This page details the Privacy Notice for Clients of Belmont Farm and Equine Vets ltd

The organisation responsible for the handling and processing of your personal information is. Belmont Farm and Equine Vets Ltd, Unit 5b Sigeric Business Park, Rotherwas, Hereford HR2 6BQ. This means that we are classed as a ‘data controller’ under the Data Protection Act 1998 and the General Data Protection Regulation (also known as GDPR).

Our registration number with the Information Commissioner’s Office is ZA143993

What information we collect about you:

The personal information we hold about you:

• Title, name, and address
• Contact details, including numbers for landline, fax and mobile, CPH, map reference and email address/es
• Contact details of significant other people on your farm, such as spouse and farm staff
• Engagement in company schemes and attendance of events and training courses
• Producer contract details
• Specific on-farm client preferences
• TB testing details including test type, history, contact log
• Farm data for health planning purposes

How we collect information about you:

• The personal information we hold about you is collected from you and other sources, such as APHA:
• When you become a client
• When you change your details
• When you purchase our products or services
• Each time you interact with us, respond to communications, surveys, or enter competitions
• When you make enquiries or raise concerns with any of our teams
• When you give us permission to access your data through milk records or farm software

What we use your information for and the legal basis for processing:

We may store and use your personal information for the purposes of:

• Administering your client account/s within Belmont Farm and Equine Vets Ltd (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Clinical services (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Managing data for electronic herd/flock management systems, lab reports, TB testing, herd/flock health schemes, insurance (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Using your payment details to process payments and for debt management purposes relating to your account (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Sending you news information including general updates, TB updates, new policy information, new product information (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Communicating with you about your account, including responding to your enquiries (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Undertaking general market research and statistical analysis, including analysing use of our website and social media. This allows us to develop new, or improve existing, products and services (as is necessary for our legitimate interests); and
• Fulfilling our obligations owed to a relevant regulator, tax authority or revenue service (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests)

Our “legitimate interests” as referred to above (and below) include our legitimate business purposes, upholding the roles and objectives of Belmont Farm and Equine Vets Ltd in operating our business in a client focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements.

Who we share your data with:

Where relevant given the nature of the products and services provided to you, we may also share your information with the following categories of third parties:

• Service providers we contract with who support the operation of our business, such as APHA, XL Farmcare UK Ltd, Veterinary Laboratories, (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests);
• Regulators and law enforcement agencies, including the police, the Financial Conduct Authority, HM Revenue and Customs or any other relevant authority who may have jurisdiction (as is necessary for compliance with our legal obligations)

Processing outside of the European Economic Area (EEA):

We only conduct business with companies that are registered in the EEA and as a result and therefore all these companies must comply with all aspects of GDPR.

How long your information is kept:

We will retain your personal information for a number of purposes, as necessary to allow us to carry out our business. Your information will be kept for up to 7 years on our main practice management systems after which time it will be deleted. Data retention periods are subject to change without further notice as a result of changes to associated law or regulations. If you have any questions in relation to the retention of your personal data, please contact our Data Compliance Officer on the details provided below.

Your rights:

THE RIGHT TO BE INFORMED

This privacy notice is to keep you informed about your data.

Our privacy notice sets out:

1. a) The types of data we hold and the reason for processing the data
2. b) Our legitimate interest for processing it
3. c) details of who your data is disclosed to and why, including transfers to other countries
   B: Where data is transferred to other counties, the safeguards used to keep your data secure are explained
4. d) How long we keep your data for, or how we determine how long to keep your data for;
5. e) Where your data comes from
6. f) Your rights as a data subject
7. g) Your absolute right to withdraw consent for processing data where consent has been provided and no other lawful reason for processing
   your data applies
8. h) Your right to make a complaint to the Information Commissioner if you think your rights have been breached
9. i) Whether we use automated decision making and if so, how the decisions are made, what this means for you and what could happen as a
   result of the process
10. j) The name and contact details of our data compliance officer

THE RIGHT OF ACCESS

You have the right to access your personal data which is held by us. Please contact the data compliance officer, details below.

THE RIGHT TO ‘CORRECTION’

If you discover that the data we hold about you is incorrect or incomplete, you have the right to have the data corrected. If you wish to have your data corrected, please contact the data compliance officer, details below.

Usually, we will comply with a request to rectify data within one month unless the request is particularly complex in which case we may write to you to inform you we require an extension to the normal timescale. The maximum extension period is two months.

You will be informed if we decide not to take any action as a result of the request. In these circumstances, you are able to complain to the Information Commissioner and have access to a judicial remedy.

