Privacy

We may also collect data about you from certain third parties such as:

• Regulatory bodies (such as RCVS, VCI) when, as part of our conditions, we need to be able to verify your registration.
• Your employer.
• Other contacts you have nominated and authorised us to speak to about your membership.
• Claimants, potential claimants or their representatives.

Individuals involved in a complaint or claim against a VDS Member

If you make a complaint about a VDS Member or raise formal concerns with a body such as the RCVS, VCI or the Police then, in order to provide advice or assistance to our Member we will ask them to provide:

• The relevant parts of your practice records which will include your personal data.
• An account of events leading to the complaint or claim.
• We may seek an expert opinion if necessary.

 If you make a claim against a VDS Member, we may need to ask you for:

• Your account of events leading to the complaint or claim against our Member.
• Information in support of your claim such as your financial records, and any details of expenses, if you are claiming for losses.
• In some instances, your bank account information.

We may also collect information from third parties, including other Members, former Members, other veterinary professionals or representatives acting on their behalf, representatives acting on your behalf, and providers of services that allow us to verify the details that you provide to us, such as bank account information.

Veterinary professionals involved in a VDS Member's claim

If a claim has been made against a VDS Member and you are a co-defendant or involved in the case, we will collect information about your clinical involvement in the case.

We may also collect information from third parties, including:

• Members, former Members, other veterinary professionals or representatives acting on their behalf, representatives acting on your behalf, claimants or potential claimants, or their representatives.

Training course and event attendees

If you attend a training course or other event run by VDS or VDS Training, your personal data will be collected and processed. This includes personal data that you provide voluntarily (or via a third party booking the event on your behalf), such as your name, contact details, payment information, dietary and access requirements. Videos and/or photographs may be taken of you during the duration of the training course or other event and you may be invited to agree for images of you or any testimonials you may provide to be used in publicity material for any of VDS, VDS Training or VDS Support by signing an appropriate consent form.

Suppliers of services to VDS, including experts and contractors

We may collect personal data about our suppliers, including experts and individuals associated with our suppliers, so that we can support our Members with business services.

We may collect information such as:

• Names and addresses, bank information, qualifications and details of individuals working on the contract.

Executors of a member's estate

The personal information we collect may include information which will help us update our membership records and provide assistance with claims brought against the Member’s estate.

Third party authorised contacts

If you are a third party and the VDS Member has given their written permission for us to discuss their membership details with you on their behalf, we will collect your personal details so that we can contact you. 

How we collect your personal information and why we have it 

We collect and process personal information that relates to our Members, the employees or other people who work in veterinary practices alongside our Members, our Members’ authorised agents, non-Members (such as veterinary students), prospective Members or those who have expressed an interest in products or services from VDS, VDS Training or VDS Support), third party claimants, complainants and others involved with claims or potential claims. We also collect personal information relating to criminal and disciplinary investigations or proceedings. This data is obtained: 

• directly from you (including but not limited to proposal forms or other documentation you may be asked to complete, from your correspondence and phone calls with us (which may be recorded) and details of your visits to our website;
• from VDS Training, where you have enquired about, purchased or attended a training course;
• via VDS Support, where VDS has made arrangements to partner with and provide the means for you to be introduced to other organisations who have a close affinity and resonance with the protection and wellbeing needs of VDS Members, and you have enquired about or purchased products or other membership benefits from those organisations,
• from third parties, such as the nominated individual at your practice who applies for insurance coverage and completes the proposal form on behalf of the practice, including providing personal information relating to the veterinary surgeons and/or RVNs who are to be insured and details of any other staff who may be employed by the Practice;
• anyone who acts as your agent, in connection with the products and services we provide;
• third parties, involved in the relevant insurance policy or claim (such as our business partners, re-insurers, claimants, defendants or witnesses to an incident, experts, adjusters, lawyers, claims handlers, translators and others);
• third parties who provide a service, in relation to the relevant insurance policy or claim (such as claims handlers and experts);
• publicly available sources, such as internet search engines, news articles and social media sites;
• credit reference agencies;
• financial crime detection agencies and databases (such as for fraud prevention);
• in limited circumstances, private investigators;
• our own websites, social media pages and other software applications we make available for use via computers and mobile devices;
• other selected third parties in connection with any sale, transfer or disposal of our business;
• other sources such as public registers, anti-fraud databases, sanctions lists, court judgments, third party websites or our business partners or subcontractors.

Your personal information may be collected and processed for a number of reasons:

• In order to deal with your enquiries, to create and service insurance policies, and deliver the range of products and services which VDS, VDS Training or VDS Support may offer from time to time;
• To provide a quote, set up, administer and renew insurance policies (which may include fraud, sanctions, credit and anti-money laundering checks and client care communications);
• To deal with claims, make payments, defend legal claims or regulatory proceedings, investigate and prosecute fraud;
• To provide veterinary risk mitigation advice and training;
• To assist with risk modelling;
• To research your opinions and explore new ways to meet your needs;
• To assess and develop VDS, VDS Training and VDS Support’s products, systems, prices and brand;
• To administer our products and services and those provided by VDS Training and VDS Support;
• To fulfil any applicable legal or regulatory obligations;
• If you are a Member, to send you membership information such as the VDS Newsletter and Bulletin, and details of our Annual General Meeting;
• To send you other forms of marketing communications from any of VDS, VDS Training or VDS Support which we believe may be of interest to you (see "Lawful Basis for processing your information", below);
• To monitor the use of VDS, VDS Training or VDS Support’s websites and online applications;
• To maintain records of your use of the products and services provided via VDS, VDS Training or VDS Support;
• To transfer books of business, company sales, restructuring and reorganisation to any appropriate third party who may lawfully require access to your personal information.

