we use the data collected and stored for. We will never sell, trade, or loan your personal information to another party.
Your Rights as Data Subject
Under the Data Protection Act 1998 and GDPR, you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting us, using the details given in section 2.
Firstly, you have the right to control your personal information and you may request details of personal information which we hold about you (commonly known as a “data subject access request”).
If we do hold information about you, we will
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to;
- let you have a copy of the information in an intelligible form and as long as it does not compromise the privacy of another person or disclose their personal data.
Secondly, you have the right to request correction of the personal data that we hold about
- Although we take reasonable steps to ensure that the information we hold about you
- is accurate and complete, if you do not believe this is the case, you can ask us to update or
- amend it. 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. You
- can ask us to correct any mistakes by contacting our PDO.
You also have the right to request erasure of your personal data, asking 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. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.
You have the right to 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. In particular, for example, we do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of medical record-keeping and of establishing, exercise or defending legal claims.
You have the right to 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You also have the right to data portability and you can 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, electronic, 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.
You have the right to object to marketing and you can ask us to stop sending you marketing messages at any time and we must comply with your request. You can do this by contacting the DPO (see section 2 for details).
You have the right not to be subject to automatic decisions (i.e. decisions that are made about you by computer alone) that have a legal or other significant effect on you. If you have been subject to an automated decision and do not agree with the outcome, you can challenge the decision.
In some cases, we need your consent in order for our use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting Brows and Beauty’s DPO whose details can be found in section 2.
Responding to clients’ requests
If you wish to exercise any of the rights set out above, please contact our DPO. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we cannot comply with your request to exercise your rights, we will usually tell you why. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The right to complain to the Information Commissioner’s Office
You can complain to the Information Commissioner’s Office if you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have. In the meantime, you should make Brows and Beauty aware directly of any uses of your data to which you object. If you would like further information about any of the matters in this Privacy Notice or have any other questions about how we collect, store or use your personal information, please contact
the DPO using the details above.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which we process your personal data then we will provide you with an updated copy of the Policy.
This Privacy Notice was last updated on 19th April 2021.