UPDATED MARCH 2020
I am committed to protecting and respecting your privacy.
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I should be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.
It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes.
This policy only applies to my site. If you leave my site via a link or otherwise, you will be subject to the policy of that website provider. I have no control over that policy or the terms of the website and you should check their policy before continuing to access the site.
- How I Obtain Your Personal Data
I may collect and process the following data about you:
- Direct interactions: You may provide data by filling in forms on my site (or otherwise) or by communicating with me by post, phone, email or otherwise, including when you:
- order my products or services;
- create an account on my site;
- subscribe to my service or publications;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give me feedback
- complete a health questionnaire or booking form
- attend a live or online talk, event, webinar or workshop
- Automated technologies or interactions: As you use my site, I may automatically collect Technical Data about your equipment, browsing actions and usage patterns. I collect this data by using cookies, server logs and similar technologies. I may also receive Technical Data about you if you visit other websites that use my cookies.
- Third parties or publicly available sources: I may receive personal data about you from various third parties and public sources as set out below
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks [such as Facebook, Instagram, Linkedin and YouTube based [inside OR outside] the EU]; and
- search information providers [such as Google based [inside OR outside] the EU].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as PayPal, WePay, and Stripe based [inside OR outside] the EU].
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
This may include the following information:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between me and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from me and our third parties and your communication preferences.
- Sensitive data may include health information that you provide in order to provide you with direct healthcare, including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes, health improvement plans and GP contact information
If I am providing you with healthcare services, I retain your personal data for the period defined by my professional association NNA and registrant body, CNHC. 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.
I may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where I review your Usage Data to work out the percentage of website users using a specific feature of my site. If I link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Uses made of the information
I use information held about you in the following ways:
- To ensure that content from my site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from me or which I feel may interest you, where you have consented to be contacted for such purposes.
- To carry out my obligations arising from any contracts entered into between you and me.
- To allow you to participate in interactive features of my service, when you choose to do so.
- To notify you about changes to my service.
Information I 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 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 me 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 other providers which means the healthcare provided by me may be less effective.
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 expressed consent.
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 expressed consent with the exception of the following categories of third parties:
- My registrant body, CNHC and my professional association, NNA, 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 I have with you
- Any legal or crime prevention agencies and/or to satisfy any regulatory request (eg, CNHC) 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 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 my 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.
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. 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 am 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 me to stop processing information about you where I am not required to do so by law or in accordance with the NNA and CNHC 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.
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, 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.
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 NNA.
Website technical details
I do use electronic forms on my website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. I also aim to use secure forms where appropriate.
IP addresses and cookies
I may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to my advertisers. This is statistical data about my users’ browsing actions and patterns, and does not identify any individual and I will not collect personal information in this way.
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
Unfortunately, the transmission of information via the internet is not completely secure. Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my site; any transmission is at your own risk. Once I have received your information, I will use strict procedures and security features to try to prevent unauthorised access
If you have a complaint regarding the use of your personal data then please contact me.