As part of your health care, Nutritional-Matters needs to gather and use certain information about clients, suppliers or organisations it has a relationship with or may need to contact.
- Nutritional-Matters is committed to a policy of protecting the rights and privacy of clients and others in accordance with General Data Protection Regulation.
Personal Data: Nutritional-Matters may hold data for the following purposes:
Data Protection Principles: There are six data protection principles that are core to the General Data Protection Regulation. Nutritional-Matters will 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-Matters is 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-Matters will 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-Matters will 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.
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 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.
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.
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-Matters will 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-Matters will 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-Matters will 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-Matters will 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-Matters will 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 processors such as testing laboratories: As a data controller, Nutritional-Matters will 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-Matters has a legal obligation to report any data breaches to UK Supervisory authority, which is the Information Commissioners Officer, within 72 hours.