Privacy Policy


1.Welcome to The London Head and Neck Clinic’s privacy notice. We respect your privacy and are committed
to protecting your personal data. This privacy notice will inform you as to how we look after
your personal data when you visit our website (regardless of where you visit it from) and tell
you about your privacy rights and how the law protects you.


Purpose of this privacy notice


2. This privacy notice aims to give you information on how we collect and process your
personal data through your use of this website. This website is not intended for children and we
do not knowingly collect data relating to children.

3. It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.


Data Controller


4. The London Head and Neck Clinic is the controller and responsible for your personal data
(collectively referred to as “the Clinic”, “we”, “us” or “our” in this privacy notice).

5. If you have any questions about this privacy notice, including any requests to exercise your
legal rights, please contact The Data Controller, The London Head and Neck Clinic, 116 Harley Street, London, W1g 6HL.

6. You have the right to make a complaint at any time to the Information Commissioner’s Office
(ICO), the UK supervisory authority for data protection issues ( We would,
however, appreciate the chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.


Changes to the privacy notice and your duty to inform us of changes


7. It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us.


Third-party links


8. This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the privacy notice of every
website you visit.


The data we collect about you


9. Personal data, or personal information, means any information about an individual from which
that person can be identified. It does not include data where the identity has been removed
(anonymous data).

10.We may collect, use, store and transfer different kinds of personal data about you which we
have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and
telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to
access this website.
• Profile Data includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and
• Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.

11.We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy notice.

12.We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health and genetic and
biometric data). Nor do we collect any information about criminal convictions and offences.


How is your personal data collected?


13.We use different methods to collect data from and about you including through direct
interactions. For example, you may give us your identity, Contact and Financial Data by filling
in forms or by corresponding with us by post, phone, email or otherwise.


How we use your personal data


14.We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data 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.

15.Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your personal data.


Opting out


16.You can ask us or third parties to stop sending you marketing messages at any time.
Change of purpose

17.We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact us.

18.If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

19.Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.


Disclosures of your personal data


20.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.


International transfers


21.Whenever we transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is implemented
and we will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data by the European Commission.


Data security


22.We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
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.

23.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.


Data retention


24.We will only retain 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

25.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 unauthorised 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

26.In some circumstances you can ask us to delete your data. In some circumstances we may
anonymise your personal data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely without further notice
to you.


Your legal rights


27.Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Your rights are to: –

• Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it
• Request correction of the personal data that we hold about you. 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.
• Request erasure of your personal data. This enables you to ask 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.
• 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.
• 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.
• 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, 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.
• Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before
you withdraw your consent. If you withdraw your consent, we may not be able to provide
certain products or services to you. We will advise you if this is the case at the time you
withdraw your consent.


28.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


29.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.


30.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.