Privacy Policy

Freeman Health Ltd - Trading as Clear Ears Wales - Version 1.0 - Last Updated July 2026

This Privacy Policy explains how Freeman Health Ltd, trading as Clear Ears Wales (“we”, “us”, “our”), collects, uses, stores and protects your personal information when you visit clearearswales.com or use our services.
We are committed to handling your information lawfully, transparently and securely. Please read this policy carefully. If you have any questions, please contact us using the details in section 1.

1. Who we are and how to contact us:

Data Controler - Freeman Health Ltd Trading as Clear Ears Wales

Registered in - Wales and England

Trading Name - Clear Ears Wales

Website - clearearswales.com / clearearswales.co.uk

Email - info@Clearearswales.com

Phone Number - 07861014090

Freeman Health Ltd is registered with the Information Commissioner’s Office (ICO) as required under the UK GDPR. Our ICO registration number is shown above. To exercise any of your data rights or raise a concern, please contact us using the details above.

2. What Personal Data We Collect

We collect different categories of personal data depending on how you interact with us.

2.1 Data you provide directly

Full name, date of birth, address, telephone number and email address
GP name and surgery
Health and medical history relevant to ear care (see section 2.2 below
Appointment preferences, including your preferred contact method for reminders
Messages and enquiries sent to us by email, telephone, WhatsApp or the website contact form

2.2 Special category health data

Because we provide a healthcare service, we collect and process special category personal data in accordance with UK GDPR Article 9(2)(h) — processing necessary for the provision of health or social care. This includes:

Medical history relevant to ear care — including ear conditions, previous ear surgery, medications, allergies, and any other health information relevant to treatment
Clinical findings from ear examinations (otoscopy) carried out before and after treatment
Treatment details — the method used (microsuction or irrigation), clinical notes and outcome
Any follow-up recommendations or onward referrals

2.3 Booking and payment data

When you book an appointment through our online booking system, provided by Manage Patients (managepatients.com), we collect your booking details including preferred date, time and address. In some cases a deposit payment is taken at the time of booking to secure your appointment slot.
We do not store your full payment card details. Deposit payments are processed directly by Manage Patients in accordance with their own privacy policy and PCI DSS security standards. The remaining balance is collected on the day of your appointment by card or bank transfer.

2.4 Website data
When you visit clearearswales.com, standard technical data may be collected automatically by our website hosting platform, including your IP address, browser type, pages visited and referring website. This data is used solely for the purposes of website security and performance and is not used to identify you personally.
We use only essential cookies on this website — those strictly necessary for it to function. We do not use analytics, advertising or tracking cookies. No cookie consent banner is required.

3. Why we collect your data and our lawful basis

Purpose
- Providing ear wax removal treatment
Legal basis (UK GDPR Art. 6)
- Contract (Art. 6(1)(b))
Special category basis (Art. 9)
- Healthcare provision (Art. 9(2)(h))
Purpose
- Maintaining accurate clinical records
Legal basis (UK GDPR Art. 6)
- Legal obligation (Art. 6(1)(c))
Special category basis (Art. 9)
- Healthcare provision (Art. 9(2)(h))
Purpose
- Processing booking deposit payments via Manage Patients
Legal basis (UK GDPR Art. 6)
- Contract (Art. 6(1)(b))
Purpose
- Sending appointment reminders
Legal basis (UK GDPR Art. 6)
- Consent (Art. 6(1)(a))
Purpose
- Responding to website or phone enquiries
Legal basis (UK GDPR Art. 6)
- Legitimate interest (Art. 6(1)(f))
Purpose
- Professional indemnity insurance
Legal basis (UK GDPR Art. 6)
- Legitimate interest (Art. 6(1)(f))
Purpose
- Legal or regulatory compliance
Legal basis (UK GDPR Art. 6)
- Legal obligation (Art. 6(1)(c))

4. How long we keep your data
4.1 Clinical health records
Patient health records are retained in line with best practice guidance for independent healthcare providers:
• Adult patients: minimum 8 years from the date of last treatment
• Patients who were under 18 at the time of treatment: until age 25, or 8 years after last treatment, whichever is the longer period

4.2 Financial and booking records
Booking records and deposit payment confirmations are retained for 6 years from the date of the transaction, in line with HMRC requirements for financial records held by limited companies

4.3 Enquiries from non-patients
If you contact us but do not go on to book an appointment, any personal data you share will be retained for no longer than 12 months, after which it will be securely deleted.

