GDPR brought in new legal protection for personal information from May 2018. This tells you what personal information I hold and why, and what your rights are.
Alison Chappell Nutrition provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. Through nutritional therapy consultations, dietary and lifestyle analysis and 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 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.
Reflexology & Massage Therapy
As a full member of the Federation of Holistic Therapies and Association of Reflexologists, I abide by their Codes of Practice and Ethics. The lawful basis under which I hold and use your information is my requirement to hold your information for the following legal reasons
- ‘claims occurring’ insurance
- CNHC requirements to retain information
As I hold special category data (i.e. health related information), the Additional Condition under which I hold and use this information is: for me to fulfil my role as a health care practitioner bound under Confidentiality as defined in their Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional treatments, I will need to ask for and keep personal information. I will only use this for informing treatments and any advice I give as a result of your treatment. 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 taking online payment
- By completing a reflexology consultation form
- By completing a massage therapy consultation form
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
- Treatment details and related notes (which I will take after each consultation)
I will NOT share your information with anyone else (other than within my own practice, or as required for legal process) without explaining why it is necessary and getting your explicit consent.
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 registrant body, CNHC and my professional associations, BANT, AoR, FHT for the processing of a complaint made by you
- Any contractors and advisors that provide a service to me or act as my 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 (e.g., CNHC if I have a duty to do so or if the law allows me 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 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. I will seek your explicit consent before processing your data in this way.
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 in order to provide you with direct healthcare. This means that the legal basis of me 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 Long I Retain Your Information for
Following completion of your healthcare I retain your personal data for the period defined by my professional associations BANT, AoR, FHT and registrant body, CNHC. This enables me to process any complaint you may make. In this case the legal basis of me holding your personal data is for contract administration.
I will keep your information for the following periods
- ‘claims occurring’ insurance: (records to be kept for 7 years after last treatment))
- CNHC requirements to retain information for 8 years
Your data will not be transferred outside the EU without your consent.
Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, I have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information I collect from you.
I will contact you using the contact preferences you give me in relation to:
- Appointment times
- Treatment information or information related to your health
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 [email protected] Under special circumstances, some information may be withheld. 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 I acquired the information
- The purposes of processing the information
- Persons or entities with whom I 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 me to stop processing information about you where I am not required to do so by law or in accordance with the BANT, AoR, FHT 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
I do not carry out any automated processing, which may lead to automated decision based on your personal data.
If you would like to invoke any of the above rights then please write to the Data Controller at 140 Alwyn Road, Bilton, Rugby CV22 7RA or email [email protected]
Full details of your rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you have a complaint regarding the use of your personal data then please contact me by writing to the Data Controller at 140 Alwyn Road, Bilton Rugby CV22 7RA or email [email protected] 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, www.ico.org.uk
- If you don’t agree to your therapist keeping records of information about you and your treatments, or if you don’t allow them to use the information in the way they need to for treatments, the therapist may not be able to treat you
- Your therapist has to keep your records of treatment for a certain period as described above, which may mean that even if you ask them to erase any details about you, they might have to keep these details until after that period has passed
- Your therapist can move their records between their computers and IT systems, as long as your details are protected from being seen by others without your permission.