Privacy Notice

I hold 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 me at info@pn4w.com. I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in 01/09/2023.

 

What I Do

I provide nutritional therapy in a naturopathic&functional  way 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.

1. 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

This may include the following information:
• basic details such as name, address, contact details and next of kin
• 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 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 FNTP registrant body, GRCCT. 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 I get from other sources

I may obtain sensitive medical information in the form of test results from biochemical testing companies (laboratories). 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 (myself and your other healthcare provider) 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 another provider (practitioner) which means that the healthcare provided by me may be less effective.

Consent to discuss your case with another of your health care providers will always be asked for separately.

2. 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/ laboratories and other healthcare providers.

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.

3.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 professional association, FNTP, for the processing of a complaint made by you. FNTP's  registrant body is GRCCT

·      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 my rights and duties under any agreement I have with you

·       Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. GRCCT) 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.

4.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 me at info@pn4w.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 have shared 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 FNTP and GRCCT 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 me email info@pn4w.com.

5. 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, and protect personal and confidential information in locked filing cabinets in a locked, alarm protected office .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.

I am registered with the Information Commissioner’s Office (ICO) as a data controller and collect data for a variety of purposes. A copy of the registration is available through the ICO website.

6. How long do you hold confidential information for?

All records held by me will be kept for the duration specified by guidance from my professional association FNTP.

7. Complaints

If you have a complaint regarding the use of your personal data then please contact me by emailing me at info@pn4w.com. and I will do my best to help you.

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Data protection policy

1 Introduction

1.     1.1  Purpose of Policy

I need to gather and use certain information about individuals.
These can include clients, suppliers, employees and other people that I have a business relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.    1.2  Policy Statement

I am committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.
I commit to:
• comply with both the law and good practice

• respect individuals’ rights
• be open and honest with individuals whose data is held
• provide training and support to staff who handle personal data, so that they can act confidently and consistently
• Register my company's details with the Information Commissioner’s Office (ICO)

1.3  Personal Data

I may hold data for the following purposes:
- Provision of direct healthcare
- Case histories
Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.

From the above list I may hold special category data for the following purposes:

- Provision of direct healthcare

1.4 Data Protection Principles

There are six data protection principles that are core to the General Data Protection Regulation. I will make every possible effort to comply with these principles at all times in my information- handling practices. The principles are:
1) Lawful, fair and transparent                                                                                                

Data collection must be fair, for a legal purpose and I must be open and transparent as to how the data will be used.
2) Limited for its purpose
Data can only be collected for a specific purpose.                                                                    

 3) Data minimisation
Any data collected must be necessary and not excessive for its purpose.

4) Accurate
The data I hold must be accurate and kept up to date.
5) Retention
I cannot store data longer than necessary.                                                                                  

6) Integrity and confidentiality
The data I hold must be kept safe and secure.

1.5 Key risks

The main risks are in two key areas:
• information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
• individuals being harmed through data being inaccurate or insufficient

2.      Responsibilities

I am the data controller for all personal data held by me and I am responsible for:

• Analysing and documenting the type of personal data I hold
• Checking procedures to ensure they cover all the rights of the individual
• Identifying the lawful basis for processing data

• Ensuring consent procedures are lawful
• Implementing and reviewing procedures to detect, report and investigate personal data breaches • Storing data in safe and secure ways
• Assessing the risk that could be posed to individual rights and freedoms should data be compromised

3.      Data Recording, Security and Storage

  3.1  Data accuracy and relevance

I will ensure that any personal data I process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. I will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

 3.2  Data security

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

 3.3  Storing data securely

• In cases when data is stored on printed paper, it will be kept in a secure place (locked filing cabinet in locked alarm protected office) 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.

• Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
• Any Cloud services used to store personal data will be assessed for compliance with 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

3.4 Data retention

I will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of my professional association FNTP.

4.  Accountability and Transparency

I will ensure accountability and transparency in all my use of personal data. I will keep written up-to- date records of all the data processing activities that I do and ensure that they comply with each of the GDPR principles.
I will regularly review my data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

5.  Consent

I will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. I will seek explicit consent wherever possible.

I will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent.
I will regularly review consents and seek to refresh them regularly or if anything changes.

6.   Direct Marketing

At present (2018) I do not do carry out direct marketing. If this changes I 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.
I will seek explicit consent for direct marketing. I will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

7.  Subject Access Requests

    7.1  What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

   7.2  How to deal with subject access requests

I will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. I endeavour to provide data subjects access to their information in commonly used electronic formats.
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.

I can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, I can request the individual specify the information they are requesting.
Once a subject access request has been made, I will not change or amend any of the data that has been requested. Doing so is a criminal offence.

7.3 Data portability requests

I will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a photocopy, word or PDF file, although other formats are acceptable. I must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.

8.   Transferring data internationally

There are restrictions on international transfers of personal data. I will not transfer personal data abroad without express consent.

9.    Third Parties

9.1 Using third party controllers and processors

As a data controller and/or data processor, I will have written contracts in place with any third-party data controllers (and/or) data processors that I use. The contract will contain specific clauses which set out my and their liabilities, obligations and responsibilities.
As a data controller, I will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.

As a data processor, I will only act on the documented instructions of a controller. I acknowledge my responsibilities as a data processor under GDPR and I will protect and respect the rights of data subjects.

9.2 Contracts

My contracts will comply with the standards set out by the ICO and, where possible, follow standard contractual clauses. My contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.

10 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 I become aware of a breach.

I have a legal obligation to report any data breaches to UK Supervisory authority which is the Information Commissioners Office .