PRIVACY NOTICE FOR NUTRITIONAL THERAPY CLIENTS
To comply with the European General Data Protection Regulation (GDPR) 25th May 2018.
FRESH Nutrition holds some personal information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. 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 the data controller, Rachael Scott at firstname.lastname@example.org or in writing to Mrs R E Scott, FRESH Nutrition Cottage Barn, Hurston Place Farm Hurston Lane Pulborough West Sussex RH20 2EW.
1. What We Do
FRESH Nutrition provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. The focus is 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, nutritional supplements and lifestyle changes.
We also offer services such as seminars and workshops to a variety of organisations and businesses.
2. How We Obtain Your Personal Data
Information provided by you
You provide us with personal data in the following ways:
- Your initial contact with us by telephone and/or email
- By completing a nutrition assessment questionnaire and food diary
- By notes taken during the consultation
- Through e mail, over the telephone or by post
This may include the following information:
- Basic details such as your name, address, telephone number and e mail address
- 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 medical details, biochemical test results, clinical 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 the completion of your healthcare we retain your personal data for the period defined by our professional registrant body FHT (The Federation of Holistic Therapies) In this case the legal basis of our holding your personal data is for contract administration.
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 co-ordinate your healthcare with that provided by other providers which will mean healthcare by us may be less effective.
3. How we use your personal data
Rachael Scott acts as the data controller and uses 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 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 serious crime. Also where there is a legal requirement such as a formal court order.
4. Do we share your 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:
- 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. from professional associations or from FHT. If we have a duty to do so or if the law allows us to do so.
- Our registrant bodies if a complaint is made against us.
We may share your information with supplement companies and biochemical testing companies as part of providing you with direct health care. 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 the appropriate authority, using the legal basis of vital interests.
5. What are my 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 request in writing to the data controller Mrs R E Scott, FRESH Nutrition Cottage Barn, Hurston Place Farm Hurston Lane Pulborough West Sussex RH20 2EW.
We shall respond within 30 working days from 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.
6. 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 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 in secure locations, restrict access to information by anyone other than the data controller, Mrs R E Scott.
7. How long do you hold confidential information for?
All records are held by FRESH Nutrition will be kept for 8 years after your last contact.
8. Website Technical Details
Personal data is collected for the following purposes and using the following services:
- Google Analytics
New EU Privacy laws require websites to list which cookies are placed on browsers visiting their websites, what their purpose is and how long the cookies will remain on the users browser.
For more information about cookies and how to manage or disable them consult the help section of your browser or take a look at the website www.aboutcookies.org
If you have a complain regarding the use of your personal data then please contact us in writing to the Data Controller Mrs R E Scott, FRESH Nutrition Cottage Barn, Hurston Place Farm Hurston Lane Pulborough West Sussex RH20 2EW.
If you do have a complaint which you feel is not resolved to your satisfaction you can make a formal complaint to the information commissioner’s office (ICO) on 01625 545745 or 0303 1231113.