I care about your privacy and Fleur Brown Nutrition is committed to protecting it. It is very important to me and I respect your concerns about maintaining it. This Privacy Notice sets out how I maintain your privacy.
Fleur Brown 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 email@example.com. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018
We provide 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 prescriptions (supplements) and lifestyle advice. We run workshops and educational seminars from time to time on health improvement subjects.
Information provided by you
You provide us with personal data in the following ways:
This may include the following information:
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 and regulatory body – The British Association .. 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.
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.
1. 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 with regard to the processing of your data from third parties such as laboratories/testing companies and other healthcare providers. We act as a data controller and processor with regard to the processing of credit card and online payments.
We undertake to protect your personal data at all times, 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 sending you newsletters but this would be subject to you giving us your express consent that you wish to receive newsletters from us.
2. 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:
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.
3. 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 Fleur Brown Nutrition, 1 Clayfield Mews, Newcomen Road, Tunbridge Wells, Kent TN4 9PA..
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:
You have the right, subject to exemptions, to ask to:
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 Fleur Brown at Fleur Brown Nutrition, 1 Clayfield Mews, Newcomen Road, Tunbridge Wells, TN4 9PA or email firstname.lastname@example.org
4. 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.
Fleur Brown 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).
5. How long do you hold confidential information for?
All records held by Fleur Brown Nutrition will be kept for the duration specified by guidance from our professional association The British Association For Nutrition And Lifestyle Medicine (BANT) - for a period of seven years.
6.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 Fleur Brown, Fleur Brown Nutrition, 1 Clayfield Mews, Newcomen Road or email email@example.com 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.
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