The policy explains how Boots uses your personal information, whether you’re shopping on boots.ie, using the Boots app or Advantage Card, using our healthcare services or having a prescription made up at your local Boots pharmacy.
We’ve made one or two other tweaks while we’re at it, just to bring our policy up to date.
Our promise to you
Who's in control of your information?
How we collect personal information about you
Information we get from you
Boots collects personal information about you whenever you shop with us or use our services. Some of this information you give us directly when, for example, you place an order on boots.ie, sign up for a Boots Advantage Card, use our app or post comments on our Facebook page. If you have a prescription dispensed in one of our pharmacies, other information is collected indirectly. Please see below for examples of the data we collect from you.
What you do with us
Personal information we collect
Browsing history and purchases
Sign up and use your Boots Advantage Card
Name, address, contact details and purchases
Use a service or product from Boots pharmacies
Your contact details and prescription information
Mobile app privacy
Information we get from the Boots app
The Boots app needs to access certain information held in your phone and some of the device’s functions in order to work properly. By downloading the Boots app, you’re giving Boots permission to do this for the purposes set out below. Rest assured that we only use the permission you give to provide the app and the services you request and use through it.
Device ID and identity of the user
The Boots app captures information about the device it’s been installed on, such as the model of your phone, the version of the operating system it’s using and the version of the app that’s been installed. This allows Boots to accurately notify you when updates to the app are available for your version. The app also captures a device ID reference which allows us to send notification messages to your specific device if you’ve agreed that we may do so.
If you give permission for the Boots app to access location services (such as GPS or location from the network), the app will use this data to enable the ‘Store Locator’ feature to help identify stores near your present location. The app can access two different location options: ‘approximate’, where location is determined by accessing the network from your device and ‘precise’, where GPS data is used in addition to network data for more accurate positioning.
Storage, photos, media files, camera and flashlight
The Boots app needs access to these areas of your device to enable you to use the photo feature and select the images you wish to send to Boots stores to be printed. The Boots app can also access your device’s camera to allow you to take photos if you choose to capture a new image for printing. The camera is also used to enable you to scan a barcode, and the app may also activate the flashlight on your device to give the camera sufficient light to take photos or scan barcodes.
Phone and call information
The Boots app can access the phone dialler on your device to enable you to make calls directly from within the Boots app, for instance to dial the Boots customer support team.
The Boots app can access contacts stored on your device to enable you to share the Boots app via social media channels with contacts held on your device.
Wi-Fi, network connections and internet data
The Boots app needs a connection to the internet in order to function, so it’ll access data services on your device. It’ll connect to available Wi-Fi networks, if Wi-Fi is active on the device, in order to download data. If the app cannot use an available Wi-Fi network, data will be retrieved from the network using the device’s 3G or 4G connection.
Prevent device from sleeping
The Boots app can, if required, prevent your device from sleeping to ensure the app can receive notifications even when the device is not awake.
The Boots app can access the device’s ability to vibrate so a vibration alert can be provided when a notification is received.
Monitoring the functioning of the Boots app
Information we get from other companies in the Walgreens Boots Alliance Group
If you’re a customer of our other brands, such as Liz Earle, Soap & Glory or Sleek, the information you provide to them and to Boots is consolidated to help us understand our business and our customers. In turn, this helps us provide you with more relevant products, services and offers. This is done in a way that doesn’t identify you as an individual.
We also use your information across our brands to keep the records we hold about you accurate and up to date. For example, if you’ve updated your address in Boots and you’re also a customer of Liz Earle, we’ll update your information there, too.
Information we get from external companies
From time to time we may supplement the information we hold about you with data from other commercially-available sources, like the electoral roll and companies such as Experian, that collate and update data. This helps us keep our records up to date, and learn more about our customers so we can continue to improve our products and services to you. We only work with organisations that obtain their data legally from publicly available or consent-based sources.
Occasionally, for marketing purposes, we may obtain lists of potential customers from external companies. We’ll only deal with reputable companies that take privacy and data protection as seriously as we do and have obtained consent to share this data with us. We’ll always let you choose not to receive further marketing material from us.
Information we get when we acquire a new pharmacy
If you’re a customer of a pharmacy business that’s been taken over by Boots, we’ll receive your personal information from them as part of the handover process. Where this happens, we place a notice in-store or we may contact you in writing to tell you that your personal information is changing hands. If you don’t wish for your data to be transferred to Boots, please speak to the store manager.
