At Balanced Body Nutrition, we appreciate that when you share your data with us, you trust us to look after it.
This Privacy Notice was last reviewed in May 2018 to reflect new Data Protection Legislation coming in to force in the UK on 25th May 2018. The General Data Protection Regulation (GDPR), is EU wide legislation, and is currently being enacted into UK law and will become the 2018 Data Protection Act. Although GDPR aims to protect the data of EU citizens, we extend these rights to all of our clients. We remain committed to protecting your rights and interests and will continue to keep our Privacy Notice under regular review.
In this Privacy Notice, we outline how your information is used, with whom 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 email@example.com.
What we do
Balanced Body Nutrition (also referred to here as ‘we’ and ‘us’) 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 supplementation and lifestyle advice. Other business services may include workshops and education seminars.
How we obain your personal data
Information provided by you
You provide us with personal data in the following ways:
- By signing a terms of engagement form
- By filling in a contact form on our website www.balancedbodynutrition.com.
- During a nutritional therapy and functional medicine consultation in person or online.
- Via 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, biochemical test results, clinic notes and health improvement plans
- GP contact information and any other specialists relevant to your health and wellbeing that you tell us about
- 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 (British Association for Applied Nutrition & Nutritional Therapy) and registrant body, CNHC (Complimentary Nutrition & Healthcare 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.
Information we get from other sources:
We may obtain sensitive medical information in the form of test results from biochemical testing companies and any relevant information you may provide to these 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 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.
Do we share your infromation 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 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 (e.g. BANT, 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 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.
Your rights to controlling your data
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 firstname.lastname@example.org. 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 contact us by writing to the Data Controller at Pavilion, 96 Kensington High Street, London W8 4SG or email email@example.com
Ensuring data that identifies you 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.
Balanced Body 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 we hold confidential information for
All records and personal data held by Balanced Body Nutrition Ltd will be kept for no longer than is necessary and duration specified by guidance from our professional association BANT. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with services you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In all cases, our need to use your personal information will be reassessed on a regular basis, and information which is no longer required for any purposes will be disposed of.
Insurance policy conditions
In addition, Balanced Body Nutrition Ltd insured under Balens Health Professionals Insurance Policy, underwritten by Zurich Insurance Plc. It is a condition of our Insurance Policy as well as to take and retain client records. The policy wording notes:
‘The records shall be kept for at least 7 years following the last occasion on which treatment was given. In the case of treatment to minors, it is advisable that records should be kept or at least 7 years after they reach the age of majority (18)’. Record Keeping - Condition 14 c, on page 35.
In the unlikely event of a claim situation, there are provisions under the GDPR with regards to keeping your records; giving us the right to hold your records to comply with our insurance Terms and Conditions, where we also have the right to refuse your request for them to be deleted under your Right of Erasure.
Website technical details
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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If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Pavilion, 96 Kensington High Street, London W8 4SG or email firstname.lastname@example.org 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.