Privacy Policy and Data Protection Policy

Nutritional-Mattersholds some information about you. This document outlines how that information is secured. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to info@nutritional-matters.co.uk.   Privacy notice last reviewed May 2018.

 

What we do:Nutritional-Mattersprovides nutritional therapy services to clients to improve their health through diet and lifestyle interventions.  We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions.  Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of your health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.

 

What information we have about you:

You provide us with personal data in the following ways:

  • By completing a nutritional therapy questionnaire
  • By signing a terms of engagement form
  • During a nutritional therapy consultation
  • Through email, over the telephone or by post
  • By taking credit card and online payment (this facility is not yet set up!)

This may include the following information:

  • basic details such as name, address, contact details.
  • details of contact we have had with you such as referrals and appointment requests
  • health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans
  • GP contact information

We use this information in order to provide you with direct healthcare.  This means that the legal basis of our holding your personal data is for legitimate interest.  Following completion of your healthcare, we retain your personal data for the period defined by BANT, our professional association and registrant body, CNHC. This enables us to process any complaint you may make.  In this case the legal basis of our holding your personal data is for the admin of our contract.

 

Information we get from other sources: We may obtain sensitive medical information in the form of test results from biochemical testing companies.  We use this information in order to provide you with direct healthcare.  This means that the legal basis of our holding your personal data is for legitimate interest.   We may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

 

How we use your personal data:  We act as a data controller for use of your personal data to provide direct healthcare. We 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.  We act as a data controller and processor in regard to the processing of credit card and online payments.

 

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  We will also take reasonable security measures to protect your personal data storage.

 

We 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.  Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.

 

Do you share my information with other organisations?

We will keep information about you confidential.  We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

  • Our registrant body, CNHC and our professional association, BANT, 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 if we have a duty to do so or if the law allows us to do so

We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. We will not include any sensitive information

 

We will seek your express consent before sharing your information with your GP or other healthcare providers.  However if we believe that your life is in danger then we 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.

 

We may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites.  We will seek your explicit consent before processing your data in this way.

 

What are 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 lucy@nutritional-matters.co.uk. Under special circumstances, some information may be withheld.   We shall respond within 20 working days from the point of receiving the request and all necessary information from you.  Our response will include the details of the personal data we hold on you including:

  • The purposes of processing the information
  • Persons or entities with whom we are 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 us to stop processing information about you where we are not required to do so by law in accordance with the BANT and CNHC guidelines.
  • Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
  • Object at any time to the processing of personal data concerning you
  • We do not carry out any automated processing, which may lead to automated decision based on your personal data.
  • If you would like to invoke any of the above rights then please write to the email me at lucy@nutritional-matters.co.uk

What safeguards are in place to ensure data that identifies me is secure?

We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We 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.

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, 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). We ensure external data processors that support us 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.

 

How long do you hold confidential information for?

All records held by Nutritional-Matterswill be kept for the duration specified by guidance from our professional association BANT.

 

Website technical details

  • Forms these are used on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
  • We may also use cookies to collect none private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites http://tools.google.com/dlpage/gaoptout

 

Analytics:    Like most websites, we may make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policyon the Google website.

 

Complaints:  If you have a complaint regarding the use of your personal data then please contact us by writing to Nutritional-Mattersor by email lucy@nutritional-matters.co.uk and we will do our best to help you.

 

part of your health care,Nutritional-Mattersneeds to gather and use certain information about clients, suppliers or organisations it has a relationship with or may need to contact.

  • Nutritional-Mattersis committed to a policy of protecting the rights and privacy of clients and others in accordance with General Data Protection Regulation.

Personal Data:   Nutritional-Mattersmay hold data for the following purposes:

  • Provision of direct healthcare
  • Marketing and newsletters
  • Case histories (anonymous)

Data Protection Principles:   There are six data protection principles that are core to the General Data Protection Regulation. Nutritional-Matterswill make every possible effort to comply with these principles at all times in our information-handling practices.  The principles are:

  • Lawful, fair and transparent: Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
  • Limited for its purpose: Data can only be collected for a specific purpose.
  • Data minimisation: Any data collected must be necessary and not excessive for its purpose.
  • Accurate: The data we hold must be accurate.
  • Retention: We cannot store data longer than necessary.
  • Integrity and confidentiality: The data we hold must be kept safe and secure.

 

Responsibilities:   Nutritional-Mattersis the data controller for all personal data held by us and is responsible for:

  • Analysing and documenting the type of personal data we hold
  • Checking procedures to ensure they cover all the rights of the individual
  • Identifying the lawful basis for processing data
  • Ensuring consent procedures are lawful
  • Implementing and reviewing procedures to detect, report and investigate personal data breaches
  • Storing data in safe and secure ways
  • Assessing the risk that could be posed to individual rights and freedoms should data be compromised

Data accuracy and relevance:   Nutritional-Matterswill ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

 

Data Security:   Nutritional-Matterswill keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

Storing Data Securely:

  • In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
  • Printed data will be shredded when it is no longer needed
  • Data stored on a computer will be protected by strong passwords that are changed regularly.
  • Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
  • Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
  • All servers containing sensitive data must be protected by security software
  • All possible technical measures will be put in place to keep data secure

Nutritional-Matterswill retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of our professional association, BANT.

 

Accountability & Transparency:   Nutritional-Matterswill ensure accountability and transparency in all our use of personal data.   We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

 

Consent:  Nutritional-Matterswill ensure that consents are specific, informed and plain English.  We will seek explicit consent wherever possible.  We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent.  For online consent, we may use a cryptographic hash function to support data integrity. Alternatively we will maintain the consents information in a spreadsheet with links to the consent forms.

 

Direct Marketing:   Nutritional-Matterswill comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages.  We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

 

Subject Access Requests:

An individual has the right to receive confirmation that their data is being processed, access to their personal data and access the privacy notice.  Nutritional-Matterswill provide an individual with a copy of the information requested, on a PDF, free of charge. This will occur within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats.

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.

Once a subject access request has been made, we will not change or amend any of the data that has been requested. Doing so is a criminal offence.

 

Using third party controllers and processorssuch as testing laboratories:  As a data controller, Nutritional-Matterswill only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.  We will only act on your documented instructions.

Data breaches:   Nutritional-Mattershas a legal obligation to report any data breaches to UK Supervisory authority, which is the Information Commissioners Officer, within 72 hours.