What we do with the information we have

We may use your information for a number of different purposes. For each purpose we must have a lawful reason to process it.

When the information that we process is classed as sensitive data (or ‘special categories of data’) we must have a specific, additional legal reason to process such information.

Please see "Lawful basis for processing your information" below. 

Lawful basis for processing your information 

Data protection law requires us to rely on one or more lawful grounds to process your personal data. We consider the following grounds to be relevant.

Consent

We may need you to provide your specific consent to us using your personal data for our business purposes. For example, we will ask you if you consent to receive electronic marketing communications from any of VDS, VDS Training or VDS Support. We will provide the option for you to unsubscribe or opt-out of receiving electronic marketing communications at any time and you may also opt out by contacting us (please refer to "Your right to withdraw consent" below).

Performance of a contract

We need your personal data in order to perform a contract, or when taking steps to enter into a contract with you, or your organisation. Examples would be where:

• we use your personal data for contractual administrative purposes such as registering you as a Member, providing you with information about our products that you may have requested, or fulfilling an order for goods or services (whether placed online, over the phone or in person), such as delivering training to you.
• we process payments, billing and collection.

Legal obligation

We need your personal information where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example, where we are ordered by a court or regulatory authority.

Vital interests

Where it is necessary to protect life or health (for example in the case of a medical emergency suffered by an individual at an event run by us or by VDS Training) or a safeguarding issue which requires us to share your data with the emergency services.

Legitimate interests

This is when we have identified a genuine and legitimate reason for contacting you, which crucially does not override your own rights or interests. Broadly speaking Legitimate Interests allow us to process your personal information if we have a genuine and legitimate reason to do so. Before we rely upon our legitimate interest we will carefully consider and balance any potential impact on you and your rights.

Examples of where we will rely on legitimate interests include:

• Your best interests – processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure;
• Keeping you informed – by sending you marketing communications by post (or by email if you have provided your consent to receive electronic marketing) from any of VDS, VDS Training or VDS Support, about the products and services we or they provide;
• Conducting research to better understand and improve the relevance of our products and services:
• Understanding how people choose/use our services and products and those provided by VDS Training and VDS Support;
• Determining the effectiveness of our services, promotional campaigns and advertising; including those services, promotional campaigns and advertising issued by VDS Training and VDS Support;
• Monitoring who we deal with to protect against fraud, money laundering and other risks;
• Enhancing, modifying, personalising or otherwise improving our services /communications and those provided from VDS Training and VDS Support for the benefit of our Members and other customers;
• To better understand how you interact with our website and the websites for VDS Training and VDS Support.

When we legitimately process your personal information in this way, we will consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

When the information that we process is classed as ‘special categories of data’ we must have an additional ‘legal reason’. We will rely on the following legal grounds when we process your "special categories of data", where:

• We need to use your sensitive personal information for an insurance purpose. Such purposes include assessing your insurance application, managing claims and preventing and detecting fraud;
• We need to use your sensitive personal information to comply with or help someone else comply with a regulatory requirement relating to unlawful acts and dishonesty;
• We need to use your sensitive personal information to establish, exercise or defend legal rights. This might happen when we are faced with legal proceedings or want to bring legal proceedings ourselves or when we are investigating a legal claim that a third party brings against you;
• We need to use your sensitive personal information to prevent or detect crime. This might happen when we are investigating allegations of fraud;
• Such use is necessary to protect your vital interests. For example, in the case of a medical emergency suffered by an individual at an event run by us or by VDS Training;
• Where you have provided your explicit consent to our use of your sensitive personal information.

When we contact you

There are reasons for us to contact you whilst you are a VDS Member or you have enquired about or purchased a product or service from VDS Training or through VDS Support. This contact may be email, post, telephone or SMS. We encourage you to let us know your preferences by visiting thevds.co.uk/myvds/PersonalDetails – Communication Preferences or by contacting the Data Protection Officer (details above).

1. Statutory communications

So that we can comply with our legal obligations, we send VDS Members statutory communications including:

• Notice of the Annual General Meeting
• Proxy form
• Notice of any other general meetings

2. Service communications

We send VDS Members information to keep them informed about their policy, renewal or any important changes to their VDS membership, including claims or advisory matters or need-to-know veterinary legal and regulatory updates.

3. Marketing communications

You can choose your preferences about how you would like to receive information about products and services from any of VDS, VDS Training or VDS Support that might be of interest. This may include details of the range of training courses and resources provided by VDS Training, or details about those products and services introduced through VDS Support.

