Independent Hearing Services – Privacy Policy

1. Who we are

Independent Hearing Services is committed to protecting personal data. For processing where we determine why and how information is used, we act as data controller.

Independent Hearing Services
323 New Road, Ferndown, Dorset, BH22 8EJ, United Kingdom
Telephone: 01202 861522
Email: info@independenthearing.com
Website: https://www.independenthearing.com/

2. Scope and applicable law

This policy explains how we collect, use, share, retain and protect personal data when you use our website, request a callback, make an enquiry or appointment, receive hearing-related services or a home visit, purchase or use hearing products, or otherwise interact with us. We process personal data under applicable UK data protection law, including the UK GDPR, Data Protection Act 2018, PECR and applicable amendments to the UK framework.

3. Information we may collect

We may collect identity and contact details; enquiry and callback information; appointment and home-visit information; hearing and health information; hearing-test and assessment results; ear-health and ear-wax information; hearing-aid fitting, programming, serial-number, repair, warranty and aftercare records; transaction information; correspondence and complaints; website technical and usage information; and marketing preferences. We collect only information reasonably necessary for relevant purposes.

4. Website forms and enquiries

Website contact or callback forms may collect your name, email address, telephone number, service of interest, enquiry content, submission metadata and anti-spam or security information where applicable. We use this information to respond, contact you as requested, provide information and arrange services. Do not submit unnecessary medical information, passwords, identification documents or complete payment-card details through a general enquiry form. Detailed health information should be provided through the appropriate consultation process.

5. How and why we use information

We may process information to respond to enquiries and take pre-contractual steps; arrange and manage appointments; provide hearing assessments, ear-wax services, hearing-aid services, repairs, aftercare and home visits; manage products, payments, warranties and complaints; maintain appropriate clinical, business, tax, insurance and legal records; protect systems and prevent fraud; establish or defend legal claims; send marketing where permitted; use cookies where consent is required; and protect vital interests in emergencies. Our lawful bases may include contract, steps before contract, legitimate interests, legal obligation, consent and vital interests, depending on the circumstances.

6. Health and special category data

Health and hearing information may be special category personal data. We may process it where reasonably necessary to assess hearing needs, provide hearing tests and related services, assess suitability, provide ear-wax or hearing-aid services, fit and maintain devices, provide aftercare, support continuity of care, meet appropriate professional or insurance requirements, and establish or defend legal claims. We will identify both an Article 6 lawful basis and an applicable Article 9 UK GDPR condition. Depending on the circumstances, this may include an applicable health or social care condition where its requirements are met, explicit consent where appropriate, or processing necessary for legal claims. We will not rely on a condition that does not apply to the actual processing.

7. Clinical and hearing-care records

Where relevant, we may maintain consultation records, hearing assessments and test results, recommendations, device fittings and settings, repairs, servicing and aftercare information. These records may be needed for safe and consistent services, continuity, warranties, complaints, insurance and legal requirements. Access is limited to those who reasonably require it.

8. Home visits

For home visits, we may process your address, contact details, relevant access information, appointment details and information necessary to provide the requested hearing service safely and appropriately.

9. Manufacturers, laboratories, repairers and suppliers

We may share limited information with hearing-aid manufacturers, laboratories, repair providers, suppliers or specialist providers where necessary to provide products, fitting, programming, repairs, servicing or warranties. Depending on the activity, a provider may act as our processor, an independent controller, or both for different purposes. Appropriate processing contracts will be used where legally required.

10. Payments

We may process transaction information to take payments, issue refunds and maintain records. Where a third-party provider processes card payments, it may process card and transaction data under its own privacy terms. We do not ordinarily need to store complete card details where payment is processed directly by the provider.

11. Marketing

We may send information about services or products where permitted by law. Where PECR requires consent for electronic marketing, we will obtain it. You may object or withdraw consent at any time by contacting info@independenthearing.com. Opting out does not prevent necessary service communications.

