ACE Nutrition holds some information about you. This document 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 requests 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 September 2020.
Who I am
My website address is: https://acenutrition.net.
ACE Nutrition 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 biochemical testing, I 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. Other business services include corporate plans, educational seminars, workshops, and public talks.
What personal data I collect and why I collect it
You provide me with personal data in the following ways:
- By completing a nutritional therapy questionnaire
- By signing a terms of engagement form
- Via the website
- 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 I 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 in order to provide you with direct healthcare. This means that the legal basis of holding your personal data is for legitimate interest.
Following completion of your healthcare I 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.
When visitors leave comments on the site I collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
If you leave a comment on my site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit my login page, I will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, I will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Information I get from other sources
We may obtain sensitive medical information in the form of test results from biochemical testing companies. I use this information in order to provide you with direct healthcare. This means that the legal basis of 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 us 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 we use 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 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. I will also take reasonable security measures to protect your personal data storage.
I 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. I may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
Do you share my 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:
- 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 (testing companies) or act as our agents on the understanding that they keep the information confidential
- 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 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 biochemical 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 or 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 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. I will seek your explicit consent before processing your data in this way.
How long I retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so I can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on my website (if any), I also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
All records held by ACE Nutrition for the purposes of nutritional therapy will be kept for the duration specified by guidance from our professional association BANT.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data I hold about you, including any data you have provided to us. You can also request that I erase any personal data I hold about you. This does not include any data I am obliged to keep for administrative, legal, or security purposes.
What safeguards are in place to ensure data that identifies me is secure?
Visitor comments may be checked through an automated spam detection service.
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, I 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. 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 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). I 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.
If you have a complaint regarding the use of your personal data then please contact me by email email@example.com and I will do my best to resolve this for 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.