Foreshore Nutrition holds some information about you. Outlined below is 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 firstname.lastname@example.org. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in August 2020. By registering as a user of the services provided by Foreshore Nutrition or by using the website generally, you agree to these terms.
1. What We Do
Foreshore Nutrition 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, functional testing and/or nutraceutical supplements (if clinically appropriate) and lifestyle advice. One-to-one consultations are available remotely via zoom.
2. How We Obtain Your Personal Data
Information provided by you
You provide us 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
By taking credit card and online payment
This may include the following information:
Basic details such as name, address, date of birth, contact details and next of kin
Details of contact we have had with you such as referrals and appointment requests, website contact form
Health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans
GP and/or other health professional information
We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding our 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 Nutrition and Lifestyle Medicine) and registrant body (CNHC, Complementary and Natural 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 obtain from other sources
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. Under these circumstances we reserve the right to refuse to provide further nutritional therapy services if we feel there is legitimate concern for your safety.
3. 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.
If you are an existing client or customer, I may contact you by various means with information about goods and services related to those which were the subject of a previous sale or service to you. Please contact email@example.com if you do not wish to receive this information.
We may use your personal data where there is an overwhelming 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.
4. Do You Share My Information With Other Organisations?
We will keep information about you confidential at all times. 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) 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 or through publishing in medical journals, trade magazines or online professional sites. We 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 and will not be charged a fee.
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 to, 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 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 an automated decision based on your personal data.
If you would like to invoke any of the above rights then please write to the Data Controller at email@example.com.
My site may occasionally contain links to related partner networks, advertisements or affiliates. Should you follow a link to these websites please note that Foreshore Nutrition does not accept any responsibility or liability for their own privacy policies and you should check these before submitting any personal data on their website.
6. 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 how your information will be used and allow you to decide if and how your information can be shared.
We also ensure that 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 PCs or laptops with password protection and/or encryption (which masks data so that unauthorised users cannot see or make sense of it) and any information recorded in paper form is kept securely in locked storage. 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.
Foreshore 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).
7. How Long Do You Hold Confidential Information For?
All records held by Foreshore Nutrition will be kept for the duration specified by guidance from our professional association BANT, insurers and in order to adhere to the requirements of HMRC (currently a minimum of 8 years from the date of your last consultation).
8. Website Technical Details
We 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.
This is used to store whether you have agreed to receive cookies and persists for one year.
Google Analytics, -utma, -utmb, -utmc, -utmz:
These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us 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 viist http://tools.google.com/dlpage/gaoptout.
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at 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 contact or make a formal complaint to the Information Commissioner's Office (ICO), you can contact them via https://ico.org.uk/global/contact-us/ or https://ico.org.uk/make-a-complaint/
Please advise me of any changes to the information that Foreshore Nutrition holds about you so that records can be maintained accurately and updated appropriately.