PRIVACY POLICY

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If you are a client of Kirsten Brooks, we will hold 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.

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1. What We Do

 

Kirsten Brooks provides nutritional therapy services to clients to improve their health through nutrition and lifestyle interventions. This includes the optimisation of physical and mental health and managing chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and laboratory testing, we aim to understand the underlying causes of your health issues which we will seek to address

through personalised dietary therapy, supplementation and lifestyle advice.

 

2. How We Obtain Your Personal Data

 

Information provided by you

• You provide us with personal data in the following ways:

• By completing a nutritional therapy questionnaire

• During a nutritional therapy consultation in person or virtually

• Through email, text, over the telephone

• Health information including your previous medical history, dietary, lifestyle,

• Supplement and medicine details, biochemical test results and clinic notes.

 

We use this information in order to provide you with 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 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.

 

Information we get from other sources

 

We may obtain sensitive medical information in the form of test results from lab 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.

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3. How we use your personal data

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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 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.

 

4. 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

• Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential (e.g., sending your contact details to biochemical testing laboratories for the purposes of ordering any tests that you have indicated a wish to undertake

• 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,

educational seminars, lectures and workshops, online forums, and through publishing in

medical journals, trade magazines, books or online professional sites. We will seek your

explicit consent before processing your data in this way.

 

5. 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 by emailing Kirsten.  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. .

• Object at any time to the processing of personal data concerning you

 

6. 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 PCs, laptops and smartphones with password protection (so that

unauthorised users cannot access 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.

 

7. How long do you hold confidential information for?
 

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

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8. Website technical details

We do not use electronic forms on our website.

 

9. Analytics
 

We do not make use of analytics software on our website.

 

10. Complaints
 

If you have a complaint regarding the use of your personal data then please contact us emailing kirsten@eatyourselftohealth.com.
 

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