Privacy notice

London Nutrition Doctor Ltd is a private physician and nutritionist providing a range of specialist services.

We are committed to being open and transparent about how we collect and use data and to meeting our data protection obligations. This privacy notice sets out how we use and protect any personal information we hold and process about you. In this document where we refer to the Regulations we refer to the General Data Protection Regulation 2018, and the Data Protection Act 2018 unless otherwise specified.

Data protection principles

All personal data obtained and held by us must be processed in accordance with a set of core principles set out in legislation, as follows:

·       processing must be fair, lawful and transparent;

·       data must be collected for specific, explicit, and legitimate purposes;

·       data collected must be adequate, relevant and limited to what is necessary for the purposes of processing;

·       data must be kept accurate and up-to-date. Data which is found to be inaccurate will be rectified or erased without delay;

·       data must not be kept for longer than is necessary for its given purpose;

·       data must be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures;

Personal data

In providing you with our services, we may process your personal data. Personal data is information about you from which you can be identified, such as your name, date of birth and contact details. We also may process ‘special category data’ such as health data.

How do we protect and safeguard your data?

We take the security of your data very seriously. We will only use information collected lawfully in accordance with the General Data Protection Regulation (GDPR) 2018, Data Protection Act 2018, Common Law Dutyof Confidentiality and NHS- Code of Confidentiality. Our internal policies and controls are designed by default to ensure that your personal data is not accidentally destroyed, misused, disclosed or lost and is not accessed except by our employees or contractors in the performance of their duties.
Where we engage third parties to process personal data on our behalf, they do so under written instructions, a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we keep your data?

We only keep your data for as long as is necessary and in accordance with legislation and medical and industry guidelines.

Your rights and how to exercise them

As a data subject, you have a number of rights and freedoms. You can:

·       obtain confirmation as to whether your personal data is being processed and where that is the case, gain access to the personal data;

·       require London Nutrition Doctor to rectify incorrect or incomplete data;

·       require London Nutrition Doctor to erase or stop processing your data, for example where the data is no longer necessary for the purposes of processing;however pleasenote that we are required by law to retain certain medical data

·       object to the processing of your data where London Nutrition Doctor is relying on its legitimate interests as the legal ground for processing.

·       move, copy or transfer your personal data from one IT environment to another, securely and without affecting its usability.

If you would like to exercise any of these rights, please contact us at the address at the bottom of this document. We will ask you to provide documentation to confirm your identity or, if you are acting on behalf of another individual, we will ask you for proof of their consent or your legal right to receive their personal information.

If you believe that London Nutrition Doctor has not complied with your rights and freedoms you can make a complaint. Please see the contact details in this document.

Changes to our processing arrangements

Should we need to change the way we collect, store or process your data we will contact you to let you know.

We have provided the rest of the information in a layered format to ensure it remains clear and concise. Please see the sub-headings below and select the heading that best describes you:

 

Visitors to our website

What personal data do we collect?

When you use our website we may collect the following personal data:

·       your name, email address and telephone number;

·       the internet protocol (IP) address of the device you are using, the browser software you use, your operating system, the date and time of access and information on how you use our website;

·       information you give to London Nutrition Doctor when responding to online surveys for research purposes or via our contact form

We may also collect technical data via Google Analytics, however these reports do not contain any personal data.

How do we collect your data?

We may collect this information in a variety of ways. For example, we might collect data when:

·       you email us or complete our ‘contact us’ form;

·       you fill in your details to register as a customer, book an appointment, or book an event

·       you subscribe to email notifications and/or newsletters;

·       you complete an online survey.

Why do we process your personal data?

We may process your personal data for any of the following reasons:

·       to enable us to contact you in response to a query or request for information;

·       to register you for email notifications and/or newsletters that you have subscribed to;

·       to book you onto an appointment/meeting, event and/or webinar;

·       to collect your opinions as part of any research we may carry out;

What is the lawful basis for processing?

We may process your data on the grounds of contractual or legitimate interests – if we need to respond to your enquiry or enter into a ‘contract’ of services with you, or book you onto an event we are hosting. If you have subscribed to our email notifications or newsletter we are relying on your consent to process your personal data. You can withdraw this consent at any time.  

