client data protection policy
PRIVACY NOTICE
Deborah Lacey Nutrition 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 deb@deborahlaceynutrition.co.uk. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2018.
What we do
Deborah Lacey Nutrition 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 recommendations (supplements) and lifestyle advice. Preventative healthcare, optimisation of physical and mental health and chronic health conditions are also addressed in a group setting through workshops and educational seminars.
How we obtain your personal data
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 providing credit/debit card and online payment
This may include the following information:
Basic details such as name, address and contact details
Details of contact we have had with you, such as referrals and appointment requests
Health information including your 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 health advice. 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, the British Association for Nutrition and Lifestyle Medicine (BANT), and registrant body, the Complimentary and Natural Healthcare Council (CNHC). 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.
Information we obtain 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/debit 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 over-riding 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, but this would be subject to you giving us your explicit 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, and our professional association, BANT, for the processing of a complaint made by you
Any contractors and advisors who 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 (e.g. CNHC) 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 explicit 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 on to 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 or online forums. We will seek your explicit consent before processing your data in this way.
What are your rights?
Every individual has the right to see, amend, delete or have a copy of data held that can identify them, 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 deb@deborahlaceynutrition.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. Our response will include the details of the personal data we hold on you, including:
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 Deborah Lacey Nutrition or email deb@deborahlaceynutrition.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 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.
Deborah Lacey 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).
How long do you hold confidential information for?
All records held by Deborah Lacey Nutrition will be kept for the duration specified by guidance from our professional association, BANT.
Website technical details
Forms
We 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.
Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. 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.
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 of it. 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.
Complaints
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Deborah Lacey Nutrition, 18 Kingston Lane, Shoreham-by-Sea, West Sussex, BN43 6YB or email deb@deborahlaceynutrition.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.
Website date protection policy
This Privacy Policy governs the manner in which Deborah Lacey Nutrition collects, uses, maintains and discloses information collected from users (each, a “User”) of the deborahlaceynutrition.co.uk website (“Site”). This privacy policy applies to the Site and all products and services offered by Deborah Lacey Nutrition.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, fill out a form and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number, Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.
How we use collected information
Deborah Lacey Nutrition collects and uses Users personal information for the following purposes:
To improve our Site we continually strive to improve our website offerings based on the information and feedback we receive from you.
To send periodic emails
The email address Users provide for order processing, will only be used to send them information and updates pertaining to their order. It may also be used to respond to their inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website‘s own terms and policies.
Advertising
Ads appearing on our site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non personal identification information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.
Compliance with the children‘s online privacy protection act
Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.
Changes to this privacy policy
Deborah Lacey Nutrition has the discretion to update this privacy policy at any time. When we do, we shall post a notification on the main page of our Site, and revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy and terms & conditions. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Contacting us
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:
Deborah Lacey Nutrition
18 Kingston Lane
Shoreham-by-Sea
West Sussex
BN43 6YB
www.deborahlaceynutrition.co.uk
deb@deborahlaceynutrition.co.uk