Gill Stewart Nutrition will hold some information about you.  This privacy policy confirms how that information will be used and protected.  This privacy policy is regularly reviewed and was last reviewed in September 2021. Should you wish to receive further information, please email info@gillstewartnutrition.co.uk

Information provided by you You may provide information in the following ways:

• By completing a nutritional therapy questionnaire;

• By signing a terms of engagement form;

• During a nutritional therapy consultation;

• Through email, the telephone or by post; and

• By taking online or card payment.

What data is collected the following information may be collected:

• basic details such as name, address, date of birth and next of kin;

• health information including previous medical history, dietary, lifestyle, supplement and medicine details;

• clinic notes and health improvement plans;

• GP contact information; and 

• bank details.

This information is used to provide you with direct healthcare.  This means that the legal basis of our holding of personal data is legitimate. Following completion of your healthcare, your personal data will be retained for a period defined by our professional association (BANT - the British Association for Nutrition and Lifestyle Medicine) and registrant body (CNHC, Complementary and Natural Healthcare Council).  This enables us to process any complaint you may make.  In this case, the legal basis for holding your personal data is for contract administration. ​

Information obtained from other sources Sensitive medical information may be obtained from test results from biochemical testing companies. This information will be used to provide you with direct healthcare.  This means that the legal basis for holding your personal data is for legitimate interest. Sensitive information may be also be obtained from other healthcare providers.  The provision of this information is subject to you giving your express consent.  If this consent is not received from you, the Nutritional Therapist will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided may be less effective.

Use of your personal data  The nutritional therapist acts as data controller for use of your personal data to provide direct healthcare. The nutritional therapist also acts as controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers. The nutritional therapist acts as data controller and processor in regard to the processing of credit card and online payments. The nutritional therapist undertakes at all times to protect your personal data, including any health and contact details, in a manner which is consistent with the duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  The nutritional therapist will also take reasonable security measures to protect the storage of your personal data.  The nutritional therapist may use your personal data when there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime, or where there is a legal requirement such as formal court order.  The nutritional therapist may use your data for marketing purposes but this would be subject to you giving your express consent. 

Do you share my information with other organisations? We will keep information about you confidential at all times.  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 or advisers that provide a service to us or act as our agents on the understanding they keep the information confidential;

• anyone to whom we may transfer our rights and duties under any agreement we have with you, provided you have consented to this; and

• any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. BANT) 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 personal data with your GP or other healthcare provider. However, if we believe your life is in danger, we may pass your information onto such appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in the 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 purposes of professional development.  This may be at clinical supervision meetings, conferences, online forums or through publishing in medical journals, trade magazines or online professional sites.  We 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 and will not be charged a fee.  If you want to access your data you must make a subject access request to info@gillstewartnutrition.co.uk.  Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and necessary information from you. The response will include the details of the personal data held including:

• sources from which the information was acquired;

• the purposes of processing the information; and

• persons or entities with whom the information is being shared.​

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 the nutritional therapist to stop processing information about you where the nutritional therapist is not required to do so by law or in accordance with the BANT or CNHC guidelines;

• receive a copy of your personal data which you have provided to the nutritional therapist, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from the nutritional therapist; and

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

The nutritional therapist does not carry out any automated processing which may lead to automated decision based on your personal data.​

If you would like to invoke an of the above rights, please email the Data Controller at gill@gillstewartnutrition.com

What safeguards are in place to ensure that data that identifies me is secure? The nutritional therapist only uses information that may identify you in accordance with GDPR. This requires her 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, the nutritional therapist also has to follow the common law duty of confidence meaning 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.  The nutritional therapist 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. The nutritional therapist will also ensure that the information 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).  The nutritional therapist ensures external data processors that support her 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.   Gill Stewart Nutrition 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) 

How long do you hold information for? All records held by the nutritional therapist will be kept for the duration specified by guidance from the professional association, BANT.

Website technical details. The nutritional therapist uses cookies to collect information about how visitors use the website.  The nutritional therapist uses the information 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.  Cookies are not used to collect any private data or personally identifiable information. The cookies used contain random strings of characters alongside minimal information about the state and session of the website, which does not collect personal information about you as a visitor.  Advanced areas of the site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information.  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.

Complaints. If you have a complaint about the use of your personal data, please contact the Data Controller at info@gillstewartnutrition.co.uk. 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 1231112. 

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