Who do we share your data with?

Your data may be shared internally within London Nutrition Doctor and our employees and contractors may view your data as part of their job role.

We share your data with Function 365, the provider of our online portal. We ensure that they apply the same level of security as we do in order to protect your data. Function 365 only store data in the U.K.

We also use Google G Suite – Google are registered with Privacy Shield

We do not share your personal information with any third-party organisations to use for their own purposes, except:

·       when we have your permission;

·       to comply with a legal obligation or to perform a public task;  

·       if we are under a duty to disclose or share personal data in order to enforce or apply our terms of use (of our website or any part of it) or terms and conditions of supply of any relevant products or services and other agreements;

·       to protect the rights, property, or safety of ourselves, our customers, or others;

·       in order to detect, prevent and help with the prosecution of financial crime;

·       if there are other exceptional circumstances, and we are unable, or it is not appropriate to seek your permission;

·       to archive for statistical or research purposes or in the public interest;

·       in the reason of public interest.

Third party websites

Our website may from time to time include hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

We cannot ensure the security of your data when it is being transmitted to our website or other digital sites from other pages. All transmission of personal information and other data is done at your own risk.

Cookies

What is a cookie?

A cookie, also known as a browser cookie, is a text file containing small amounts of information which a server may download to your computer hard drive, tablet or mobile device when you visit a website or use an app.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies may be either ‘persistent’ cookies or ‘session’ cookies. A persistent cookie will be stored on the web browser and will remain valid until its set expiry date, unless detected by the user before the expiry date. A session cookie, on the other hand, will expire at the end of the user session when the web browser is closed.

First-party and third-party cookies

Cookies can be set and controlled by the operator of the website which the user is browsing (known as a ‘first-party cookie’) or a third party such as Facebook, for example to display advertisements and social sharing features (known as a ‘third-party cookie’).

Cookies used by us

The only cookies in use on our website are for Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.

Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our website. We then use the information to compile reports to help us improve our website.

Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the website before and what site referred the visitor to the web page.

Google Analytics collects information anonymously. It reports website trends without identifying individual visitors.

How can you control the use of cookies?

You can opt out of Google Analytics without affecting how you visit our website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.

Sharing of data from cookies

We may disclose data collected from third party cookies, such as visitor trends, to third parties, in an anonymous form, for research and statistical purposes, and to help us optimise our websites.

Learn more about cookies

To find out more about cookies in general either search in Google or visit aboutcookies.org or allaboutcookies.org.

A guide to behavioural advertising and online privacy has been produced by the internet advertising industry which can be found at www.youronlinechoices.eu. The guide contains an explanation of the Internet Advertising Bureau's self-regulatory scheme to allow you greater control of the advertising you see.

 

People who use our Private GP Medical Services

What personal details do we collect?

Details about you include for example,

-       details such as name, address, next of kin and contact details;

-       billing address if different;

-       payment card/bank details;

-       details of contact we have had with you during the booking process for appointments;

-       details of services you have received;

-       written summaries of calls we receive or make;

-       email communications we receive or make;

-       information about complaints and incidents;

-       appointments, consultations, visits, emailetc.;

-       notes/reports about yourhealth;

-       details of investigations, such as laboratory tests, x-rays, scansetc.;

-       relevant information from other health professionals, relatives,carers

 

Under the Regulations certain information such as health data is known as special category data as it is of a more sensitive nature, and the processing of such data requires us to provide you with details of our lawful bases under both Article 6 and Article 9 of the GDPR 2018, as supplemented by Schedule 1 Part 1 of the DPA 2018. As a health professional our lawful bases under Article 6 for processing such data are the performance of a contract to provide you with the service, and our legitimate interests which do not in our opinion override your own interests or fundamental rights and freedoms. Under Article 9(2)(h) our lawful basis is the provision of healthcare services.

 

Why we collect information

As a health professional who provides you with care, we are legally required to maintain records about your health, treatment and care. We collect and hold information about you for the sole purpose of providing you with healthcare services. These records can be written and/or in digital form.

