This policy outlines how certain information is collected and used about individuals and how it is kept secure, under the General Data Protection Regulation. This notice does not provide exhaustive detail, however, if additional information or explanation is required, requests can be sent to email@example.com
What I Do
I provide nutritional therapy services to clients to improve their health through diet and lifestyle interventions. The focus is 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, I aim to understand the underlying causes of your health issues which we will seek to address together through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice. I may also offer educational workshops, seminars, or online courses for groups.
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
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
I use this information to provide you with direct healthcare. This means that the legal basis of my holding your personal data is for legitimate interest.
Following completion of your healthcare I retain your personal data for the period defined by my professional association the British Association for Nutrition and Lifestyle Medicine (BANT) and registrant body, the Complementary and Natural Healthcare Council (CNHC).
This enables me to process any complaint you may make. In this case the legal basis of holding your personal data is for contract administration.
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 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 Your Personal Data Is Used
I act as a data controller for use of your personal data to provide direct healthcare, and also act as a controller and processor regarding the processing of your data from third parties such as testing companies and other healthcare providers. I act as a data controller and processor regarding 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. Reasonable security measures to protect your personal data storage will be taken. Your personal data may be used where there is an overriding public interest in using the information eg. to safeguard an individual, or to prevent a serious crime. Also, where there is a legal requirement such as a formal court order. Your data may also be used for marketing purposes such as newsletters, but this would be subject to you giving us your express consent to do so.
Do You Share My Information With Other Organisations?
Information about you will be kept confidential. Your information will only be disclosed with other third parties with your express consent except for the following categories of third parties:
Any contractors and advisors that provide a service to me or act as my agent on the understanding that they keep the information confidential
Anyone to whom I may transfer any rights and duties under any agreement I have with you
Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g., (CNHC) if I have a duty to do so or if the law allows me to do so
Your information may be shared with supplement companies and biochemical testing companies as part of providing you with direct healthcare. No sensitive information will be included.
Your express consent will be sought before sharing your information with your GP or other healthcare providers. However, if I believe that your life is in danger, I 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.
Your case history may be shared 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. Your explicit consent will be sought 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 them, 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 Jo Santini. Under special circumstances, some information may be withheld. A response will be made within 20 working days from the point of receiving the request and all necessary information from you. The response will include the details of the personal data we hold on you including:
Sources from which the information was acquired
The purposes of processing the information
Persons or entities with whom the information is shared with
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 BANT 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
No automated processing, which may lead to automated decision based on your personal data in carried out.
If you would like to invoke any of the above rights then please email firstname.lastname@example.org for the attention of the Data Controller.
What Safeguards Are In Place To Ensure Data That Identifies Me Is Secure?
Only information that may identify you in accordance with GDPR is used. This requires the processing of 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, the common law duty of confidence should be followed, 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 that information held 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 are legally and contractually bound to operate and proven security arrangements are in place where data that could or does identify a person are processed.
Jo Santini 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 You Hold Confidential Information For?
All records held by Jo Santini will be kept for the duration specified by guidance from my professional association BANT.
Website Technical Details
We do use electronic forms on our website making use of an available ‘forms module’ which has several built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
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.
If you have a complaint regarding the use of your personal data then please email email@example.com for the attention of the Data Controller and I will do my 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.
This Privacy Notice is regularly reviewed. Last reviewed January 2021.