My practice will hold some information about you. This document outlines how that information is used, who I may share that information with and how I keep it 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 moniquemstone@gmail.com. I keep this Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.

1 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 cause of your health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.

2 How I Obtain Your Personal Data

Information provided by you

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, telephone or post

– By taking 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 previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans

– GP contact information

– Bank details

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 will 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 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 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 that the healthcare provided by me may be less effective.

3 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 cards 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 my 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.

4 Do I Share Your 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:

– My registrant body, CNHC, and professional association, BANT, for the processing of a complaint made by you.

– Any contractors and advisors that provide a service to me or act as my agent on the understanding that they keep the information confidential

– Anyone to whom I may transfer my rights and duties under any agreement I have with you

– Any legal or crime prevention agencies and /or to satisfy and 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 direct consent before sharing your information with your GP or other healthcare providers. However, if I believe your life is in danger then I may pass your information onto an appropriate authority (such as 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.

5 What are Your Rights?

Every individual has a 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 me at moniquemstone@gmail.com. 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 purpose of processing the information

– Persons or entities with whom I am 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 BANT 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 me at the following address – 1 Beattock Rise, Muswell Hill, London, N10 3DS, or email moniquemstone@gmail.com.

6 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, 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. 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 will 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 will 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 Commissioners Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the IOC website.

7 How Long Do You Hold Confidential Information For?

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

Cookie Name	Purpose
Eg., Accept cookies	Eg., This is used to store whether you have agreed to receive cookies.  Persistent for 1 year
Eg., Google analytics, utma, utmb,utmc,utmz	Eg.,These cookies are used to collect information about how visitors used the site.  The information is used to compile reports and to help 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.

STRICTLY NECESSARY COOKIES

WordPress (the software used to power this website) sets the following cookies in your browser, if you have logged into the website dashboard:

Cookie Name	Description	Session
wordpress_	WordPress cookie for a logged in user.	Session
wordpress_logged_in	WordPress cookie for a logged in user.	Session
wordpress_test_cookie	WordPress test cookie.	Session
wp-settings-time-	WordPress also sets a few wp-settings-{time}-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface and possibly also the main site interface.	1 Year
wp-settings-	WordPress also sets a few wp-settings-[UID] cookies. The number on the end is your individual user ID from the users database table. This is used to customize your view of admin interface and possibly also the main site interface.	1 Year
PHPSESSID	To identify your unique session on the website.	Session

 

Cookies are small. I 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 website may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also my 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

9 Analytics

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

10 Complaints

If you have a complaint regarding the use of your personal data then please contact me by writing to me at 1 Beattock Rise, London N10 3DS, or emailing moniquemstone@gmail.com and I will do my best to assist you.

If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office you can contact them on 01625 545745 or 0303 1231113.

Data Protection Policy

1 Introduction

1.1 Purpose of Policy

1.2 I need to gather and use certain information about individuals.

These can include clients, suppliers, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.

1.3 Policy Statement

I am committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.

I am committed to:

• comply with both the law and good practice
• respect individuals’ rights
• be open and honest with individuals whose data is held
• Register my details with the Information Commissioner’s Office (ICO)

1.4 Personal Data

I may hold data for the following purposes:

• Provision of direct healthcare
• Marketing and newsletters
• Case histories

Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.

I may hold special category data for the following purposes:

• Provision of direct healthcare

1.5 Data Protection Principles

There are six data protection principles that are core to the General Data Protection Regulation. I will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:

1) Lawful, fair and transparent

Data collection must be fair, for a legal purpose and I must be open and transparent as to how the data will be used.

2) Limited for its purpose

Data can only be collected for a specific purpose.

3) Data minimisation

Any data collected must be necessary and not excessive for its purpose.

4) Accurate

The data I hold must be accurate and kept up to date.

5) Retention

I cannot store data longer than necessary.

6) Integrity and confidentiality

The data I hold must be kept safe and secure.

1.6 Key risks

The main risks are in two key areas:

• information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
• individuals being harmed through data being inaccurate or insufficient

2. Responsibilities

I am the data controller for all personal data held by me and am responsible for:

• Analysing and documenting the type of personal data I hold
• Checking procedures to ensure they cover all the rights of the individual
• Identifying the lawful basis for processing data
• Ensuring consent procedures are lawful
• Implementing and reviewing procedures to detect, report and investigate personal data breaches
• Storing data in safe and secure ways
• Assessing the risk that could be posed to individual rights and freedoms should data be compromised

3 Data Recording, Security and Storage

3.1 Data accuracy and relevance

I will ensure that any personal data I process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. I will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

3.2 Data security

I will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on my behalf, I will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

3.3 Storing data securely

• In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
• Printed data will be shredded when it is no longer needed
• Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords.
• Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
• Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
• Data will be regularly backed up.
• All servers containing sensitive data must be protected by security software
• All possible technical measures will be put in place to keep data secure

3.4 Data retention

I will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of my professional association, BANT.

4 Accountability and Transparency

I will ensure accountability and transparency in all our use of personal data. I will keep written up-to-date records of all the data processing activities that I do and ensure that they comply with each of the GDPR principles.

I will regularly review my data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

5 Consent

I will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. I will seek explicit consent wherever possible.

I will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. For online consent, I may use a cryptographic hash function to support data integrity. Alternatively I will maintain the consents information in a spreadsheet with links to the consent forms.

I will regularly review consents and seek to refresh them regularly or if anything changes.

6 Direct Marketing

I will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which I can market people and other organisations by phone, text, email or other electronic means.

I will seek explicit consent for direct marketing. I will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

7 Subject Access Requests

7.1 What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

7.2 How to deal with subject access requests

I will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. I will endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 4.3).

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.

I can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, I can request the individual specify the information they are requesting.

Once a subject access request has been made, I will not change or amend any of the data that has been requested. Doing so is a criminal offence.

7.3 Data portability requests

I will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. I must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.

8 Transferring data internationally

There are restrictions on international transfers of personal data. I will not transfer personal data abroad without express consent.

9 Third Parties

9.1 Using third party controllers and processors

As a data controller and/or data processor, I will have written contracts in place with any third-party data controllers (and/or) data processors that I use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.

As a data controller, I will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.

As a data processor, I will only act on the documented instructions of a controller. I acknowledge my responsibilities as a data processor under GDPR and will protect and respect the rights of data subjects.

9.2 Contracts

My contracts will comply with the standards set out by the ICO and, where possible, follow standard contractual clauses. My contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.

10 Reporting breaches

Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach.

I have a legal obligation to report any data breaches to UK Supervisory authority which is the Information Commissioners Office within 72 hours.