This information will be posted or emailed to you depending on how you set your preferences. If you would rather not receive marketing communications, you can let us know at any time by using the unsubscribe function in our emails, or by visiting the MyVDS area of the VDS website, or by contacting the Data Protection Officer (details above). 

The recipients or categories of recipients of the personal data

From time to time, we will share your personal information with VDS Training and VDS Support or with other third parties. We will keep your personal information confidential and only share it with the third parties listed below for the purposes set out in this Privacy Notice.

Where relevant, we will share your personal information with:

• VDS Training;
• VDS Support;
• Insurance and reinsurance partners;
• Other third parties who assist in the administration of your insurance policy or claim, such as claims handlers, accountants, actuaries, auditors, banks, lawyers, translators, and other experts, including veterinary experts;
• Our regulators, government or other public bodies, law enforcement and HMRC;
• Veterinary membership organisations;
• Fraud detection agencies and other third parties who operate and maintain fraud detection registers;
• Credit referencing agencies and third parties;
• Our third-party service providers, such as IT suppliers, actuaries, auditors, lawyers, document management providers, outsourced business process management providers and tax advisers;
• Third parties who handle our direct marketing on our behalf (this includes, for example, inclusion or suppression of your personal information from our contact lists, sending marketing communications, and analysis of responses to our marketing communications);
• Selected third parties in connection with any sale, transfer or disposal of our business;
• Where necessary, courts and other alternative dispute resolution providers (such as arbitrators, mediators and the Financial Ombudsman Service).

Transferring your information outside of Europe

As part of the services offered to you, the information which you provide to us may be transferred to countries outside the European Economic Area (‘EEA’). You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you are agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. Transfers outside of EEA will be protected by appropriate safeguards, namely the use of standard contractual data protection clauses adopted or approved by the European Commission. 

How we store your information

We apply appropriate technical and organisational measures to encrypt and protect email traffic. If your email service does not support encryption, any emails we send or receive may not be protected. We use strict procedures and security features to protect communications and personal data from unauthorised access. Data is held in the United Kingdom using secure servers, in printed form and in secure off-site storage facilities. We also have 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.

How long is your information kept for?

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal data for is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. regulatory and tax/accounting purposes).

We review our retention periods on a regular basis.

Your data protection rights

You have certain rights over the personal information that we hold about you. If you want to exercise any of these rights, please contact the Data Protection Officer (details above). We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Here is a summary of the rights that apply: Right of access

You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. If you want to access your information, please send a description of the information you would like to see and proof of your identity.

Right to have inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us. If your details change, or if you believe any of the other information we hold is inaccurate or out of date, please let us know.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, we will do so as far as we are required to.

Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we are not lawfully allowed to use it.

Right for your personal information to be portable

You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. 

Right to object

(See "Your right to object" below).

Right in relation to automated decision-making including profiling

You have the right to request us to reconsider a decision or take a new decision that is not based solely on automated processing. A limited amount of automated decision making may take place and where such decision making involves automated processing, including profiling, you also have the right to request human intervention to review the decision.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.

Your right to object 

You have the right to object to processing where we are using your personal information: 

• based on legitimate interests:
• for direct marketing; or
• for statistical/research purposes.

Please contact the Data Protection Officer (details above).

Your right to withdraw consent 

If you have given your consent to receive electronic marketing communications and you wish to withdraw that consent, you can let us know at any time by using the unsubscribe function in our emails, by visiting the MyVDS area of the VDS website, or by contacting the Data Protection Officer (details above).

Your choices 

We are obliged to send you certain information relating to your insurance contract or membership of the VDS (for example servicing communications in connection with your insurance contract or invitations to attend our Annual General Meeting). You have a choice about whether or not you wish to receive other forms of information from us and you can select your choices by visiting the ‘Communication Preferences’ section of our website. We’re committed to putting you in control of your data so you’re free to change your communication preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes.

How to complain

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, or if you think we have breached data protection legislation, you have the right to complain to the ICO, details below.

Information Commissioner’s Office Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate)

01625 545745 (national rate)

Email: casework@ico.org.uk

If you fail to provide personal data

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 the data when requested, we may not be able to perform the contract we have or are trying to enter with you to provide you with our services. In this case, we may have to cancel your policy.

Keeping your information up to date

We take reasonable steps to ensure your information is accurate and up to date. Please do let us know if your details change. 

Links to other websites

Our website may contain links to other websites run by VDS Training, VDS Support or other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

Cookies

We may receive information about you if you use any websites that we operate (including websites for VDS Training and VDS Support) or other services we provide. We work closely with third parties (including, for example, product providers you may be introduced to through VDS Support, other business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

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 website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

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 or make use of e-billing services.

Analytical/performance cookies             

They 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 any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Changes to this policy

Any changes we may make to this Privacy Notice in the future will be posted on this website so please check this page to ensure that you are aware of any changes. If we make any significant changes we'll make this clear on this website.

Review of this Policy

We keep this Privacy Notice under regular review. This Notice was last updated in March 2019.