Privacy policy

 

Clearly Hearing Ltd is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store and protect your personal data when you use our website or services. Please read it carefully.

We are the data controller for the personal data we collect. Our registered address is Inside OruSpace, 20-22 Lordship Lane, London, SE22 8HN.

 

1. What data we collect

We may collect the following categories of personal data:

  • Identity data: name, date of birth, gender.
  • Contact data: email address, telephone number, postal address.
  • Health data: audiological history, hearing test results, medical history, referral letters, and other clinical information. This is special category data under UK GDPR Article 9.
  • Financial data: payment card details (processed securely by Square — we do not store full card details).
  • Technical data: IP address, browser type, device information, pages visited, and time spent on our website (collected via Google Analytics).
  • Communications data: emails, enquiry forms, and any correspondence with us.
  • Marketing preferences: whether you have opted in to receive communications from us.

 

2. How we collect your data

We collect data in the following ways:

  • Directly from you: when you book an appointment, complete a health questionnaire, contact us by email or phone, or purchase a product or service.
  • Automatically: through cookies and analytics tools when you visit our website. See our Cookie Policy for details.
  • From third parties: from referring clinicians such as GPs, ENT consultants, or speech and language therapists, where you have consented to a referral.

 

3. How we use your data

We use your personal data for the following purposes:

  • To provide clinical services: processing bookings, conducting assessments, fitting and servicing hearing aids, and managing your ongoing care.
  • To process payments: via our payment processor Square.
  • To communicate with you: appointment reminders, clinical correspondence, and responses to your enquiries.
  • To send marketing communications: where you have given your consent, we may send updates about our services via Blueprint CRM. You can opt out at any time.
  • To comply with legal and regulatory obligations: including HCPC registration requirements and clinical record retention obligations.
  • To improve our services: using anonymised and aggregated data from website analytics.

 

4. Legal basis for processing

We process your personal data under the following legal bases:

  • Contract: to fulfil a booking or service agreement with you.
  • Legal obligation: to comply with HCPC standards, tax obligations and clinical record-keeping requirements.
  • Legitimate interests: to manage our business, improve our services, and prevent fraud.
  • Consent: for marketing communications and for processing special category health data where required. You may withdraw consent at any time.
  • Vital interests: in an emergency where processing is necessary to protect your health or safety.

 

5. Special category data — health information

Because we provide healthcare services, we process health data which is classified as special category data under UK GDPR Article 9. We process this data on the basis of Article 9(2)(h) — for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health care or treatment, and the management of health care systems.

Please see our Clinical Privacy Notice for full details of how we handle your health and audiological information.

 

6. Who we share your data with

We do not sell your personal data. We may share it with:

  • Clinical partners: ENT consultants, GPs, speech and language therapists, and schools where clinically necessary and with your knowledge.
  • Hearing aid manufacturers: to process hearing aid orders, warranties and repairs.
  • Payment processors: Square, for secure payment processing.
  • CRM and communications: Blueprint CRM, for appointment management and service communications.
  • Website analytics: Google Analytics, for anonymised website performance data.
  • Legal and regulatory bodies: the HCPC or other regulators where required by law.

All third parties are required to handle your data securely and in accordance with UK GDPR.

 

7. How long we keep your data

We retain personal and clinical data in accordance with professional and legal obligations:

  • Adult clinical records: minimum 8 years from the date of last treatment.
  • Children’s clinical records: until the patient’s 25th birthday, or 26th birthday if treatment ended before age 17.
  • Financial records: 7 years in accordance with HMRC requirements.
  • Marketing preferences: until you withdraw consent or request deletion.

After the relevant retention period, data is securely deleted or anonymised.

 

8. Your rights

Under UK GDPR, you have the following rights:

  • Right of access: to request a copy of the personal data we hold about you.
  • Right to rectification: to request correction of inaccurate data.
  • Right to erasure: to request deletion of your data, subject to legal retention obligations.
  • Right to restrict processing: to ask us to limit how we use your data.
  • Right to data portability: to receive your data in a structured, machine-readable format.
  • Right to object: to object to processing based on legitimate interests or for direct marketing.
  • Right to withdraw consent: at any time, without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at hello@clearlyhearing.co.uk or write to us at Inside OruSpace, 20-22 Lordship Lane, London, SE22 8HN.

 

9. Data security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or disclosure. Payment data is processed securely by Square and we do not store full card details.

In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and the Information Commissioner’s Office (ICO) as required by UK GDPR.

 

10. Cookies

We use cookies on our website. For full details of the cookies we use and how to manage them, please see our Cookie Policy.

 

11. Links to other websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and recommend you read their privacy policies.

 

12. Changes to this policy

We may update this Privacy Policy from time to time. The date of the most recent revision is shown at the top of this page. We will notify you of significant changes by email where we hold your contact details.

 

13. How to complain

If you are unhappy with how we have handled your personal data, you have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113. We would welcome the opportunity to resolve your concerns directly first — please contact us at hello@clearlyhearing.co.uk.