Information we get from your GP or healthcare professional
Boots provides a range of clinical and healthcare services which are private services or are provided on behalf of the Health Services Executive (HSE). Where these require information to be obtained from or transmitted to your GP, we’ll tell you that this is necessary before providing you with the service. We’ll only share information to meet our regulatory obligations.
Information we get from social media
We may obtain information posted publicly on social media sites and use it to help us understand how our different customers interact with us. We do this in a way that doesn’t always identify individual customers. For example, we may look at which groups of customers that are more likely to talk to us via social media or use social media to talk about Boots products. If you raise a query or a complaint through Boots’ social media pages, we’ll of course have a record of your user name. This is used only to enable us to correspond with you and resolve the matter you’ve raised.
Information provided by other people on your behalf
Booking appointments for other people
If someone books an appointment on your behalf we’ll ask them for basic details about you, which may include health details such as whether you have a family history of diabetes or glaucoma. This is to ensure we book you in for the right type and length of appointment with the correct healthcare professional. Of course, we’ll check with you when you come to your appointment to make sure the information we’ve been given is accurate.
If you’re booking an appointment for someone else, please make sure they’re happy for you to provide their personal information on their behalf and that they understand why we need to ask for it. We don’t use it for any other purpose.
Dispensing services: care homes
If you or a relative are a resident of a care home to which Boots provides dispensing services, Boots will receive personal information from the care home to enable us to dispense prescriptions safely and comply with our legal and regulatory obligations.
How and why we use your personal information
We use your personal information for a number of different purposes. Some are essential for us to provide the services you use or to fulfil our legal obligations, some help us run our business efficiently and effectively, and some enable us to provide you with more relevant and personalised offers and information. In all cases, we must have a reason and a legal ground for processing your personal information. Some of the most common legal grounds we rely on are briefly explained below.
When you freely and voluntarily give your personal information to Boots, you give us your permission to process your personal information. All of the details such as:
• How and why Boots processes your personal information (including information concerning your health, such as your prescriptions or illnesses)
Where Boots are processing your personal information for the above reasons, you’ll see a consent tick box.
Important: you have the right to withdraw your consent at any time if you no longer want to be part of the Boots processing activity. However, please note that any processing carried out before you withdraw your consent will remain valid. We may be unable to provide a certain number of our services to you if you withdraw your consent.
When you choose to use certain Boots services, such as administering your prescriptions or booking an appointment with a healthcare professional, by providing your personal information voluntarily you consent to us using your personal information to provide that service to you.
Boots may use consent where we’re asking you to confirm your marketing preferences to ensure we only contact you via the medium you have chosen i.e. text or email.
You may also be asked to give your consent when you’re entering any sort of competition.
Processing personal information for the purposes of providing a service or product to you.
Important: if you don’t provide your personal information to Boots so that we can provide services or products to you, Boots will not be able to offer you the service or product.
When you use our prescription services in-store.
When you use your Boots Advantage Card to pay for products.
To set up and run your Boots account.
See, "Things we need to do to provide you with the services you’ve requested" under section 3.1 below.
Boots will on occasion be under a legal obligation pursuant to European Union Member State or European Union law to obtain and disclose your personal information.
Where possible, Boots will notify you when processing your data due to such a legal obligation. However, this may not always be possible (see examples).
Boots provides a range of clinical and healthcare services. As part of this, Boots are required to share certain amounts of personal information with the HSE in order to meet legal obligations.
Boots may also hold personal information for our own legitimate business interest. This relates to us managing our business to enable us to give you the best service/products and most secure experience. When we rely on this, we’ll carry out a legitimate interest assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under European Union Member State and European Union data protection laws.
It can also apply to processing that’s in your interests as well.
Our legitimate business interests don’t automatically override your interests – we’ll not use your personal information for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by member state or European Union law.
IMPORTANT: if you have any concerns about the processing, you have the right to object to processing that’s based on our legitimate interests. For more information on your rights, please see "Your Rights" under section 5 below.
We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that’s tailored to your interests.
As a healthcare provider, we’re regulated by the Pharmaceutical Society of Ireland (PSI), all of which may set out standards and codes of practice with which we need to comply. Where we provide pharmacy services in our pharmacies on behalf of the HSE, we also have to comply with HSE information governance requirements.
We may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
The use of CCTV in our stores to prevent and detect crime.
See "Things we do to provide you with a better service" under section 3.2 below.
