DATA PROTECTION

PRIVACY POLICY

Natural Food Therapy holds some information about you. This document outlines how that information is collected, processed and protected in accordance with the General Data Protection Regulation (GDPR). Natural Food Therapy is committed to ensuring that your privacy is protected. Should you provide sensitive information it will be used in accordance with this privacy statement. This notice does not provide exhaustive detail. If you require any additional information or explanation, please email your request to info@naturalfoodtherapy.co.uk. This privacy policy was last reviewed May 2018.

What We Do

Natural Food Therapy provides nutritional therapy services to clients to improve health through diet and lifestyle interventions. We focus on preventative healthcare, optimising health and supporting chronic health conditions. Through nutritional therapy consultations, dietary analysis and biochemical testing, we seek to understand the underlying causes of your health issues in order to provide individualised nutritional plans, nutraceutical prescription (supplements) and lifestyle advice.

How We Obtain Your Personal Data

Information provided by you

You may be providing us with personal data in the following ways:

- Through completing a client form
- By signing a disclaimer
- During a nutritional therapy consultation
- By payment through debit/credit card or online payment
- Through email, telephone, Skype, post or social media
- When ordering a biochemical/nutritional test
- Through automated technologies such as cookies

This may include the following information:

- Identity data such as full name, date of birth and contact details
- Details of contact we have had with you such as appointment requests
- Health information including GP contact, medical history, dietary/lifestyle information, medication/supplements, family medical history, test results, consultation notes and nutrition plans
- Financial data such as details about payments between us

This information is used in order to provide you with direct healthcare. This means that the lawful basis of our holding your personal data is for legitimate interest.

Following completion of your healthcare we retain personal data for the period defined by our professional association NNA and registrant body CNHC, this is a period of 8 years. For minor’s (aged under 18) records are kept until age 25. This enables us to process any complaint that may be made. The legal basis of 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 private testing companies if you order a test. This information is used to provide you with direct healthcare. On occasions, we may also obtain sensitive data from other healthcare providers or individuals authorised by you to give out such information. This is subject to you giving us your express consent.

How we use your personal data

We act as a data controller for use of 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 act as a data controller and processor in regard to the processing of credit card and online payments.

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 a serious crime.  Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.

Disclosure of your personal data with other organisations

We will keep information about you confidential. We will only disclose information with other third parties with your express consent with the exception of the following categories of third parties:

- Our registrant body CNHC for the processing of a complaint made by 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
- Anyone whom we may transfer our rights and duties under any agreement we have with you

We may share your information with biochemical testing companies and supplement companies as part of proving 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.

On occasions, we may share a brief summary of your health problems in an anonymised form for the purpose to seek professional health opinion in order to provide you with better healthcare, or for the purpose of professional development.  This may be at clinical supervision meetings, conferences, private and professional health online forums. In such cases your personal data and identity will not be disclosed and will remain fully confidential. We may publish your anonymised full case history in medical journals, trade magazines or online professional sites.  We will first seek your explicit consent before processing your data in this way.

Your Legal 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 Natural Food Therapy Ltd. We shall respond within 30 days from the 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 including:

- The purposes of processing the information
- Sources from which we acquired the information
- Persons or entities with whom we are sharing the information (if applicable)

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 us to stop processing information about you where we are not required to do so by law or in accordance with the NNA & 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 us.
- Object at any time to the processing of personal data concerning you

If you would like to invoke any of the above rights then please email sasha@naturalfoodtherapy.co.uk

Data Protection And Security

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 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. 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 kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops. Natural Food Therapy is registered with the Information Commissioner’s Office (ICO). A copy of the registration is available through the ICO website (search by business name: Natural Food Therapy Limited).

Cookies

Cookies are small pieces of data stored in encrypted text files and located in browser directories. Their purpose is to make the website easier to use, help analyse web traffic or remember your preferences. If you are not happy with this, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We do not make use of cookies to collect any private or personally identifiable information. The cookies used contain random strings of characters alongside minimal information about the state and session of the website, which in no way collects or discloses any personal information about you as a visitor.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org 

Analytics

Just like many websites, we use analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout 

Complaints

If you have a complaint regarding the use of your personal data then please write to the data controller by emailing sasha@naturalfoodtherapy.co.uk and we will do our 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.