PRIVACY POLICY

www.karendevine.co.uk is committed to protecting your privacy and complies with the principles of the relevant data protection regulations, including the Data Protection Act (DPA) and the General Data Protection Regulation (GDPR).

This privacy policy explains how and why we collect your personal data and how it is used and how we keep it secure. If you would like to speak to us about our policy or the data we hold on you, please contact Karen directly.

This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. We keep our Privacy Notice under regular review. This Privacy Notice was reviewed in Sept 2020.

What We Do

As part of our business we provide nutritional therapy and colonic hydrotherapy services and workshops 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.

How We Obtain Your Personal Data

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 on the questionnaire

  • During a nutritional therapy consultation

  • Through email, skyp consults, over the telephone, zoom 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 medicinedetails, 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, ARCH 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.

You will also be presented with a hard copy of a privacy policy to sign at an initial consultation to show how I collect and store your data.

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 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/debit 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 achieved through you signing up to our mailing lists via the website.

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

  • 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. I/we ask for permission by you to do so. 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 first seek your explicit consent before processing your data in this way.

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 Karen Devine.  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.

If you would like to invoke any of the above rights then please contact www.karendevine.co.uk

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. 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.

Karen Devine 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.

How long do you hold confidential information for?

All records held by Karen Devine will be kept for the duration specified by guidance from our professional association BANT.

Website technical details

Forms

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.

In compliance with EU legislation, the following table lists the use of cookies on this web site:

Cookie name

Purpose

AcceptCookies

This is used to store whether you have agreed to receive cookies. Persistent for one year.

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

 

Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Social media

We use social media plugins on our website that allows you to connect with social networks in various ways. For these to work the following social media sites including; LinkedIn, Facebook, Instagram; will set cookies through our website which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal date" above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also submit a request to us via email to unsubscribe from our marketing emails.

Our EMS provider is Mail Chimp. We hold the following information about you within our EMS system;

  • Email address

  • I.P address

  • Subscription time & date

  • First Name

  • Last Name

 

 

 

 

Complaints

If you have a complaint regarding the use of your personal data then please contact Karen Devine at kdvn9@aol.com

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.

Reviewing the Policy

This policy will be reviewed on an annual basis and as and when necessary following any legislative changes or relevant best practice recommendations. The last review data is specified at the top of this policy.