Things we need to do to provide you with the services you've requested
Providing our products and services
We use your personal information to provide our products and services, for example to set up and run your account, process orders and transactions, respond to queries and comments and provide you with the best possible level of customer service. We may also use it to contact you about orders you’ve placed, appointments you’ve booked or to send you reminders (e.g. about repeat prescriptions). We may also contact you in emergency situations such as an urgent product recall or where we have a duty of care to notify you of information that relates to your health.
Can I object to having my data used for this?
No, this covers the many procedures and legal obligations that we need to carry out in order to provide you with the Boots service(s) you’ve requested and also to protect you in emergency situations.
Keeping our records up to date
We have a legal obligation to keep the personal information we hold accurate and up to date so we share your personal information across our group companies in order to do this. This also makes life simpler for you.
We also periodically update our records against commercially or publicly available sources (using companies such as Experian) to update addresses where customers have moved or who are deceased, to fill gaps in the contact details we hold and to correct addresses that are incorrectly formatted.
This excludes the information we hold about you on our prescription dispensing system. The information held there originates from your prescriber (usually your GP or a hospital) and is used only in connection with dispensing prescriptions. Any updates you make to information held elsewhere in Boots, such as your boots.ie account or Advantage Card, aren’t applied to information held on this system.
Can I object to this?
Yes, however there may be legal and regulatory requirements that require Boots to keep your information up to date if you’re using a Boots service.
Crime prevention and detection
Like all retailers, Boots undertakes certain activities that enable us to provide our customers and colleagues with a safe, secure and legal environment online and in stores.
When you place an order on our website we carry out identity verification, fraud prevention and anti-money laundering checks, validating the personal information you give against appropriate third party databases.
In our stores, we use CCTV to prevent and detect crime. Where we do this we display clear signage, and have internal processes in place to minimise the impact on your privacy.
Can I object to this?
Yes, however there may be legal and regulatory reasons that these activities need to be carried out as mentioned above. Therefore, we may not be able to prevent processing your data for this reason as it’s essential to protect our customers, our colleagues and our business.
Things we do to provide you with a better service
The following are things we do as a business to help us operate effectively and efficiently, and in turn provide you with better and simpler services. It’s in our legitimate interests to do these things and we do them in a way that respects and minimises any impact on your privacy.
Learning more about our customers and our business
We carry out basic analytics on the information we hold about our customers to help us understand who our customers are, how they use our services, and how people interact with us. This enables us to plan our business - for example stock and staffing levels make sure we offer the same experience online as in our stores, maximise the effectiveness of our advertising and understand how our business is performing. We don’t do this in a way that enables individual customers to be identified. It’s not related to the direct marketing or special offers that we send to you based on your use of Boots services.
Can I object to this?
Yes, you have the right to object to the way we use your data if you believe our legitimate interest in doing it is outweighed by your right to privacy. This type of basic analysis is important in enabling Boots (like all major retailers) to operate efficiently. As we carry it out in a way that doesn’t identify individuals, we believe it has no impact on your privacy. If you do wish to object, you’ll not receive all of the offers and benefits available on boots.ie or Advantage Card accounts.
Recognising you when you use our services
Whichever Boots services you use, and wherever and however you interact with us, we want to give you the same level of service to make things simple and straightforward. We use your details across our services so we can recognise you as a customer and provide consistent care - whichever service you’re using. This also means you don’t need to give the same details each time you come in.
Can I object to this?
Yes, we do this because it makes things more efficient both for you and for Boots. You can object, but doing so will limit the Boots services you’re able to use in the future. If you don’t wish for us to recognise you across our services, the following services will be affected and may not work to their full potential:
• .com/.ie account
• Boots Advantage Card
• Booking an appointment using our appointment booking service online, by phone or in store
The following services will remain unaffected if you object:
• Having your prescriptions dispensed at Boots pharmacies as normal
• Boots pharmacy services
• Placing an order on boots.com/ie as a guest customer. You’ll not be able to sign up for an account
How do I object to this?
If you’re a new customer on boots.ie, you should use the guest checkout rather than setting up a boots.com/ie account.
If you’re an existing customer, you’ll need to email in with your request. Note that if you close your account, we may continue to hold your personal information for a period of time after you cease to be a customer.
Personalising your online experience
Can I object to this?
Yes, but we believe it’ll result in your online experience being less personal and relevant to you. The content and search results you see will be generic rather than related to your interests. Personalising your online experience doesn’t affect your marketing options you’ve selected, it’s to offer you a service personalised to you needs.
How do I object?
Please view the Cookies section or contact us at the contact details below.
