Privacy Policy

Data Controller

Renee Broughton-Johnson (Director)

Privacy Policy for Branded Eyewear Ltd

This privacy notice tells you what to expect us to do with your personal information.

Contact details

Post:

Brand Eyewear, Gloucester Quays Designer Outlet, St Ann’s Way,Gloucester, Gloucestershire, GL1 5SH, GB

Telephone

01452 903212

Email

admin@brandeyewear.co.uk

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

Name, address and contact details
Gender
Pronoun preferences
Date of birth
Health information (including medical conditions, medical requirements and medical history)
Test results (The Eye Test’s subsequent spectacle prescription results)

We collect or use the following personal information to comply with legal requirements:

Name
Contact information
Any other personal information required to comply with legal obligations

We collect or use the following personal information for information updates, marketing or market research purposes:

Names and contact details
Addresses
Records of consent, where appropriate

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details
Addresses
Payment details
Purchase or service history
Financial transaction information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the Information Commissioner’s Office website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
The processing of specific personal information, namely Name, Address, date of birth, email address, telephone number enables our organisation to easily access customers who have made spectacles with our organisation. The need to retain and process the copy of the customer's specific valid spectacle prescription from their testing Optometrist is a legal requirement by the regulating body of The General Optical Council for the supply of an prescription optical device ie. spectacles
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
The processing of specific personal information, namely Name, Address, date of birth, email address, telephone number enables our organisation to easily access customers who have made spectacles with our organisation. The need to retain and process the copy of the customer's specific valid spectacle prescription from their testing Optometrist is a legal requirement by the regulating body of The General Optical Council for the supply of an prescription optical device ie. spectacles.
For Financial and Tax Records - To retain and process transaction data (such as customer names, addresses, and purchase details) for the required statutory period to comply with financial, tax, and audit obligations.The Companies Act 2006 or HMRC requirements (generally 6 years + current year for financial records in the UK).
For Product Safety Reporting - To report necessary customer and product data to regulatory bodies (e.g., MHRA, European Commission, GOC) in the event of a serious adverse incident or product safety recall, as required by medical device regulations.
For the Medical Devices Regulations (UK/EU) which mandate post-market surveillance and reporting.
For Statutory Disclosure - To disclose personal data to law enforcement agencies, fraud prevention services, or other governmental bodies when legally compelled by a court order or official request, Criminal Justice Act, Police and Criminal Evidence Act, etc.

Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Service and Practice Updates - To keep our customers informed about key changes to our practice, services, hours, or any new government health schemes that may directly affect their entitlement to care or appointments. The interest is in maintaining a professional and transparent relationship. The customer reasonably expects to be kept informed about the service they use.
Market Research (Internal) - To analyze anonymous or aggregated data related to customer demographics and service usage (e.g., number of sight tests, most common products purchased) to improve the quality of our service, products, and practice efficiency. The interest is in running a commercially viable and improved business. The impact on the individual is minimal if data is aggregated or pseudonymised.
Feedback and Review Requests - To collect voluntary feedback on the quality of the service, the performance of our staff, and the efficiency of the practice following a purchase, for the purpose of maintaining high professional standards. The interest is quality control and business reputation. The customer has an expectation to be asked for feedback on a service they have received.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Dealing with Queries, Complaints, and Claims - to manage, investigate, and respond to queries, complaints, and legal claims raised by customers, suppliers, regulatory bodies, or any third party concerning our products and services. This includes using contact and transaction data to communicate updates, carry out root cause analysis, ensure appropriate remedial action, and protect our business from liability and fraud.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Where we get personal information from

Directly from you
Other health and care providers
none

How long we keep information

Spectacle prescription - 10 years after the customer’s last visit

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

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

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint