I take your privacy seriously.
I do not trade or sell your personal data.
This document outlines how your information is used, who I may share that information with and how I keep it secure. This notice does not provide exhaustive detail. However, I am happy to provide any additional information or explanation needed. Any requests for this should be sent to firstname.lastname@example.org
1. What I Do
I provide nutritional therapy and naturopathy services to clients to improve their health through diet and lifestyle interventions. I focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and functional testing (where needed), I aim to understand the underlying causes of your health issues which I will seek to address through personalised nutrition and lifestyle advice.
2. How I Obtain Your Personal Data
Information provided by you
You provide me with personal data in the following ways:
· By completing a health questionnaire before a nutritional therapy/naturopathy consultation.
· By signing a ‘Terms Of Engagement’ form before a nutritional therapy consultation.
· During a consultation.
· By e-mail, over the telephone or by post.
· By making credit card or online payments.
· By sending me any test results and medical reports as well as any correspondences with other practitioners.
This may include the following information:
· Basic details such as name, address, contact details, date of birth.
· Details of contact I have had with you such as free telephone consultations, nutritional therapy consultations, referrals and communications with you.
· Health information including your previous medical history, dietary, lifestyle, supplement and medicine details, functional test results, clinic notes and health improvement plans
· GP contact information.
If you have requested a free telephone consultation, I will retain your data so that I have a record that I have already offered you a free telephone consultation. Although the phone call is intended to decide whether you and I will work together I may give very simple advice and therefore I am obligated to retain your personal data for the period defined by my professional associations BANT and NNA (currently 8 years) and registrant body CNHC.
If you book a consultation with me you will then be providing me with further data. I use this information in order to provide you with direct healthcare. This means that the legal basis of my holding your personal data is for legitimate interest.
Following completion of your healthcare, I retain your personal data for the period defined by my professional associations BANT and NNA (currently 8 years) and registrant body CNHC. This enables me to process any complaint you may make. In this case the legal basis of my holding your personal data is for contract administration.
Information I get from other sources
I may obtain sensitive medical information in the form of test results from functional testing companies. I use this information in order to provide you with direct healthcare. This means that the legal basis of my holding your personal data is for legitimate interest.
I may obtain sensitive information from other healthcare providers. The provision of this information is subject to your giving me your express consent. If I do not receive this consent from you, I will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by me may be less effective.
3. How I Use Your Personal Data
I act as a data controller for use of your personal data to provide direct healthcare. I also act as a controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers. I act as a data controller and processor in regard to the processing of credit card and online payments.
I undertake due care at all times to protect your personal data, including any health and contact details, in a manner which is consistent with my duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. I will also take reasonable security measures to protect your personal data storage.
I may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime or where there is a legal requirement such as a formal court order.
4. Do I Share Your Data With Any Other Organisations?
I will keep information about you confidential. I will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
· My registrant body, CNHC, and my professional associations, BANT and NNA, for the processing of a complaint made by you
· Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential.
· Anyone to whom we may transfer our rights and duties under any agreement we have with you.
· Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. CNHC) if we have a duty to do so or if the law allows us to do so.
For example I may share your information with testing companies, as part of providing you with direct healthcare on the understanding that they will maintain confidentiality. This can be helpful, for example, as sometimes I may consult with a testing laboratory representative to interpret your test results in the context of your medical history, current symptoms, diet, lifestyle.
I will seek your express consent before sharing your information with your GP or healthcare providers other than the contractors and advisors as specified above. However if I believe that your life is in danger then I may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.
I may share your case history in an anonymised form with my peers for the purpose of professional development only with your explicit consent. This may be at clinical supervision meetings, conferences, online forums and through publishing in medical journals, trade magazines or online professional sites. This use of your personal information would be on the legal basis of consent.
5. Your Rights
Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data, you must make a subject access request in writing to me at email@example.com or City Way Health Clinic, Fort Pitt House, New Road, Rochester ME1 1DX. Under special circumstances, some information may be withheld. I shall respond within 20 working days from the point of receiving the request and all necessary information from you. My response will include the details of the personal data I hold on you including:
· Sources from which I acquired the information
· The purposes of processing the information
· Persons or entities with whom I am sharing the information
You have the right, subject to exemptions, to ask to:
· Have your information deleted
· Have your information corrected or updated where it is no longer accurate
· Ask me to stop processing information about you where I am not required to do so by law or in accordance with the BANT, NNA and CNHC guidelines.
· Receive a copy of your personal data, which you have provided to me, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.
· Object at any time to the processing of personal data concerning you
I do not carry out any automated processing and thus there are no automated decisions made based on your personal data that I hold.
6. What Safeguards Are In Place To Ensure Data That identifies Me Is Secure?
I only use information that may identify you in accordance with GDPR. This requires me to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Since my work is within the health sector, I also follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it is treated as confidential and only shared for the purpose of providing direct healthcare. I will protect your information, inform you of how your information will be used and allow you to decide if and how your information can be shared.
I also ensure the information I hold is kept in secure locations such that access is limited to authorised personnel only and protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). I am the sole authorised person with access to your personal data that I am holding. Third parties with whom I have shared your data as specified above, such as biochemical testing companies, will have their own GDPR compliant privacy policies in place, such that your data that they hold will only be used for the purposes of providing you with the services you have requested. I ensure external data processors that support me are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
I am registered with the Information Commissioner’s Office (ICO) as a data controller. A copy of the registration is available through the ICO website.
7. How Long Do I Hold Your Data For?
I keep all records for the duration specified by guidance from my professional associations BANT and NNA.
If you have a complaint regarding the use of your personal data then please contact me at firstname.lastname@example.org or City Way Health Clinic, Fort Pitt House, New Road, Rochester ME1 1DX and I will do my best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them at https://ico.org.uk/concerns/ or call 0303 1231113.