Vital Health Nutrition Ltd (VHN) holds some information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to email@example.com. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2019
- What We Do – Applied Nutrition
VHN provides applied nutrition services to clients as part of their wellness programmes. We use BANT Registered Nutritionists to deliver workshops and seminars providing generic advice on preventative healthcare and general tips for the optimisation of physical and mental health.
- What We Do – Nutritional Therapy
As part of a wellness programme VHN may also provide individual nutritional therapy services to the client’s employees to improve their health through diet and lifestyle interventions. Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of an individual’s health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.
- What We Do – Health Checks
As part of a wellness programme VHN offers health checks to the client’s employees that include body composition measurements, blood pressure, cholesterol and blood sugar tests.
- How We Obtain Personal Data
You provide us with personal data in the following ways:
Data collected for Nutritional Therapy purposes may be anonymous if requested, or 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 medicine details, biochemical test results, clinic notes and health improvement plans
- GP contact information
- Bank details
VHN will use this information in order to provide an individual with direct healthcare. This means that the legal basis of our holding their personal data is for legitimate interest.
Following completion of the healthcare we retain the personal data for the period defined by our professional association BANT and registrant body, CHHC. This enables us to process any complaint you may make. In this case the legal basis of our holding the personal data is for contract administration.
- How we use your personal data
VHN acts 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.
VHN undertakes 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.
VHN 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.
- Sharing Your Data
VHN 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
- 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 (eg, CNHC) if we have a duty to do so or if the law allows us to do so
When providing Nutritional Therapy VHN 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 an individual’s express consent before sharing their information with their GP or other healthcare providers. However if we believe that their life is in danger then we may pass the 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 an individual’s 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.
VHN may post photographs or testimonials onto our website or social media sites. These are anonymous and only posted with the express permission of the client.
- 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 firstname.lastname@example.org. 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 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 by email to email@example.com.
VHN will 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.
VHN ensures 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.
Vital Health Nutrition Ltd 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).
All records held by VHN will be kept for the duration specified by guidance from our professional association BANT.
10.Website technical details
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.
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
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at firstname.lastname@example.org 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.