Running our Advantage Card scheme
The Boots Advantage Card offers great benefits and rewards, and we aim to make these as relevant to you as we can. In order to do so. we need your personal information. If you’re a member of our Advantage Card scheme, we’ll build up a picture of you based on your use of Boots services. This includes your online and offline shopping habits, your browsing habits, information you give us about yourself and through any clubs you’re a member of (such as Parenting Club, Over 60s etc.), and any information you provide about your family. We also include any information we’ve obtained from consent-based, commercially available sources (such as Experian) about you and people with similar interests and attributes. By building up and fine-tuning this picture of you, we can provide you with tailored offers that are exciting and relevant to you. Please note that we only send you marketing material if you’ve agreed that we can.
Please be assured that information we hold about prescriptions that we’ve dispensed aren’t included in the picture we build up of you.
Can I object to this?
The benefit of being an Advantage Card member is to receive points and rewards on the products and services that interest you. Without building up a detailed picture of you, we can’t tailor our offers and rewards to be personal to you and so you won’t receive the benefits of being an Advantage Card member. If you don’t wish to have your data used in this way, you’ll not be able to have an Advantage Card. If you’re an existing member, you therefore need to close your Advantage Card account. You’ll still be able to shop at Boots and use our services, but you won’t earn points or receive rewards.
Building up a picture of you
We may analyse your personal information, including the products you view and buy, your browsing habits and other ways you interact with Boots. This is to evaluate the effectiveness of our advertising and help us provide more relevant offers, advice and information. This will include information about the way you interact with our other group companies and information about your Boots memberships club. We may also use information from external (consent-based) companies such as Experian. Rest assured that we’ll only send you marketing material if you’ve agreed that we can. We’ll never use sensitive information about your health. If you’re an Advantage Card customer, we’ll carry out this type of analysis in order to provide the benefits of the scheme.
Can I opt out of this?
Yes, but if you’ve asked to receive marketing you’ll receive only generic offers based on your gender, age and location, rather than specific marketing based on preferences and how you use Boots services.
Healthcare/clinical research and market research
We work with leading universities, healthcare and pharmaceutical companies and other bodies carrying out healthcare research. This may involve providing anonymised and/or aggregated data about our dispensing activities. We have a strict process for assessing research requests and we only agree to take part in projects that have received ethical approval. Where any third party has access to Boots premises or data, we have measures in place to ensure they access only the data we’ve authorised them to access and for purposes of the research only.
Being able to conduct, participate and contribute to this type of research enables Boots to assist with helping to find cures and better solutions for healthcare, which will hopefully go on to benefit the healthcare of the public and our customers healthcare.
Can I object to this?
We believe this is an important activity that’ll benefit the public and may lead to a breakthrough in the healthcare sector. As any data we use or provide is anonymised in line with DPC guidance, it’s no longer personal information and you can’t exercise a right to object.
As a pharmacy-based retailer, research is vital to our business. Occasionally, we contact customers who meet a particular set of criteria, including health-related factors, to invite them to take part in clinical research. The research may be carried out by external companies acting on our behalf but we’ll never pass your personal information to them unless we have your consent to do so. You’re always free to decline or withdraw your consent at any time by contacting us.
On occasion, we may work with researchers who are looking for volunteers to take part in various research studies. Therefore our pharmacists in store may ask if you’re willing to take part in this type of research. If you’re interested in hearing more, we may then put you in touch with the researchers who will provide you with all of information and ask for your consent before any research begins. In such cases, Boots doesn’t receive any details about people who decide to take part in the research. Your data will be processed by the researcher.
Customer feedback surveys and market research
We may invite you to give feedback on Boots services you’ve used or take part in market research activities such as customer surveys, questionnaires or focus groups. Although the invitation may be sent to you by third party agencies on our behalf, rest assured that we only send your contact details and, where relevant, data that we’ve collected through use of your Advantage Card. Please be aware that you won’t be contacted more than every six months for research purposes, unless you’ve signed up separately to our Viewpoint panel, and we never sell your personal information.
Boots will only ever share your data with reputable marketing agencies such as Verve and Kantar TNS, in a safe and secure manner. All personal information is deleted as soon as it’s been used. Keeping your data safe is our top priority.
Can I opt out?
Yes, you’ll always be able to decline to take part in research activities and you can opt out of these types of emails from Boots, as well as other marketing emails. You can do this by managing your preferences online or following the unsubscribe link at the bottom of any of our emails.