 

 

How we use your information

We primarily use your information to enable us to provide you with healthcare services. However, we may also use information to:

-       process payments for services you receive;

-       investigate patient queries and complaints;

-       review the care weprovide through audit;

-       train and educate members ofstaff

 

Data Retention

We manage patient records in line with the Records Management Code of Practice for Health and Social Care 2016, which sets the required standards. Financial data may be required by law to be retained for up to 7 years. Other data will normally only be retained for as long as it is required in order to provide you with our services.

 

Access to your information

You have a right under the Regulations to request access to view or to obtain copies of the information we hold about you. You will need to provide adequate information (full name, address, date of birth, and details of your request) so that we can verify your identity and locate your record. We will respond your request within 30 days unless your request is highly complex or you provide repeated requests, in which case we may take longer. We will not charge for access to your information unless the request is highly complex or you provide repeated requests.

 

Change of details

It is important that you inform us if any of your details such as your name, address or contact information have changed or if any of your details are incorrect in order for this to be amended. You have the responsibility to inform us of any changes so our records are accurate and up to date for you.

 

Email address

If you provide us with your email address, we may use it to contact you about your appointments, your treatment and also about billing and administrative matters. We may also email you a newsletter, any changes to our services, our opening hours of our practice.

We will never use your email for marketing purposes or share your email with third parties. Please let us know if you do not wish to receive email correspondence from us.

 

People who use our Nutritional services

 

What personal details do we collect?

Details about you include for example,

-       details such as name, address and contact details;

-       billing address if different;

-       payment card/bank details;

-       details of contact we have had with you during the booking process for appointments;

-       details of services you have received;

-       written summaries of calls we receive or make;

-       email communications we receive or make;

-       information about complaints and incidents;

-       appointments, consultations, visits, emailetc.;

-       notes/reports about yourhealth;

-       details of investigations, such as laboratory tests

 

Under the Regulations certain information such as health data is known as special category data as it is of a more sensitive nature, and the processing of such data requires us to provide you with details of our lawful bases under both Article 6 and Article 9 of the GDPR 2018, as supplemented by Schedule 1 Part 1 of the DPA 2018. As a nutritionist our lawful bases under Article 6 for processing such data are the performance of a contract to provide you with the service, and our legitimate interests which do not in our opinion override your own interests or fundamental rights and freedoms. Under Article 9(2)(a) our lawful basis is explicit consent.

 

How we use your information

We primarily use your information to enable us to provide you with nutrition services. However, we may also use information to:

-       process payments for services you receive;

-       investigate patient queries and complaints;

-       review the care weprovide through audit;

-       train and educate members ofstaff

 

Data Retention

We manage health data in line with the Records Management Code of Practice for Health and Social Care 2016, which sets the required standards. Financial data may be required by law to be retained for up to 7 years. Other data will normally only be retained for as long as it is required in order to provide you with our services.

 

Access to your information

You have a right under the Regulations to request access to view or to obtain copies of the information we hold about you. You will need to provide adequate information (full name, address, date of birth, and details of your request) so that we can verify your identity and locate your record. We will respond your request within 30 days unless your request is highly complex or you provide repeated requests, in which case we may take longer. We will not charge for access to your information unless the request is highly complex or you provide repeated requests.

 

Change of details

It is important that you inform us if any of your details such as your name, address or contact information have changed or if any of your details are incorrect in order for this to be amended. You have the responsibility to inform us of any changes so our records are accurate and up to date for you.

 

Email address

If you provide us with your email address, we may use it to contact you about your appointments, your treatment and also about billing and administrative matters. We may also email you a newsletter, any changes to our services, our opening hours of our practice.

We will never use your email for marketing purposes or share your email with third parties. Please let us know if you do not wish to receive email correspondence from us.

 

ICO registration

London Nutrition Doctor LTD is registered with the informative Commissioners Office (ICO) as a Data Controller and our registration can viewed online in the public register.

 

Complaints and compliments

If you have concerns or are unhappy about any of our services, or to pass on compliments please contact info@londonnutritiondoctor.comor speak to us directly

 

Further information

For independent advice about data protection, privacy and data-sharing issues, or if you are unhappy with how we handle your information, you can communicate:

 

The information Commissioners Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

www.ico.org.uk