Lucy Bishop, The Nutritional Therapist, Diet & Health Coach
Statement about General Data Protection Regulation (GDPR)
With effect from 25th May 2018, the way in which personal data is treated will change; this is known as General Data Protection Regulation, or GDPR.
The privacy of clients’ personal data is of utmost importance to me and is treated with respect.
Lucy Bishop, the Nutritional Therapist:
is committed to observing reasonable procedures to safeguard and protect any personal data that a client shares;
only uses the personal data that a client has shared for the purposes that would be expected and have been detailed on registration (including making appointments and/or contacting the client, or the practitioner, about a change to an existing appointment);
only processes personal data about children (those aged under 16 years) with the consent of the parents or legal guardians;
does not sell, trade or rent any personal data to third parties;
will always respond to a request to remove personal data.
Marketing is only done by email newsletters once you have expressly given your consent.
Every e-newsletter contains the option to unsubscribe at any time.
Clinic Policy at The Traditional Acupuncture Centre:
All Practitioners practicing at the Trad-Ac Therapies Ltd’s premises at Trinity House request that their clients complete a Practitioner/Client Registration Form; some practitioners may also request their clients complete their own, additional versions of registration forms that collect therapy-related or treatment-related specific personal data needed by the practitioner.
Some of the personal data on the Practitioner/Client Registration Form (typically mobile and/or home telephone numbers) is shared with Trad-Ac Therapies Ltd. This data is used by Trad-Ac Therapies Ltd in the event that a practitioner needs to contact their client about future appointments or other related matters, and/or the practitioner needs to ask the Reception function to contact the client on the practitioner’s behalf.
In addition, a practitioner may need to retain their records of a client’s personal data for a number of years, in line with guidance published by their respective professional bodies. Personal data recorded on the Practitioner/Client Registration Form may help the practitioner determine the appropriate point in time at which they should remove their own client records for an individual client and also advise Trad-Ac Therapies Ltd to do like-wise.
Other information about data privacy:
Some personal data may be collected automatically when a visit is made to the thenutritionaltherapist.com website. Such data may include information about IP addresses; internet browsers; the means used to access the website; and clicks, including pages visited.
For further details please read on:
I, Lucy Bishop, The Nutritional Therapist, hold certain 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 firstname.lastname@example.org. I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.
1. What I Do
I provide diet & health coaching 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 consultations and dietary and lifestyle analysis, 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.
I also offer educational workshops on a range of nutrition, diet & lifestyle topics.
2. How I Obtain Your Personal Data
Information provided by you
You provide me with personal data in the following ways:
- By completing an initial consultation questionnaire
- By signing a terms of engagement form
- During 1 to 1 coaching consultations
- 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, 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 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 registrant body, The Federation of Nutritional Therapy Practitioners. This enables me to process any complaint you may make. In this case the legal basis of 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 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 me your express consent.
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.
4. Do I share your 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:
- Our registrant body the FNTP and our professional association, 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 we have with you
- Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, URHP) 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 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.
I 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. I will seek your explicit consent before processing your data in this way.
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 email@example.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 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 FNTP 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 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 Nutritional Therapist, The Traditional Acupuncture Centre, 19 Binswood Street, Leamington Spa, CV32 5RW.
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 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, 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.
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 (search by business name).
7. How long do you hold confidential information for?
All records held will be kept for the duration specified by guidance from our professional association FNTP.
8. Website technical details
I use electronic forms on my website and use secure forms where appropriate.
Eg, These cookies are used to collect information about how visitors use my site. I use the information to compile reports and to help me improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
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
If you have a complaint regarding the use of your personal data then please contact me by writing to the The Nutritional Therapist, The Traditional Acupuncture Centre, 19 Binswood Street, Leamington Spa, CV32 5RW or email firstname.lastname@example.org.