PRIVACY NOTICE FOR EAT DRINK LIVE WELL
Eat Drink Live Well holds some information about you. This document outlines how that information is used, whom 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
This document was last updated in May 2018.
- What We Do
Eat Drink Live Well 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, nutraceutical prescription (supplements) and lifestyle advice.
We also provide workshops, educational seminars, product sales (e.g. an app, e-books and online courses) and mentoring services.
- What Personal Data We Collect
Personal Data refers to any information capable of identifying an individual. It does not include anonymised data.
Ways we may process personal data include:
- Identity Data such as first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data such as billing address, delivery address, email address and telephone number. May also include social media profile names.
- Financial Data for example bank account and payment card details.
- Transaction Data such as details about payments between us and other details of purchases made by you.
- Technical Data such as login details, internet protocol addresses, browser type, browser plug-in types, time zone setting and location, operating system and platform and other technology on the devices you use to access our site.
- Profile Data such as username and password, purchases or orders, preferences, feedback and survey responses.
- Usage Data information about website use, products and services.
- Marketing and Communications Data such as your preferences in receiving marketing communications from us and your communication preferences.
We may also process Aggregated Data from your personal data but this data will not reveal your identity and as such is not personal data. An example of this is where we review Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
The personal data described above may relate to any of the following categories of person:
- our clients and clients’ personnel
- our prospective employees and contractors
- our current employees and contractors
- third parties with whom we have contact by virtue of providing services
- our contacts, professional advisors or others with whom we work in the context of our services
- our prospective target clients
- those who submit enquiries through our website or whose details are otherwise entered into our client relationship management system
- How We Obtain Your Personal Data for the Eat Drink Live Well Clinic
Information provided by you
You may be providing 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, 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
- Bank details
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 BANT and registrant body, CNHC. 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 get 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.
- How We Obtain Your Personal Data for Indirect Healthcare, Sales and Marketing
We collect data about you through a variety of different methods including:
Interactions: such as filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services;
- work with us;
- network online or offline with us;
- create an account on our site;
- subscribe to our service or newsletter;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
- Opt in via a landing page
- Via interactions on our social media platforms including LinkedIn, Facebook, Instagram, Twitter and Pinterest. We do not store any personal data within this type of tracking.
- Why We Collect Your Personal Data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform a contract between us
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
This may include:
- to respond to any query that you may submit to us
- to manage our relationship with you including by maintaining our database of clients and other third parties for administration, and accounting and relationship management purposes
- to send you any relevant information on our services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent or it is for your legitimate interest
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses
- to allow you to participate in interactive features on our Site when you choose to do so
- as part of our efforts to keep our Site safe and secure
- to comply with any other professional, legal and regulatory obligations which apply to us
- as we feel is necessary to prevent illegal activity or to protect our interests.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, customised online advertising or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com
We use a third party provider, that is GDPR compliant, to process your subscription and deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing us. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
- 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.
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 newsletters but this would be subject to you giving us your express consent. This is gained through you signing up to our mailing lists.
- 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:
- 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. CNHC) 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, 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.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within our company which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
- 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 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, 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 the 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 automated decision based on your personal data.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We understand that you trust us with your personal information and we are committed to ensuring you can manage the privacy and security of your personal information yourself.
With respect to the information relating to you that ends up in our possession, and recognising that it is your choice to provide us with your personal data, we commit to giving you the ability to do all of the following:
- You can verify the details you have submitted to Eat Drink Live Well by contacting us at firstname.lastname@example.org . Our security procedures mean that we may request proof of identity before we reveal information.
- You can also contact us by the same method to change, correct, or delete your personal information controlled by Eat Drink Live Well regarding your profile at any time. Please note though that, if you have shared any information with others through social media channels, that information may remain visible, even if your account is deleted.
- You can unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link at the bottom of any email. Once you do this, you will no longer receive any emails from us unless you select you would still like to receive emails about an individual topic or you explicitly provide consent in future.
If you would like to invoke any of the above rights then please write to the Data Controller at 5 Lena Gardens, London W6 7PY or email email@example.com
- 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. 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.
Eat Drink Live Well 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).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Our Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site as safe as possible. We do not use Malware Scanning.
All sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. When you are on a secure page, a lock icon will appear in the address bar of your browser.
We implement a variety of security measures when a User places an order, hires us, enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider (PayPal or Stripe) or a bank transfer and are not stored or processed on our servers. Payment and login information are encrypted.
Non-sensitive details (e.g. your name, email address) are sent normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- How long do you hold confidential information for?
All records held by Eat Drink Live Well will be kept for the duration specified by guidance from our professional association BANT.
- 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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- Questions and Complaints
If you have a question or complaint regarding the use of your personal data then please contact us by writing to the Data Controller at 5 Lena Gardens, London W6 7PY or email firstname.lastname@example.org and we will do our best to help you.
If at that stage you are not happy with any aspect of how we 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, tel: 01625 545745 or 0303 1231113)
We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com