The symphony of health holistic nutrition holds some information about you. This page 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 request for this should be sent to firstname.lastname@example.org.
I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2022.
1. What I do
The symphony of health provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. I focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and functional biochemical testing, I aim to understand the underlying causes of your health issues which I will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.
I also provide group programmes and workshops.
2. How I obtain your personal data
Information provided by you
You provide me 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 joining my nutrition mailing list
• Via social media channels such as Facebook and Instagram
• By taking credit card and online payment
• By filling in a form on my website such as downloading my eBook of booking a free 30 minute consultation
• When you subscribe to my services via any other channel
• When you make any bookings via the Practice Better (booking) system connected with my account
• When you opt in to receive marketing messages, or news by email, SMS or the means.
This may include the following information:
• Basic details such as name, address, contact details and next of kin
• Details of contact I have had with you such as referrals and appointment requests
• Health information including your previous medical history, dietary, lifestyle, supplement and medicine details, functional/clinical test results, clinic notes and health improvement plans.
• GP contact information
• Bank details
• Data collected from my website
I use this information in order to provide you with direct healthcare. This means that the legal basis for us holding and processing your personal data is in line with GDPR Aticle 6 (1) 9b) and Article 9 (2) (h):
• Legal obligation: the processing is necessary for compliance with a legal obligation Article 6 (1) (c) *
• Vital interests: the processing is necessary to protect someone’s life. Article 6 (1) (d)
• Public interest: the processing is necessary to perform a task in the public interest. Article 6 (1) (e)
• Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third-party Article 6 (1) (f)
Information I get from other sources
I may obtain sensitive medical information in the form of test results from functional testing companies. I use this information to provide you with direct healthcare. This means that the legal basis of our 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 us may be less effective.
3. How I use and store 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 protect all personal data I hold about you by ensuring that I have appropriate organisational and technical security measures in place to prevent unauthorised access or unlawful processing of personal data and to prevent personal data being lost, destroyed or damaged.
This is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.
At your request, I may occasionally transfer personal information to you via email, or you may choose to transfer information to me via email. Email is not a secure method of information transmission; if you choose to send or receive such information via email, you do so understand the risk associated with doing so.
I may use your personal data where there is an overriding public interest in using 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. How I retain your personal data
Any personal data you provide will be held for as long as is necessary having regard to the purpose for which it was collected and in accordance with all applicable UK laws. Unless I explain otherwise to you, I will retain your personal data on the basis of the following guidelines:
For as long as I have a reasonable business need, such as managing our relationship with you and managing our business
For as long as I provide services and/or treatment to you and then for as long as someone could bring a complaint or claim against me (in general this is a period of 8 years)
In line with the requirements of my professional association ANP (Association of Naturopathic Practitioners) and in accordance with GDPR law.
5. Sharing 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:
• My professional association, ANP, for the processing of a complaint made by you
• Any contractors and advisors that provide a service to me or act as our agents on the understanding that they keep the information confidential (such as my booking and payment systems)
• 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 (such as ANP) if I have a duty to do so or if the law allows us to do so.
I may share your information with supplement companies and functional 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, social services in the case of a child 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 my peers for the purpose of professional development. This may be at clinical supervision meeting, 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.
6. 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 request in writing to the Data Controller at email@example.com
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 we acquired the information
• The purposes of processing the information
• Persons and entities with whom we are sharing the information
7. What safeguards are in place to ensure data that identifies you 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, we also have to follow the common law 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 you 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 us are legally bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
The symphony of health 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).
8. How long I hold confidential information
All records held by The symphony of health will be kept for the duration specified by guidance from our professional association ANP.
9. 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. We also aim to use secure forms where appropriate.
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.
My website uses cookie to distinguish you from other users of our websites. This helps me provide you with a good experience when you browse my website and allows me to improve it.
By law, website operators are required to ask for a website user’s permission when placing certain kinds of cookie on their devices for the first time. You can opt out of this.
Like most websites, I use analytics software to help me understand trends in popularity of my website and of different sections. I make no use of personally identifiable information in any if the statistical reports.
If you have a complaint regarding the use of your personal data then please contact me by writing to the Data Controller at firstname.lastname@example.org and I will do my very 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.