Privacy Policy

Who We Are

OCL Vision Group Ltd trading as “OCL Vision” (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data when you are using the company’s website. 

Our registered office is at 55 New Cavendish Street, London, W1G 9TF. We are a company registered in England and Wales under company number 11353298. We have registered with Information Commissioner’s Office [ICO] for data protection and privacy matters. Our ICO registration no is ZA473865. We act as the data controller/data processor when processing your data. Our designated Appointed Person for your consent and privacy related queries, is Vanessa Fernandis, who can be contacted at OCL Vision, 55 New Cavendish Street, London, W1G 9TF. Tel No: 0203 993 2020. 

Information That We Collect

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. 

The personal data that we collect from you is: 

• Contact details: including name, email, telephone number and physical address
• Personal details: including gender and date of birth
• Medical eye data: Specific eye history, including prescriptions and previous eye surgery. These are collected during your appointment with our consultant [after becoming a patient to us] to provide your treatment plan.
• Other health data: General health conditions and allergies. These are collected to provide your treatment plan.
• Payment or credit card information: this is taken when paying for your appointment or surgery. We use a secure card processing terminal and a secure online payment portal to process payments and  your card details are stored via tokenisation for future payment processing. When interacting with our Sites, data is automatically collected and shared with The Company by the technology platforms providing the experience. For example, your web browser or mobile device may share certain data with The Company as those devices interact with our Sites. More information about these practices is included in the Cookies and Pixel Tags section below. 
• Sensitive data: including race and ethnicity. We collect this information as some eye conditions are more common in certain ethnicities such as Keratoconus; this data is taken at the stage of an individual becoming a patient.

We may also ask you to complete surveys that we use for research and Marketing purposes, although you do not have to respond to them. 

We collect information in the below ways: 
Registration Form (electronic or paper), Website Contact form, From your GP/Doctor(referral) and any notes from your consultation with the specialist during appointments & treatments.

How We Use Your Personal Data

We take your privacy very seriously and will never disclose, share your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:

• We collect your personal data to provide service(s) related to your medical care (vision related) and to ensure that we provide relevant ongoing care.
• We collect and store your personal data as part of our legal obligation to the General Medical Council, for business accounting and tax purposes.
• We will occasionally send you marketing information where we have assessed that it is beneficial to your ongoing medical care. Such information will be non-intrusive and is processed on the grounds of legitimate interests.

How we communicate with you 

We are likely to communicate with you by telephone, SMS, email, and/or post. If we call the telephone number(s) which you have provided, and the call directs to a voicemail and/or answering service, we may leave a voice message on your voicemail and/or answering service. 

In particular: 

• to provide you with timely updates and reminders about your care, we may send you SMS messages and/or email.
• to provide you with your medical information (including test results and other clinical updates) and/or invoicing information, we may communicate with you by encrypted email.
• the first time we send you any important encrypted email eg one that we are not also sending by post or which requires you to take an action, we will try to contact you separately to ensure that you are able to access that encrypted email.
• if we have your mobile number or your email address we may use them to ask you to complete patient surveys which are for the purpose of improving our service or monitoring outcomes and are not a form of marketing.

Patient surveys, audits and initiatives 

We may contact you to ask you to participate in patient surveys regarding your care.  We will usually send these surveys to you by email or SMS message. These surveys are not a form of marketing and they do not try to sell you any further products or services. They are solely to get your feedback on your experience, and to improve the quality and safety of the healthcare services we offer to future patients. It is entirely up to you whether you participate in the surveys and you can unsubscribe from receiving further survey requests. We use the responses you provide to make improvements to our services. You may also opt-in to receive a call back to discuss your responses. 

In addition, we may also contact you to invite you to participate in online surveys regarding the clinical outcomes of your care called Patient Reported Outcome Measures (“PROMs”). Again, these are not a form of marketing. We may send you an initial invitation asking you to participate before you receive your care, by post, SMS, email or in person when you attend the hospital for your care. If you choose to complete a PROMs survey you will also receive subsequent surveys after your care to help establish the benefit you have gained from treatment. 

Your Rights

You have the right to access any personal information that we process about you and to request information about: 

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request the erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We use other processor(s) to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Hospitals/Medical Centers

We use external hospitals/medical centres to perform your surgeries or treatments [for example BMI The Clementine Churchill Hospital, Spire Harpenden Hospital, King Edward VII Hospital, Spire London East]. We share your information with them if you are booked in for treatment with them. They are obliged by the law to enter your personal and health related data onto their system, in order for us to provide you the relevant treatment and care at their facilities.

Schwind

Schwind supply our diagnostic and laser equipment and we therefore may need to share patient data with them occasionally for evaluation of scans or to produce specific treatment plans.

Trustpilot

We use Trustpilot to gain your feedback independently about our services, and your experience with us. Trustpilot may process your personal data such as your name, email [not medical data] to obtain your feedback.
For more information about Trustpilot and their privacy notice, please visit their website, trustpilot.com.

Google

We use Google to gain your feedback independently about our services, and your experience with us. Trustpilot may process your personal data such as your name, email [not medical data] to obtain your feedback. 
For more information about Trustpilot and their privacy notice, please visit their website: www.google.com.

Telephone Answering Services

We use  External Partners to answer your calls and take messages while our admin team are busy, or we are closed for business [out of office hours]. On behalf of OCL Vision they are instructed to collect your personal details and pass on to us in order to process your queries effectively. For more details please contact our customer service team. 

Third-party Service Providers

We use third-party organisations who provide support that enables our organisation to perform effectively & safely. This includes support for website hosting and moderating, mobile app, hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, collection of anonymized patient experience & outcome data, email and direct mail delivery services, credit card processing, auditing services and other services.

Safeguarding Measures

OCL Vision takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We comply with UK data protection law and all the applicable medical confidentiality guidelines issued by professional bodies such as the General Medical Council. Your confidential medical information will only be disclosed to those involved with your treatment or care, or in accordance with UK law and guidelines from professional bodies.

We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: SSL, TLS encryptions when communicating between systems, pseudonymization (where it’s possible), restricted access, IT authentication, firewalls, anti-virus/malware, Email encryption.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to OCL Vision however, as this information is required for us to provide you with our services, we will not be able to offer all of our services without it.

Data Minimisation and Data Retention

We aim to never collect or store any information that is not required for the delivery of the services to which you subscribe. Any information that we do collect is and will always be explicitly accounted for in this Privacy policy. We will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above, or required for us to maintain a high level of care, in accordance with EU General Data Protection (GDPR) regulation and the ePrivacy regulation.

We retain your personal data for as long as we hold ‘legitimate interests’ to fulfil the purposes for which we collect it, until the interests cease to exist unless if otherwise required by law. For example, we retain your medical records for minimum of 8 years.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data

We may need to process sensitive personal information (known as special category data) about you, to provide episodes of treatment and ongoing medical care. Where we collect such information, we will only request and process the minimum necessary for the specified purpose.

Where we rely on your consent for processing special category data, we will obtain your explicit consent. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

Our Supervisory Authority

Information Commissioner’s Office
Wycliffe House
Water Lane,
Wilmslow,
Cheshire SK9 5AF
Tel: 0303 123 1113
ico.org.uk