The Optical Consumer Complaints Service (OCCS) is operated by Nockolds Solicitors Ltd. This website privacy notice explains what personal information we collect from you when you use our website and how we use it, the conditions under which we may disclose it to others and how we keep it secure. It will also tell you about your privacy rights and how the law protects you. We respect your privacy and we are committed to protecting your personal information.

We are registered with the Information Commissioner’s Office under registration number Z3224785. We will not disclose your personal details to any third parties unless it is necessary or we are legally obliged to do so. On those occasions when we do need to disclose your personal information we will do so in accordance with the General Data Protection Regulations (GDPR) which came into effect on 25 May 2018.

Important Information and Who We Are

Controller and Processor This notice aims to give you information on how we collect and process your personal information when using our website. It is issued on behalf of Nockolds Solicitors Limited and where the term ‘we’, ‘us’ or ‘our’ is used, we are referring to the relevant company responsible for processing your personal information.  We are the ‘Controller’ and ‘Processor’ of the personal information you provide us with. Your personal information will be securely stored confidentially on our computer systems and/or in paper files.

Contact Details

Our full details are:

Full Name: Optical Consumer Complaints Service
Address: 6 Market Square, Bishop’s Stortford, Hertfordshire, CM23 3UZ
Telephone Number: 0344 800 5071
Email Address: privacy@opticalcomplaints.co.uk

Nockolds Solicitors is a company regulated by the Solicitors Regulation Authority under ID numbers 567738 and 605527. Our website is managed by the Marketing Team at Nockolds Solicitors Ltd.

What Personal Information We Collect From You

Under GDPR, personal information is defined as ‘any information relating to an identified or identifiable natural person’. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

The personal information which we will record when you use our website is general information that you supply about yourself – such as your name, address, gender, date of birth and contact details.

We do collect sensitive personal information in order to report to the General Optical Council on complaint trends. This includes racial or ethnic origin, religious beliefs and sexual orientation. This sensitive personal information is held anonymously and cannot be identified or linked to an individual. We do not collect any information about criminal convictions and offences.

With regard to each of your visits to our site we may automatically collect the following information:

• Technical information including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site www.opticalcomplaints.co.uk (‘our site’). This includes information provided at the time of referring your enquiry or requesting further services. We may also ask you for information when you report a problem with our site;
• If you contact us, we may keep a record of that correspondence;
• Details of your visits to our site and the resources that you access.

IP Address

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

Why We Need It

We use information we record about you in the following ways:

• To ensure that content from our site is presented in the most effective manner for you and for your computer;
• To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• To carry out our obligations arising from any contracts entered into between you and us
• To allow you to participate in interactive features of our service, when you choose to do so;
• To notify you about changes to our service;
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, which may also include us instructing third parties to analyse the data from you from our website; and
• Other ways set out in our Privacy Notice

How We Use Your Personal Information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstance:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

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.

Marketing and Your Personal Information

We may use your personal information that we have collected in accordance with this website privacy notice to contact you about our products or services, events etc. which we feel may interest you. These direct marketing communications may be provided to you by social media channels, email, post or telephone.

Your personal information will be used solely by the OCCS, save in the following circumstances:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Nockolds Solicitors Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal or contractual obligation, or in order to enforce or apply our terms of use terms of use;
• To analytics and search engine providers that assist us in the improvement and optimisation of our site;
• To carefully selected third parties, where we have agreed to run a joint seminar or event with them and we believe the event may be of interest to you.

How We Protect Your Personal Information

We recognise that your personal information is valuable and we take all reasonable measures to protect it whilst it is in our care.

We have exceptional standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Similarly, we adopt a high threshold when it comes to confidentiality obligations and both internal and external parties have agreed to protect confidentiality of all information; to ensure all personal information is handled and processed in line with our stringent confidentiality and data protection policies.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this website privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How Long We Will Keep It For

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount of your personal information, the nature and sensitivity of it, the potential risk of harm from unauthorised use of disclosure, the purposes for which we processed it and whether we can achieve these purposes though other means, and the applicable legal requirements.

Your Rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at enquiries@opticalcomplaints.co.uk.

Our site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Request Access to Your Personal Information

GDPR gives you the right to see a copy of the personal information that we hold about you. You can ask us to supply you with copies of both paper and/or computer records and related information. This is called a ‘Subject Access Request’.

Your request to us must be in writing and we will respond within one month from receipt of your request. Requests should be made in writing and sent to us by post to the relevant office address or by email to privacy@opticalcomplaints.co.uk.

Where we consider requests to be manifestly unfounded or excessive, in particular because they are repetitive, we are entitled to charge a reasonable fee taking into account the administrative costs of providing the information or we can refuse to respond. If we refuse to respond to your request, we will explain why and may ask you to specify the information the request relates to.

Further information on Subject Access Requests can be obtained from the Information Commissioner’s Office (ICO) at www.ico.org.co.uk.

Request Correction of Your Personal Information

We take all reasonable steps to ensure the personal information we have for you is accurate and up to date. If you think that what we have is not accurate or up to date, please tell us as soon as possible and we will correct it.

It is your responsibility to ensure that the personal information you provide is correct and that you notify us of any changes to enable us to correct our records e.g.: address and telephone number/s. We may need to verify the accuracy of any new information you provide to us.

Request Erasure of Your Personal Information

This enables you to ask us to delete or remove personal information 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 information 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 information 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 and the right to erasure does not apply where there is a lawful reason for continue processing. If applicable, we will explain these to you at the time of your request.

You can also exercise the right at any time by contacting us at enquiries@opticalcomplaints.co.uk.

Object to Processing of Your Personal Information

You may object 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 information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

Request Restriction of Processing Your Personal Information

This enables you to ask us to suspend the processing of your personal information in the following scenarios:

• If you want us to establish its accuracy;
• Where our use is unlawful but you do not want us to erase it;
• Where you need us to hold it even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use but we need to verify whether we have overriding legitimate grounds to use it.

Request Transfer of Your Personal Information

If we are asked to transfer your personal information to you or to a third party, we will provide this to you, or a third party you have chosen, 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. This relates to portability of your personal information only.

Right to Withdraw Consent

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

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.

Queries About Our Use of Your Personal Information

You can exercise any of your rights at any time by contacting us at enquiries@opticalcomplaints.co.uk.

If you have a query about how we have handled your personal information, you can contact our Data Protection Officer who will be happy to look in to this for you. You can contact our Data Protection Officer by email at privacy@opticalcomplaints.co.uk.

Your also have the right to contact the Information Commissioner’s Office (ICO) direct. Please see their website www.ico.org.co.uk. However we would appreciate the chance to deal with your queries before you approach the ICO so please contact us in the first instance.