Introduction

This privacy notice is issued on behalf of the FODO Group so when we mention "FODO", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the FODO Group responsible for processing your data. The Federation of Optometrists and Dispensing Opticians is the Data Controller for the purposes of data protection law, and responsible for the collection of your Personal Data and how it is used by the members of the FODO Group.

[email protected]

16 Upper Woburn Place, London, WC1H 0BS 

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).

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes postal address, email address and telephone numbers.

Publication Data – any biographical or other publicly-available data published online or in any other publicly-available medium.

Financial Data includes bank account and payment card details.

Transaction Data includes details about your membership and payments to and from you, and other details of services provided by us and by related Third Parties through the course of your membership.

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, details relating to your membership, your interests, preferences, feedback and survey responses. 

Usage Data includes information about how you use our website, your membership and related services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will 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.

We collect and process Special Categories of Personal Data (which includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data) in very limited circumstances – specifically when any member using our medical malpractice insurance scheme may need to share health records with us that relate to any such claim and related claimant or any associated legal advice provided to our members. We process this data based on our legitimate interest for the purposes of defending legal claims involving our members in accordance with Articles 6 and 9 of the General Data Protection Regulation. We minimise the collection of any Special Category Data and will seek legal advice on a case-by-case basis on how long it should be retained on file.

We collect any information about criminal convictions and offences when providing regulatory defence services to our members. We process this data based on our legitimate interest for the purposes of defending legal claims involving our members in accordance with Article 6 and 10 of the General Data Protection Regulation, as well as Paragraph 33 Schedule 1 of the Data Protection Act 2018 on the basis that such processing is necessary for the purpose of, or in connection with obtaining legal advice in relation to or defending prospective or actual legal claims against our members. We minimise the collection of Criminal Conviction and Offence Data and will seek legal advice on a case-by-case basis on how long it should be retained on file.

 

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services through your membership). In this case, we may have to cancel any service provided through your membership, but we will notify you if this is the case at the time.

• Direct interactions. 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. This includes Personal Data you provide when you:
  • enquire about or apply for membership or to use our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter or survey or participate in our research;
  • participate in any of our committees; or
  • give us feedback or contact us.

 

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:

Identity, Contact, Special Category and Publication Data in the following circumstances:

in relation to any claim against our members which would involve the use of our medical malpractice scheme – please note that this may include Special Category Data as referred to below;

websites or other online or offline publications which have been made publicly- available

Contact, Financial and Transaction Data from providers of accounting technical, payment and delivery services such as Xero, whose make use of AWS servers based outside the EU.

Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the EU.

 

Most commonly, we will use your Personal Data in the following circumstances:

Where we need to perform the contract for membership 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 obligation.

Please see the Glossary and Lawful Basis sections below to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Our business model means we also hold other personal data and engage with a wide range of stakeholders – including but not limited to members, committee members, potential members, other stakeholders we have a direct or indirect relationship with, charities, elected representatives and national and international representative bodies. The table below summarises personal data that we might hold regarding these activities

Please 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 where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To receive and deal with any enquiry about membership or any request for support	Information including relating to anyone making an enquiry, including: (a) Identity (b) Contact	Necessary for our legitimate interests (to develop our services, grow our business and operate and operate an effective and successful representative and professional body)
To register new members	Information relating to our members, including: (a) Identity (b) Contact	Performance of a contract with our members, specifically maintaining their membership.
To process payments relating to memberships, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	Information relating to our members, including: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with members, specifically maintaining their membership. (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with members which will include: (a) Notifying Members about changes to our terms of membership or privacy notice (b) Asking Members to participate in research or take a survey	Information relating to our members, including: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with members, specifically maintaining their membership (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how members use our services)
For the provision of legal support to our Members as mart of our Medical Malpractice insurance scheme	Information relating to potential and actual claimants, solicitors, lawyers, witnesses, advisers, consultants and professional experts (a) Identity (b) Contact (c) Special Category Data	the purpose of, or in connection with, any legal proceedings (including prospective proceedings) the purpose of obtaining legal advice, or the purposes of establishing, exercising or defending legal rights
To maintain our relationship with Direct and Indirect Stakeholders including (without limitation) Committee Members or Elected Representatives	(a) Identity (b) Contact (c) Publication Data	Necessary for our legitimate interests (to develop our services, grow our business and operate and operate an effective and successful representative and professional body)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how members use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, member relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of members for our and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

 

We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes outside of the FODO Group. 

Cookies

A cookie is a small file of letters and numbers that we store on your browser or on your device, if you agree. Cookies contain information that is transferred to your device.

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We use the following cookies:

·         Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

·         Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

·         Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

·         Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

 

 

Cookie Title Cookie Name	Description & Purpose	Type & Duration
__cfduid	The cookie is set by CloudFare. The cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.	Necessary   4 Weeks
CookieControl	This cookie is set by Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".	Necessary   3 Months
ASPSESSION*	Used by the server to anonymously save session information like login status	Necessary Session
_ga	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.	Optional Analytics
_gid	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.	Optional Analytics   1 Day
_gat	This cookies is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites.	Optional Analytics Performance   1 Minute

 

 

 

We may share your Personal Data with the parties set out below for the purposes set out in the table

Purposes for which we will use your Personal Data above.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy notice.

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 any of 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.

Whenever we transfer your personal data to service providers outside 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:

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.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7.Data security

This means how long we keep your personal details might vary. For example:

•           Our claims occurring insurance cover means we need to keep information about your cover in case a claim arises against you in the future, including after you have retired or after your membership has come to an end. 

•           If you supplied references as part of your application process, this personal information is destroyed after two years of active membership or your date of leaving membership (whichever is sooner).

In the case of stakeholders we have a direct relationship with, we will retain your personal data for as long as is necessary for the purpose it was collected. This will typically mean until the point you leave a committee or specific role, unless you decide to stay in contact with us by updating your details.

In the case of stakeholders we might have an indirect relationship with, we will retain your personal data for as long as is necessary for the purpose it was collected. This will typically mean until the point you are no longer a local representative and or have your contact details on a recognised public site removed.

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

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.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

          

Service providers acting as processors based in the United Kingdom, who provide IT and system administration services.

Professional advisers and service providers acting as processors or joint controllers including lawyers, bankers, auditors, underwriters and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services to the FODO Group and our members.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances