SHIRLEY BRIARS NUTRITION holds some information about you. This document outlines how that information is used, who I may share that information with and how I keep it 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 the Shirley@shirleybriarsnutrition.co.uk . I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in October 2018.
1. What I Do
Shirley Briars Nutrition provides 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 I will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.
As well as one to one consultations, Shirley Briars Nutrition also engages in workshops and talks to groups of people.
2. How I Obtain Your Personal Data
Information provided by you
You 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
– By taking credit card and online payment
This may include the following information:
– basic details such as name, address, contact details and next of kin
– 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
– Bank details
I use this information in order to provide you with direct healthcare. This means that the legal basis of my 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 association BANT and registrant body CNHC. This enables me to process any complaint you may make. In this case the legal basis of my holding your personal data is for contract administration.
Information we 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 my 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 me may be less effective.
I also collect data about you through a variety of different methods including:
Interactions: such as filling in forms on my website (or at talks and workshops) or by communicating with me by post, phone, email or otherwise, including when you:
- enquire about my services
- work with me
- network with me, online or offline
- subscribe to a service or newsletter
- request resources or marketing be sent to you
- Via interactions on my social media platforms including Facebook, Instagram, LinkedIn and Twitter. (No data is stored within this type of tracking)
I use a third party provider, that is GDPR compliant, to process your subscription and deliver my newsletter. I gather statistics around email opening and clicks using industry standard technologies to help me monitor and improve my e-newsletter. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of my emails or by emailing me. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
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 credit card and 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 my 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 me your express consent.
I will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where I need to perform a contract between us
- Where it is necessary for legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where I need to comply with a legal or regulatory obligation
This may include:
- to respond to any query that you may submit to me
- to manage my relationship with you including by maintaining my database of clients and other third parties for administration, and accounting and relationship management purposes
- to send you any relevant information on my services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent or it is for a legitimate interest
- to administer my site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses
- as part of my efforts to keep my site safe and secure
- to comply with any other professional, legal and regulatory obligations
- as I feel is necessary to prevent illegal activity or to protect my interests.
Generally, I do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, customised online advertising or text message. You have the right to withdraw consent to marketing at any time by emailing me at firstname.lastname@example.org
4. Do you share my information with other organisations?
I will 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:
– My registrant body, CNHC, and my professional association, BANT, for the processing of a complaint made by you
– Any contractors and advisors that provide a service to me or act as my 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), if I have a duty to do so or if the law allows me 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 I 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. I will seek your explicit consent before processing your data in this way.
Some of my third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever I transfer your personal data out of the EEA, I do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where I use certain service providers, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where I use providers based in the United States, I may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
I may request your explicit consent to the specific transfer if none of the above safeguards are available. You will have the right to withdraw this consent at any time.
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 Shirley Briars Nutrition. 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 are 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 me, 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 to the Data Controller at Shirley Briars Nutrition by email to email@example.com
6. What safeguards are in place to ensure data that identifies me is secure?
I only use information that may identify you in accordance with GDPR. This requires me 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 I 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). I ensure external data processors that support me 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.
Shirley Briars Nutrition 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 the Shirley Briars Nutrition will be kept for the duration specified by guidance from our professional association BANT.
I do use electronic forms on my website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. I also aim to use secure forms where appropriate.
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If you have a complaint regarding the use of your personal data then please contact me by emailing the Data Controller at Shirley Briars Nutrition at my email address firstname.lastname@example.org 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.
Please advise me of any changes to the information that I hold about you so that I can maintain accurate and up to date records.