Third parties to whom the data was disclosed will be informed of the rectification.

THE RIGHT OF ‘ERASURE’

In certain circumstances, we are required to delete the data we hold on you. Those circumstances are:

1. a) Where it is no longer necessary for us to keep the data
2. b) Where we relied on your consent to process the data and you subsequently withdraw that consent. Where this happens, we will consider whether another legal basis applies to our continued use of your data
3. c) Where you object to the processing (see below) and the Company has no overriding legitimate interest to continue the processing
4. d) Where we have unlawfully processed your data
5. e) Where we are required by law to erase the data

If you wish to make a request for data deletion, please contact the data compliance officer, details below.

We will consider each request individually, however, you must be aware that processing may continue under one of the permissible reasons. Where this happens, you will be informed of the continued use of your data and the reason for this.

Third parties to whom the data was disclosed will be informed of the erasure where possible unless to do so will cause a disproportionate effect on us.

THE RIGHT OF ‘RESTRICTION’

You have the right to restrict the processing of your data in certain circumstances.

We will be required to restrict the processing of your personal data in the following circumstances:

1. a) Where you tell us that the data we hold on you is not accurate. Where this is the case, we will stop processing the data until we have taken steps to ensure that the data is accurate
2. b) Where the data is processed for the performance of a public interest task or because of our legitimate interests and you have objected to the processing of data. In these circumstances, the processing may be restricted whilst we consider whether our legitimate interests mean it is appropriate to continue to process it
3. c) When the data has been processed unlawfully
4. d) Where we no longer need to process the data, but you need the data in relation to a legal claim

If you wish to make a request for data restriction, please contact the data compliance officer, details below.

Where data processing is restricted, we will continue to hold the data but will not process it unless you consent to the processing or processing is required in relation to a legal claim.

Where the data to be restricted has been shared with third parties, we will inform those third parties of the restriction where possible unless to do so will cause a disproportionate effect on us.

You will be informed before any restriction is lifted.

THE RIGHT TO DATA ‘PORTABILITY’

You have the right to obtain the data that we process on you and transfer it to another party. Where our technology permits, we will transfer the data directly to the other party.

Data which may be transferred is data which:

1. a) You have provided to us
2. b) Is processed because you have provided your consent or because it is needed to perform the client contract between us
3. c) Is processed by automated means

If you wish to exercise this right, please contact the data compliance officer, details below.

We will respond to a portability request without undue delay, and within one month at the latest unless the request is complex or we receive a number of requests in which case we may write to you to inform you that we require an extension and reasons for this. The maximum extension period is two months.

We will not charge you for access to your data for this purpose.

You will be informed if we decide not to take any action as a result of the request, for example, because the data you wish to transfer does not meet the above criteria. In these circumstances, you are able to complain to the Information Commissioner and have access to a judicial remedy.

The right to data portability relates only to data defined as above.

THE RIGHT TO ‘OBJECT’

You have a right to require us to stop processing your data; this is known as data objection.

You may object to processing where it is carried out:

1. a) In relation to the Company’s legitimate interests
2. b) For the performance of a task in the public interest
3. c) In the exercise of official authority
4. d) For profiling purposes

If you wish to object, you should do so, please contact the data compliance officer, details below.

In some circumstances we will continue to process the data you have objected to. This may occur when:

1. a) We can demonstrate compelling legitimate reasons for the processing which are believed to be more important than your rights
2. b) The processing is required in relation to legal claims made by, or against, us

If the response to your request is that we will take no action, you will be informed of the reasons.

RIGHT NOT TO HAVE AUTOMATED DECISIONS MADE ABOUT YOU

You have the right not to have decisions made about you solely on the basis of automated decision making.

However, Belmont Farm and Equine Vets Ltd does not make any decisions based on such processes.

In circumstances where we use special category data, for example, data about your health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership the Company will ensure that one of the following applies to the processing:

1. a) You have given your explicit consent to the processing
2. b) The processing is necessary for reasons of substantial public interest

However, Belmont Farm and Equine Vets Ltd does not make any decisions based on such processes.

If you are not satisfied with how we are processing your personal information, you can make a complaint to the Information Commissioner.

You can find out more about your rights under data protection legislation from the Information Commissioner’s Office website: www.ico.org.uk.

Data Compliance Officer – Andrew Cooke, Belmont Farm and Equine Vets Ltd, Unit 5b Sigeric Business Park, Rotherwas, HR2 6BQ. 01432 351471