Using your data with your consent
Appointment booking – searching our systems
When you register for a service or book an appointment, we’ll search our records and retrieve the contact details we hold for you, which may have originated in any of our systems which may hold your records.
Sending you marketing material
We use your information to send you offers and information. You’ll always be asked if you want to receive offers and information and via what channels you’d like to receive them.
Can I object to this?
Yes, you can change your mind about receiving marketing material from us at any time by contacting our Customer Service Centre or logging into your account on boots.ie.
Please be aware that as our marketing campaigns are prepared well in advance, you may still receive material by post for up to two months, and by e-mail or text for up to 28 days after updating your preferences.
You can also opt in or out of receiving our e-newsletters on a variety of health-related topics, as well as ‘weekly offers’ emails by visiting our online preference centre. Alternatively, you can click on the link at the bottom of any email we’ve sent you to opt out of that particular type of email.
Important: using information about your prescriptions
When you use our services, some of the information we collect may be about your health and include data from HSE bodies such as your GP or hospital. We understand the sensitivity of this information and will only use it to provide you with these services and fulfil our legal obligations to the HSE or similar bodies. As a healthcare provider, we’re regulated by the Pharmaceutical Society of Ireland (PSI) who may set out requirements which we need to comply with when processing personal information. This includes timescales for keeping data, reporting requirements and professional codes of practice. Where we provide HSE services, we’re required to comply with HSE Information Governance requirements.
Where we’re contracted to provide a service to or on behalf of the HSE, we’ll use your personal information to help us meet our contractual requirements to the HSE.
The information we hold on your personal medical record is used only to enable us to dispense your prescription legally, safely and to fulfil our requirements to you and the HSE.
Can I object this?
No. If you request Boots Pharmacy to carry out this service we need to use this information to dispense your prescription safely and legally.
We’ll never use information about your prescriptions for marketing, although we may use it to let you know about services we provide that might be useful and relevant to you when you come into our pharmacy. For example, when you collect a prescription a Boots pharmacist might ask if you’d like to take advantage of a pharmacy service such as vaccination, ambulatory blood pressure monitoring or other similar services that may be relevant and useful to you. These services are voluntary, but if you choose to use them we’ll need to ask you some health-related questions in order to fulfil our legal and contractual obligations to the HSE (where the service is provided in partnership with the HSE). The information you give us will only be shared with the HSE, where this is required, and we won’t use it for any other purpose.
Sharing your information outside the Walgreens Boots Alliance Group
We may share your personal information with third parties where required or permitted by law, if we believe we need to do so to protect our rights, or to comply with legal proceedings. In such cases, we’ll always do so legally and with due regard to your privacy.
Sharing with the HSE
We share information the HSE to fulfill our legal obligations as a provider of pharmacy services, or where we have a duty of care to do so. For example, to obtain payment for the services we provide and to measure the effectiveness of services.
In some circumstances, we might need to let your GP know we’ve prescribed an item or given you a particular service.
If you’ve asked us to register you for a HSE scheme or service such as the Drug Payments Scheme, we’ll pass your personal information to the HSE using a secure method of data transfer. This is so the HSE can register you for the relevant scheme or service.
If you choose to have one of the HSE funded services provided in our pharmacies, such as a Winter Flu Vaccination Service, we’ll ask you for health-related information which is needed to fulfil our contractual obligations to the HSE. We share this information only with the HSE and your GP, and won’t use it in any other way, although we may use your contact details to send you reminders about any follow-up appointments.
From time to time we may contact you with special offers on behalf of brands we stock, but we’ll never sell your data to those brands for them to use in their own marketing.
If you give your contact details and any other personal information at one of the premium beauty counters in our stores, you may be giving the information to that company rather than to Boots. Each company has its own data protection notice/statement, which may not be the same as ours, so we advise that you check who’s collecting your personal information and how they’ll use it before signing up to receive offers or information. Similarly, if you click through to another company’s website via a link on boots.ie, check that you’re happy with that company’s data protection notice/statement before giving your personal information.
Changes to our business
If ownership of all or part of our business changes, or we undergo a reorganisation (including an acquisition or transfer between Walgreens Boots Alliance companies), we’ll transfer your personal information to the new owner or successor company so we can continue to provide our services.
Companies that provide services on our behalf
We share your personal information with companies that provide services on our behalf, such as printers, couriers, mailing houses, data hosting services, call centre providers, manufacturers and suppliers. We always ensure these companies give your information the same level of care and security as we do. If your inf