Nolan 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 the firstname.lastname@example.org. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in June 2018.
Personal Data - Information Provided By You
In order to work with your health goals, Nolan Nutrition may require detailed medical information. We will only collect what is relevant and necessary to achieve those goals. When you arrange an appointment, you provide us with some of these details by completing a Health Questionnaire and taking part in the assessment process. This data is always held securely and not shared with anyone without your explicit consent. Contact details provided by you such as telephone numbers, postal and email addresses may be used to remind you of future appointments or shared with companies who need to send you test kits, supplements, etc, and only with your express consent. As primary healthcare practitioners there may be circumstances related to your treatment and on-going care that will require the sharing of your medical records with other healthcare practitioners e.g GPs, consultants, surgeons and/or medical insurance companies. Where this is required we will always inform you first unless we are under a legal obligation to comply.
For marketing purposes, Nolan Nutrition will only use the contact details you provide to respond to your enquiries. We will not inundate you with information we assume to be of interest to you!
Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
Nolan Nutrition will only collect the information needed to provide you with the services you require. This means that Nolan Nutrition does not sell or broker your data. 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.
Personal Data - Information We Get From Other Sources
Nolan Nutrition 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 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 cheque and BACS 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.
Do we share your 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 (eg, 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.
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. All data held by Nolan Nutrition is held in the United Kingdom.
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.
Nolan 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 (please search by business name).
All records held by Nolan Nutrition will be kept for the duration specified by guidance from our professional association BANT.
What are your rights?
Whilst Nolan Nutrition is in possession of, or processing your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you. You do not need to give a reason to see this data.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data.
Right of portability – you have the right to transfer the data we hold about you to another organisation, without hindrance from us.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling, although we do not carry out any automated processing, which may lead to automated decisions based on your personal data.
If you want to access your data you must make a subject access request in writing to email@example.com. Under special circumstances, some information may be withheld. We will also require proof of identification including photographic identification. Nolan Nutrition reserves the right to ensure that requests are genuine before releasing personal data. We shall respond within 30 working days from the point of receiving the request and all necessary information from you. At your request, Nolan Nutrition can confirm what information it holds about you and how it is processed.
If you would like to invoke any of the above rights then please write to the Data Controller at Nolan Nutrition, York Natural Health, 36 York Road, Acomb, York YO24 4LZ or email firstname.lastname@example.org.
In the event that you wish to make a complaint about how your personal data is being processed by Nolan Nutrition, send your complaint to Clarissa Nolan, Nolan Nutrition, York Natural Health, 36 York Road, Acomb, York YO24 4LZ or email email@example.com. If you do not receive a response within 30 days, please send your complaint to the ICO, see https://ico.org.uk/make-a-complaint/.