Policies

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PART 1

The Nutritional Therapy Descriptor

Nutritional therapy is the application of nutrition and lifestyle medicine services in the promotion of health, peak performance and individual care. Registered Nutritional Therapy Practitioners assess and identify potential nutritional imbalances and understand how these may contribute to an individual’s symptoms and health concerns. This approach allows them to work with indiviuals to address nutritional imbalance and help support the body towards maintaining health.

Nutritional Therapy is recognised as a complementary medicine and is relevant for individuals with chronic conditions, as well as those looking for support to enhance their health and wellbeing. Practitioners never recommend nutritional therapy as a replacement for medical advice and always refer any client with ‘red flag’ signs or symptoms to their medical professional. They frequently work alongside medical professionals and will communicate with other healthcare professionals involved in the client’s care to explain any nutritional therapy programme that has been provided.

The Registered Nutritional Therapy Practitioner (RNTP) requests that the client notes the following:

• The degree of benefit obtainable from NT may vary between clients with similar health problems and following a similar nutritional therapy programme
• Nutrition and Lifestyle recommendations will be tailored to support health conditions and/or health concerns identified and agreed between both parties.
• As a RNTP, I am not permitted to diagnose, or claim to treat, medical conditions
• As a RNTP, my recommendations are not a substitute for professional medical advise an/or treatment

A signed copy must be retained by both the client and the RNTP

• I may recommend food supplements an/or functional testing as part of your NT programme and may receive a commission on these products
• Standards of professional practice in NT are governed byt the CNHC (Complementary and Natural Healthcare Council code of conduct, ethics and performance
• This document only covers the practice of nutritional therapy within this consultation, and I will make it clear if I intend to provide services that are outside the scope of nutritional therapy practice

The client understands and agrees to the following:

• I, the client, am responsible for contacting my GP about any health concerns
• If I am receiving treatment from my GP, or any other medical provider, I should tell him/her about any nutritional recommendations provided by me, as your RNTP. This is necessary because of any possible reaction between medication and the nutritional programme
• It is important that I tell my RNTP about any medical diagnosis, medication, herbal medicine or food supplements I am taking as this may affect the nutritional programme
• If I am unclear about the agreed nutritional therapy programme/food supplement doses/time period, I should contact my RNTP promptly for clarification
• I understand that the recommendations are personal to me an and may not be appropriate for others
• I must contact my RNTP should I wish to continue any specified supplement programme for longer than the originally agreed period, to avoid any potential adverse reactions
• Recording consultaions using any form of electronic media is not allowed without the written permission of both me and my RNTP
• It is my responsibility to ensure I have a working internet connection for online appointments. If I am unable to connect as scheduled, the appointment is considered a ‘no show’ and charged in full

Confidentiality and Data Protection

I, your RNTP will keep your personal information confiential and secure following the UK GDPR guidelines for the practice. I will not share your information with third parties without your consent. However ,if I believe there is a risk of signifiant harm to yourself or another person, I may pass the information onto an appropriate authority using the leal basis of vital interest. A separate Privacy and Consent Notice is available for your review

Part 2

Payment Terms and Cancellation Policy:

Fees are agreed in advance of the appointment and are paid in advance of a first appointment and/or an online appointment. No NT plan or recommendations will be issued without full payment. Payment can be made by bank transfer. Appointments cancelled with less that 48 hours notice and ‘no shows’ will be charged in full except under extreme circumstances.

In the case of advance payments for service, you have the right to cancel this Agreement within 14 days of the purchase without penalty (‘cooling off period’. If you wish to terminate the agreement within the 14 days Cooling-Off Period you must do so in writing to buffy@buffyrowe.com. I will refund any monies paid prior to cancelling this agreement. If the services have commenced during the 14 day Cooling-Off Period, I will refund any monies due to you for services yet provided. The refund payent will be made within 14 days of cancellation.

We understand the above and agree that my professional serices will be based on the content of this Agreement. I declare that all the information we share during this professional relationship is confidential and to the best of my knowledge is true and correct.

