Regaining Self Privacy Policy I October 2020
What we do
Regaining Self provides nutrition and health testing services to clients to improve their health through nutrition and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health, and chronic health conditions. Through our consultations with you, nutrition 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 nutrition advice, nutraceutical prescription (supplements) and lifestyle advice.
How we obtain your personal data
Information provided by you
You provide us with personal data in the following ways:
This may include the following information:
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, the British Association for Nutrition and Lifestyle Medicine (BANT) and registrant body, the Complementary Natural and Healthcare Council 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 healthcare providers you use, which means the healthcare provided by us may be less effective.
You provide us with personal data in the following ways:
- By completing a client questionnaire
- By signing a Terms of Engagement form
- During a consultation
- Through email, over the telephone
- Through the secure Practice Better application/client portal
- By making debit/credit card payment
- By providing feedback.
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, diet, lifestyle, supplement and prescription 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, the British Association for Nutrition and Lifestyle Medicine (BANT) and registrant body, the Complementary Natural and Healthcare Council 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 healthcare providers you use, 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 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.
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 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:
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.
- 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.
What are my 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 emma@regainingself.com. 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:
You have the right, subject to exemptions, to ask to:
We do not carry out any automated processing which may lead to an 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 emma@regainingself.com.
If you want to access your data you must make a subject access request in writing to emma@regainingself.com. 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 an 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 emma@regainingself.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 (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.
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.
Online consultations
Online consultations are carried out using Zoom which is encrypted and secure. Online consultations are never recorded.
Website cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our site uses cookies to distinguish you from other users of our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our site uses cookies to distinguish you from other users of our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:
- Strictly necessary cookies are cookies that are required for the operation of our site
- Analytical/performance cookies allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example by ensuring that users are finding what they are looking for easily
- Functionality cookies are used to recognise you when you return to our site. This enables us to personalise our content for you and remember your preferences.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.
Mobile device privacy
The following applies to our website, www.regainingself.com, when viewed on a mobile device:
When accessed with a mobile device, our site may collect information automatically, such as the type of mobile device you have, device identifiers, and information about your use of the site. Regardless of the device you use to access the site, it will also collect information you provide, as well as information about your interaction with the site and its content.
If location services are activated on your mobile device, our site may collect information about the location of your device. Your mobile network service providers may collect device-specific information, such as a device identifier, when you use our website or one of our mobile applications. This information collected by your mobile network service will not be associated with your user account with us, or with your personally identifiable information.
When accessed with a mobile device, our site may collect information automatically, such as the type of mobile device you have, device identifiers, and information about your use of the site. Regardless of the device you use to access the site, it will also collect information you provide, as well as information about your interaction with the site and its content.
If location services are activated on your mobile device, our site may collect information about the location of your device. Your mobile network service providers may collect device-specific information, such as a device identifier, when you use our website or one of our mobile applications. This information collected by your mobile network service will not be associated with your user account with us, or with your personally identifiable information.
Third party websites
The Regaining Self website contains links to other websites. Please be notified that Regaining Self cannot be held responsible for the privacy practices of other websites. We encourage all visitors to be aware and read the privacy statements of each and every website that collects personally identifiable information. We are not responsible for the content or functionality of any of those external websites.
If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered the Regaining Self Privacy Notice. We suggest you read the privacy policy of any website before providing any personal information. When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with Regaining Self.
If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered the Regaining Self Privacy Notice. We suggest you read the privacy policy of any website before providing any personal information. When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with Regaining Self.
Marketing
The Regaining Self website Contact Form asks you to “opt-in” to receive marketing and promotional materials. This includes all our marketing communications (the term marketing is broadly defined).
This means you’ll have the choice as to whether you want to receive these messages. You can decide not to receive communications.
What does ‘marketing’ mean?
Marketing does not just mean offering things for sale, but also includes news and information about:
This means you’ll have the choice as to whether you want to receive these messages. You can decide not to receive communications.
What does ‘marketing’ mean?
Marketing does not just mean offering things for sale, but also includes news and information about:
- Benefits and offers
- Our events;
- Products, services and offers (our own, and those of third parties which may interest you)
- Changes in legislation regarding the service we offer
- Changes in the world of marketing which may affect our service.
Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website, www.regainingself.com.
Complaints
Regaining Self 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).
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at emma@regainingself.com, and we will do our 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.
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at emma@regainingself.com, and we will do our 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.