4.4 Secure disposal
At the end of the applicable retention period, records are securely destroyed. Paper records are shredded; digital records are permanently deleted. We do not retain data beyond what is legally or clinically required.

5. How we store and protect your data

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration or disclosure.

Paper consent forms and clinical records are stored in a locked filing system, accessible only to the treating practitioner
Digital records are held on password-protected, up-to-date devices
Data held within Manage Patients is subject to that platform’s own security standards and our data processing agreement with them
We do not store personal data on unencrypted portable devices
Sensitive clinical information is not transmitted by unsecured email

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, Freeman Health Ltd will notify the ICO within 72 hours and inform affected individuals without undue delay, as required by UK GDPR.

6. Who we share your data with

We do not sell your personal data. We do not share it with third parties for marketing purposes. Data is shared only in the following limited and necessary circumstances:

6.1 Your GP or other healthcare professionals

With your knowledge, we may communicate with your GP or refer you to another healthcare professional where clinically appropriate — for example if we identify a condition that requires further assessment or treatment. We will always explain if this is the case.

6.2 Manage Patients (data processor)

Your booking details and deposit payment are processed by Manage Patients (managepatients.com), who acts as a data processor on behalf of Freeman Health Ltd under a formal data processing agreement. Manage Patients does not use your data for any purpose other than processing your booking. Their privacy policy is available at managepatients.com.

6.3 Our professional insurer

In the event of a claim or complaint, we may share relevant records with our professional indemnity insurer — Westminster Insurance / Westfield Specialty — to the extent necessary to handle the matter.

6.4 Legal or regulatory requirements

We may disclose personal data if required to do so by law, by court order, or by a regulatory or supervisory authority. We will only disclose what is strictly required and will not volunteer additional information.

6.5 International transfers

We do not transfer your personal data outside the United Kingdom or the European Economic Area. If this changes, this policy will be updated accordingly and appropriate safeguards will be put in place.

7. Cookies

clearearswales.com uses only essential cookies — those strictly necessary for the website to operate correctly. These may include session management cookies or security cookies set by our hosting platform.
We do not use:

Analytics cookies (such as Google Analytics)
Advertising or retargeting cookies (such as Facebook Pixel or Google Ads tags)
Preference or personalisation cookies

Because we use only essential cookies, we are not required to display a cookie consent banner under UK law. If our cookie use changes in future, this policy will be updated and an appropriate notice added to the website.

8. Your rights under UK GDPR

As a data subject, you have the following rights in relation to your personal data held by Freeman Health Ltd. To exercise any of these rights, please contact us using the details in section 1. We will respond within one calendar month.

Access

Request a copy of the personal data we hold about you (Subject Access Request). Free of charge. We respond within one month.

Rectification

Ask us to correct inaccurate or incomplete data we hold about you.

Erasure

Ask us to delete your data. Subject to our legal obligation to retain clinical records for the required period — we will explain if this limitation applies.

Restrict processing

Ask us to limit how we use your data in certain circumstances, for example while a complaint is being investigated.

Data portability

Where data is processed by automated means on the basis of consent or contract, request a copy in a structured, portable format.

Object

Object to processing based on legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds that override your interests.

Withdraw consent

Where processing is based on your consent (e.g. appointment reminders), withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.

Withdraw consent

Where processing is based on your consent (e.g. appointment reminders), withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.

Some rights are subject to legal limitations — for example, the right to erasure does not override our obligation to retain clinical health records. We will always explain clearly if a limitation applies to your request.

9. Automated decision-making and profiling

Freeman Health Ltd does not use automated decision-making or profiling in relation to your personal data. All clinical decisions — including the choice of treatment method — are made by a qualified human practitioner based on individual assessment.

10. How to raise a concern or complain

If you have any concern about how we have handled your personal data, please contact us in the first instance. We take all concerns seriously and will aim to resolve the matter promptly and fairly.
If you remain dissatisfied after contacting us, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

ICO website : ico.org.uk
ICO helpline : 0303 123 1113
ICO live chat : Available at ico.org.uk
ICO post : Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or in data protection law. The current version will always be published on clearearswales.com with the date it was last updated.
Where we make significant changes that affect how we process your data, we will notify active patients by email where we hold a valid address for them.