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Privacy policy

Nutritious Health Ltd

Address: 

First Floor Office 

Westerham Garage

190 London Road

Westerham Kent

England

TN16 2DJ

 

Email:info@nutritioushealth.co.uk

 

Policy Statement

This policy together with Nutritious Health Ltd terms and conditions demonstrates how we collect data from you including information you may provide us with when purchasing any products, programs, newsletters, or online events, when visiting www.nutritioushealth.co.uk you are accepting and consenting to the terms outlined in this policy.

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Nutritious Health Ltd holds some 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  info@nutritioushealth.co.uk we keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2022. This policy describes how this personal data will be collected, handled and stored to comply with the UK General Data Protection Regulation.

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Nutritious Health Ltd  is committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with UK General Data Protection Regulation (GDPR). 

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Nutritious Health Ltd 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 Information Commissioner’s Office (ICO)

 

Data Protection Principles

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

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Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

 

Limited for its purpose

Data can only be collected for a specific purpose.

 

Data minimisation

Any data collected must be necessary and not excessive for its purpose.

 

Accurate

The data we hold must be accurate and kept up to date.

 

Retention

We cannot store data longer than necessary.

 

Integrity and confidentiality

The data we hold must be kept safe and secure

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What We Do

Nutritious Health Ltd provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions.  We 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, we 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.

 

How We Obtain Your Personal Data

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Information provided by you

You provide us 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  

  • Signing up to free ebooks, newsletters, booking courses

 

This may include the following information:

  • basic details such as name, address, email, 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

 

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 completion of your healthcare we retain your personal data for the period defined by our professional association BANT and registrant body, CNHC (The complementary Natural Health council).  This enables us to process any complaint you may make.  In this case the legal basis of our holding your personal data is for contract administration.

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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 coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

 

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 UK General Data Protection Regulation (UK 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.

 

Do you share my 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 categories of third parties:

  • Our registrant body, CNHC (The complementary Natural Health council)  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 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 (eg, if we have a duty to do so or if the law allows us to do so

 

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

 

We may share your case history in an anonymised form with our 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.

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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 nutritioushealth.co.uk. Under special circumstances, some information may be withheld.   We shall respond within 20 working days from the point of receiving the request and all necessary information from you. You are not required to pay any charge for exercising your rights.  Our response will include the details of the personal data we hold on you including:

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  • Sources from which we acquired the information

  • The purposes of processing the information

  • Persons or entities with whom we are 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 us to stop processing information about you where we 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 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

 

We 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 email info@nutritioushealth.co.uk

 

What safeguards are in place to ensure data that identifies me is secure? 

 

We only use information that may identify you in accordance with UK 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 with encryption (which masks data so that unauthorised users cannot see or make sense of it). We 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. 

Nutritious Health Ltd 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).

 

Data Recording, Security and Storage

Nutritious Health Ltd will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

  • In cases when data is stored on printed paper, it will be kept in a secure and locked 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. A password manager will be used to create and store passwords.

  • Data stored on CDs or 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.  An authenticator app will be used to access cloud data.

  • 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

 

How long do you hold confidential information for? 

All records held by the Nutritious Health Ltd will be kept for the duration specified by guidance from our professional association BANT.

 

Direct Marketing

Nutritious Health Ltd will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages.  PECR restricts the circumstances in which we can market people and other organisations by phone, text, email or other electronic means.

We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

 

Website technical details 

 

Forms 

We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate. 

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We have a dedicated page about our use of cookies, all of which are only Essential 

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> Find out more about our cookies >

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Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

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 

 

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

 

Analytics 

Like most websites, we make use of 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.

 

Reporting breaches

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

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Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at info@nutritioushealth.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.  

ICO address: ICO website www.ico.org.uk

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wimslow

Cheshire

SK9 5AF

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