I hold some information about you and below is an outline of how that information is used, whom it may be shared with and how it is kept 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 email@example.com. I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in September 2018.
1. What I do:
I provide nutritional therapy 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 biochemical testing, I 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.
2. How I Obtain Your Personal Data
Information provided by you:
You may provide me 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
This may include the following information:
• Basic details such as name, address, contact details
• Details of contact I 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
I use this information in order to provide you with direct healthcare. This means that the legal basis of me 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 CNHC, and by my indemnity insurance provider (Balens Health Professional Policy). This enables me to process any complaint you may make. In this case the legal basis of me 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 biochemical testing companies. I use this information in order to provide you with direct healthcare. This means that the legal basis of me 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 you giving us 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 us 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 online payments.
I 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. 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. Also where there is a legal requirement such as a formal court order. I may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
4. Do I Share Your Information With Other Organisations?
I 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:
• 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 I may transfer our rights and duties under any agreement I have with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, CNHC, BANT if I have a duty to do so or if the law allows us to do so.
I may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. I will not include any sensitive information.
I will seek your express consent before sharing your information with your GP or other healthcare providers. However if I 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.
I may share your case history in an anonymised form with my 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.
5. 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 Buffy@buffyrowe.com. 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 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 me.
• Object at any time to the processing of personal data concerning you.
I 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 me at firstname.lastname@example.org
6. What Safeguards are in Place to Ensure Data that Identifies You is Secure?
I 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, I 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. 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 we hold is kept in secure locations, restrict access to information to myself 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). I 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.
Buffy Rowe is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).
7. How Long Do You Hold Confidential Information For?
All records held by Nourish to Flourish will be kept for the duration specified by guidance from our professional association BANT.
If you have a complaint regarding the use of your personal data then please contact us by writing to me at email@example.com 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 on 01625 545745 or 0303 1231113.