12. Cookies and analytics

Our website may use cookies and similar technologies for essential functions, security, preferences and analytics. Strictly necessary cookies may be used where permitted without consent. Where consent is legally required, non-essential technologies should not be activated before valid consent. The website should maintain an accurate Cookie Policy identifying technologies actually deployed, their purposes, providers and durations.

13. Sharing information

We do not sell personal data. Where necessary and lawful, we may share information with IT, hosting, cybersecurity, communications, appointment, payment, storage and backup providers; hearing-aid manufacturers and suppliers; repair and laboratory providers; accountants, insurers, solicitors and professional advisers; and public authorities where required or permitted by law. We apply data minimisation and appropriate contractual and confidentiality controls where required.

14. International transfers

Some providers may process information outside the UK. Where UK law restricts a transfer, we will use a lawful mechanism such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to EU Standard Contractual Clauses, or another applicable safeguard or derogation, together with supplementary measures where required.

15. Security and confidentiality

We use reasonable technical and organisational measures designed to protect information against loss, alteration, unauthorised disclosure or access. Measures may include access controls, password protection, secure systems, updates, backups, malware protection, monitoring and confidentiality controls. Health and hearing information is treated with particular care. No electronic system can be guaranteed completely secure.

16. Retention

We keep information only as long as reasonably necessary for its purposes, including continuity of service and applicable clinical, legal, tax, accounting, insurance, warranty, contractual and legal-claims requirements. Different records may have different retention periods. We consider sensitivity, purpose, professional requirements, limitation periods and legal obligations, and delete or anonymise information when no longer required unless continued retention is required or permitted.

17. Your rights

Subject to applicable conditions and exemptions, you may have rights to be informed; access your data; correct inaccurate data; request erasure or restriction in certain circumstances; object to certain legitimate-interest processing and at any time to direct marketing; data portability where applicable; withdraw consent; receive protections concerning certain solely automated significant decisions; and complain to the UK data protection regulator. These rights are not absolute.

18. Exercising rights and complaints

Contact info@independenthearing.com or 01202 861522. We may reasonably verify identity and will respond within the period required by law. You will not normally be charged, although the law permits fees or refusal in limited circumstances.

If dissatisfied, you may complain to the UK data protection regulator. We encourage you to contact us first.

Information Commissioner’s Office (ICO)
Website: https://ico.org.uk/
Telephone: 0303 123 1113

19. Children and vulnerable individuals

Where services involve children or vulnerable individuals, we take appropriate care regarding transparency, capacity, safeguarding, consent or other lawful bases, and involvement of parents, guardians, carers or authorised representatives. We do not disclose information to another person merely because of their relationship to the client; authority, consent, capacity, safeguarding and applicable law will be considered.

20. Automated decision-making

We do not ordinarily make decisions about clients based solely on automated processing that produces legal or similarly significant effects. If this changes, we will provide information and safeguards required by law.

21. Third-party websites

Our website may link to third-party websites, social media, manufacturers, mapping or other services. Those organisations may act as independent controllers under their own notices. We are not responsible for services we do not control, without limiting responsibilities imposed on us by law for our own use of providers.

22. Changes to this policy

We may update this policy to reflect changes in services, systems, suppliers, law or privacy practices. The latest version will be published on our website with an updated date and, where appropriate, material changes may be communicated by another suitable method.

23. Contact us

Independent Hearing Services
323 New Road, Ferndown, Dorset, BH22 8EJ, United Kingdom
Telephone: 01202 861522
Email: info@independenthearing.com
Website: https://www.independenthearing.com/

Compliance note

Before publication, this notice should be checked against the organisation’s actual live systems, including website forms, cookie scanner, analytics, appointment or patient-management systems, payment providers, manufacturers, repair providers, marketing platforms, CCTV or call recording if used, and referral arrangements. Independent Hearing Services should also assess its ICO data protection fee obligations and maintain appropriate internal records, processor contracts, security controls, retention schedules and consent records. A privacy notice is one part of compliance and does not itself establish full compliance.