Privacy Information Notice
At Mint Practice, we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and what choices you have. It relates to all our business activities, not just this website.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our services, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to email@example.com,
Date: 1st March 2018
Next Review Date: 1st March 2019
Author: Deborah Smith
Who are we?
We are Mint Practice, a company providing a clinical compliance manual, practice leaflets and CPD to healthcare practitioners in the UK.
Mint Practice is a company limited by guarantee (Registration Number: 9279997); our registered address is 7a Conway Drive, Flitwick, Bedfordshire, MK45 1DE, United Kingdom.
How do we collect information from you?
We obtain information about you when you contact us to enquire about our services.
We also collect information from you if you leave a comment on our blog or fill in our feedback or help forms.
If you purchase customised products we collect information to process your order. We also collect information when we process your order.
What information do we collect & how is it used?
We collect information to allow us to fulfil our obligations to our customers, and to respond to enquiries. We also collect your information if you leave a comment on our blog. The table in section 3.3 below outlines what information we collect, and for what purpose.
3.0. Sensitive Data
We do not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). We expressly request that you do not provide any such sensitive data to us.
3.1. Children’s information
Our services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.
3.2. Third Parties
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf (for example, we may provide your contact details to the printers and delivery service we work alongside). We disclose only the personal information that is necessary to deliver the service.
We also use a number of 3rd party services to help us fulfil our contractual obligations. These 3rd party services are listed below; we have verified that these 3rd party services are GDPR compliant (or are working towards GDPR compliance), and are certified under the EU-US Privacy Shield Framework (or are working towards certification) where these organisations are based outside of the EU.
The following table outlines the personal data we collect and for what purpose. The table also outlines the 3rd parties the data is processed by or shared with, and how long the data is stored for:
|Name||What||Legal Ground||Purpose||3rd Parties||Data Retention|
|Prospect, client & supplier contact information||Contract||To allow initial and ongoing contact with prospects, clients, suppliers, etc.||Office 365
|Until request for deletion, archived after 2 years|
|Blog Comments||Website commenter name, email address and website||Legitimate interests||To allow website users to comment on and discuss blog posts, or ask questions.||Held within WordPress database, hosted with WP Engine||Until request for deletion. To maintain flow of conversation comments may not be deleted on request, but all personally identifying information will be removed.|
|News letter||Email address||Consent||To allow customers to receive ongoing news and compliance information and product updates||WP Engine, Mailchimp||Until request for deletion|
|Feedback and help forms||Website commenter name, email address and website||Legitimate interest||To allow customers to ask for help and give feedback on products and for us to respond||WP Engine, Office 365||Until request for account deletion|
|Personalised products||Clinic details and logo||Contract||To allow Mint to produce customised leaflet for the customer and liaise about final design.||WP Engine, Office 365, Printer and delivery company||Until request for deletion|
|Customer invoicing and order processing||Contact details, payment processing||Contract, consent, legal requirement||To enable Mint to process customer’s order with delivery address and full legal obligations for processing payment. Customer opts-in to receive news, information on products and compliance. Information is processed through Kashflow accounts package.||WP Engine, Office 365, Printer/delivery company, Stripe, Mailchimp, Kashflow, Hermes|
|Analytics||Website visitor behaviour (anonymised – full IP address is NOT stored)||Legitimate interests||To analyse popular content, website performance, etc – so we can further improve.||Google Analytics
We have signed EU model contract clauses & anonymise IP addresses
|Indefinitely/for as long as Google Analytics retains. NB: not personal data|
|Server Logs||IP address||Legal obligation||To help prevent DoS (Denial of Service) attacks; for website security and diagnostics.||WP Engine||Server logs are stored unencrypted for 7 days, and then moved to an encrypted backup which is stored indefinitely and only accessible by WP Engine.|
Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation. If you wish to exercise these rights, please contact us, including your email address in the first instance (this is the unique identifier we use to identify and collate personal information).
4.0. Requesting a copy of your information
You may request a copy of any data we hold about you. Upon request, we will provide a CSV file (which you may open in a program such as Microsoft Excel) containing the personal data we hold on record about you.
4.1. Updating or correcting your information
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.
4.2. Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request.
Users have the ability to leave comments on our blog and feedback on our products. To maintain flow of conversation, blog comments will not normally be deleted (unless there is a compelling reason to do so), and feedback will be left to help other customers but all personally identifying information will be removed.
4.3. Automated decision making
We do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.
Use of ‘cookies’
Information we collect from visitors
If you choose to supply us with your personal information, we may use it in the following ways:
- To process your purchase/membership/request/enquiry made via this website
- For internal record keeping
- To send you regular email updates, if you opt in to this service
- To improve our products and services
You can manage these small files yourself. You can find out how to do this, and learn more about Cookies in general here.
Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible. Google Analytics sets the following cookies:
- __utma (Expiry: 2 years)
- __utmb (Expiry: 30 minutes)
- __utmc (Expiry: At end of session)
- __utmz (Expiry: 6 months)
When you leave a comment on our blog, three cookies are set to store your name, email address and website. This is so that if you wish to leave another comment, you won’t have to re-type this information:
We use a technology called ‘Adaptive Images’ to display appropriately sized images across all screensizes. This sets a cookie to store your screensize:
By using and browsing the Mint Practice website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
Links to other websites
Our website contains links to other third party sites. Mint Practice Ltd is not responsible for the privacy practices within any of these other sites. You should be aware of this when you leave the Mint Good Clinical Practice website and we encourage you to read the privacy statements on other websites you visit.
Mint Practice takes security seriously. In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
- Data minimisation
- Password best practice
- Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
- Staff training and accountability on data protection
A copy of our internal Data Security Policy is available on request.
Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, Mint Practice will promptly notify you of any unauthorized access to your personal information.
If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).