Client Name:

Client Signature:

Date:

RNTP Name:

RNTP Signature:

Date:

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BUFFYROWE.COM GDPR POLICY

My Nutritional Therapy business needs to gather and use certain information about individuals. This policy describes how this personal data will be collected, handled and stored to comply with the UK General Data Protection Regulation.

My Nutritional Therapy Business is committed to a policy of protecting the rights and privacy of clients in accordance with UK General Data Protection Regulation.

My Nutritional Therapy Business commits to:

• Comply with both the law and good practice
• Respect individuals’ rights
• Be open and honest with individuals whose data is held
• * Register our details with the ICO (Information Commissioner’s Office

My Nutritional Therapy Business my hold data for the following purposes:

• Provision of direct healthcare
• Case histories

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

1. Lawful, fair and transparent - data collection must be fair, for a legal purpose and I must be open and transparent as to how the data will be used
2. Limited for its purpose - Data can only be collected for a specific purpose
3. Data minimisation - Any data collected must be necessary and not excessive for its purpose
4. Accurate - the date I hold must be accurate and kept up to date
5. Retention - I cannot store data for longer than necessary
6. Integrity and Confidentiality - The data I hold must be kept safe and secure

Risks:

The main risks are in two key areas:

• information about individuals getting into the wrong hands through poor security or inappropriate disclosure of information
• individuals being harmed through data being inaccurate or insufficient

Responsibilities:

My Nutritional Therapy Business is the data controller for all personal data held by me and is responsible for:

• Analysing and documenting the type of personal data we hold
• Checking procedures to ensure they cover all he 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 sae and secure ways
• Assessing the risk that could be posed to individual rights and freedoms should data be compromised

Data Recording, Security and Storage:

My Nutritional Therapy Business will ensure that any personal data I process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. I 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.

My Nutritional Therapy Business will keep personal data secure against loss or misuse.

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 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 UK GDPR principles
• Servers containing personal data must be kept in a secure location, away from general office space
• Data will be regularly backed up
• All servers containing sensitive data must be protected by security software
• All possible technical measures will be put in place to keep data secure

My Nutritional Therapy Business will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines for our professional association, BANT.

Accountability and Transparency:

My Nutritional Therapy Business will ensure accountability and transparency in all its use of personal data. I will keep written up to date records of all the data processing activities that I do and ensure that they comply with each of the UK GDPR principles I will regularly review my data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy measures.

Consent:

My Nutritional Therapy Business will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. I will seek explicit consent wherever possible. I 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. I will regularly review consents and seek to refresh them regularly or if anything changes.

Direct Marketing:

My Nutritional Therapy Business will seek explicit consent for direct marketing. I 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 supplementary information which means the information which should be provided in a privacy notice My Nutritional Therapy Business will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. I 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, I can request the individual specify the information they are requesting. Once a subject access request has been made, I will not change or amend any of the data that has been requested. Doing so is a criminal offence.

Data Portability Requests:

I will provide the data requested in a structured, commonly used and machine readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month. I will not transfer personal data abroad without express consent.

Third Parties:

As a data processor I will have the written contracts in place with any third-party data controllers that are used. The contract will contain specific clauses which set out my and their liabilities, obligations and responsibilities. I acknowledge my responsibilities as a data processor under UK GDPR and we will protect and respect the rights of data subjects.

Breaches:

Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as I become aware of a breach.

My Nutritional Therapy Business has a legal obligation to report any data breaches to UK Supervisory Authority which is the Information Commissioners Office within 72 hours.

Cookie policy

This cookie policy (“Policy”) describes what cookies are and how and they’re being used by the buffyrowe.com website (“Website” or “Service”) and any of its related products and services (collectively, “Services”). This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Website operator (“Operator”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. You should read this Policy so you can understand the types of cookies we use, the information we collect using cookies and how that information is used. It also describes the choices available to you regarding accepting or declining the use of cookies.

What are cookies?

Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”).

Session cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser.

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Cookies may be set by the Website (“first-party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the Website (“third party cookies”). These third parties can recognize you when you visit our website and also when you visit certain other websites.

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Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features the Website and Services offer.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

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Contacting us

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This document was last updated on September 29, 2022