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WENDY SMITH BSc (Hons) CNHC Registered Nutritional Therapist


GDPR PRIVACY NOTICE FOR CLINICAL WORK


Wendy Smith holds some information about you.  This document outlines how that information is used, who she may share that information with and how it is kept 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 me at wtemplesmith@aol.com.  Wendy Smith keeps her Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.    


What I Do


I provide 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 and seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice. I also provide cookery workshops, educational workshops and seminars and menu planning advice.


How I Obtain Your Personal Data


Information provided by you


You provide me with personal data in the following ways:


This may include the following information:


I use this information in order to provide you with direct healthcare.  This means that the legal basis of my holding your personal data is for legitimate interest.  


Following completion of your healthcare I retain your personal data for the period defined by my professional association BANT and registrant body CNHC.  This enables me to process any complaint you may make.  In this case the legal basis of my holding your personal data is for contract administration.


Information I obtain 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 my 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 I 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 its 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 me 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:


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 on to 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 wish to 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.


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 wish to access your data you must make a subject access request in writing to Wendy Smith at wtemplesmith@aol.com.  Under special circumstances, some information may be withheld.   I will respond within 20 working days from the point of receiving the request and all necessary information from you.  The response will include the details of the personal data I hold on you including:



You have the right, subject to exemptions, to ask to:


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 email Wendy Smith, the Data Controller, at wtemplesmith@aol.com


What safeguards are in place to ensure data that identifies me is secure?


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 I 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 me 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.


I am 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).


How long do you hold confidential information for?


All records held by me will be kept for the duration specified by guidance from my professional association BANT.


Website technical details


I may use electronic forms on my website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy.  I also aim to use secure forms where appropriate.


I currently do not use cookies.  If in future I do make use of cookies these will not be used to collect any private or personally identifiable information, only to aid the proper technical functioning of the website.


Any cookies used would 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.


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 https://tools.google.com/dlpage/gaoptout


Analytics


Like most websites, I may make use of analytics software in order to help me understand the trends in popularity of my website and of different sections.  I will make no use of personally identifiable information in any of the statistical reports generated from this package.  


Complaints


If you have a complaint regarding the use of your personal data then please contact me by  email wtemplesmith@aol.com 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.