This policy outlines what information Alible Nutrition holds about clients, how it is used, who that information may be shared with and how it is kept secure. This notice does not provide exhaustive detail. However, additional information or explanation can be requested using the email address nutrition@alible.diet.
Please Note
- Communications with clients under 16 years of age will require written consent from an appropriate guardian, who is expected to be present during one-to-one consultations with the child.
- Carers, or persons with lasting power of attorney of health and welfare, involved in the healthcare of an adult client who does not have the capacity to understand the information provided or any decisions required, may act in the best interests of the client. Evidence of their authority will be required.
This policy is reviewed regularly. This Privacy Policy was last reviewed in May 2024.
About Us
Alible Nutrition provides nutritional therapy and nutrition advice services to clients on a one-to-one basis to help them optimise their health using nutrition and lifestyle. In addition, Alible Nutrition may provide nutritional analysis and advice services to businesses to help them support the health of their staff and students.
Alible Nutrition focuses on supporting long-term help using science-based nutrition and lifestyle recommendations. Through client consultations, dietary and lifestyle analysis and biochemical testing (if appropriate), Alible Nutrition aims to understand clients’ needs and the underlying causes of any health issues, which we will seek to address through development of business client menus or personalised dietary support which may include nutraceutical recommendations (supplements) and lifestyle advice.
Alible Nutrition also provides information through educational nutrition-based talks in line with client requirements. These are based on science-based information around healthful eating habits or specific nutrients. Topics and content will vary according to client needs.
How Data is Obtained
Information Provided By Clients
Clients and prospective clients (hereby included under the term “clients”) provide personal data in the following ways:
- By completing a Health & Lifestyle Questionnaire, and Food Diary, as appropriate
- By signing a terms of engagement form
- During consultations
- Through communications via email, the Alible Nutrition website, telephone or by post
- By making credit card and online payment.
This may include the following information:
- Basic details such as name, address, contact details and next of kin
- Details of contact with clients 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
- Appropriate business information, such as diner numbers and age groups
- GP contact information
- Bank details.
This information is used to provide direct healthcare/nutritional advice based on the service the client requested. This means that the legal basis for holding personal data is legitimate interest.
Following completion of the client’s chosen service, the personal data is retained for the period defined by British Association for Nutrition and Lifestyle Medicine (BANT), our professional association; Complementary & Natural Healthcare Council (CNHC) and insurer (Balens Ltd). This enables any complaint that may be made by the client to be processed. In this case the legal basis for holding personal data is contract administration.
Information From Other Sources
Alible Nutrition may obtain sensitive medical information in the form of test results from biochemical testing companies. This information is used to provide clients with direct healthcare. This means that the legal basis for holding personal data is for legitimate interest.
Sensitive information may be obtained from other healthcare providers. The provision of this information is subject to the client giving their express consent. If this consent is not given, it will not be possible to coordinate the client’s healthcare with that provided by other providers, which means the healthcare provided may be less effective.
How Personal Data is Used
Alible Nutrition acts in the following roles with respect to data management:
- Data controller for use of personal data to provide direct healthcare.
- Data controller and processor in regard to the processing of data from third-parties such as testing companies and other healthcare providers.
- Data controller and processor in regard to the processing of credit card.
- Data controller for online payments – the payments are processed using the third-parties Paypal or Stripe, according to clients’ preferred payment method. Payments made via these methods are subject to that third-party’s privacy policy.
Alible Nutrition undertakes at all times to protect clients’ personal data, including any health and contact details, in a manner which is consistent with a duty of professional confidence and the requirements of the Data Protection Act 2018. Reasonable security measures are taken to protect personal data storage.
A client’s personal data may be used 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.
The time and location (address) of consultations will be made available to one trusted contact of Alible Nutrition. This is a Lone Worker Policy measure in the interests of personal safety. No other client details will be shared as part of this measure.
Alible Nutrition does not use client data for marketing purposes such as newsletters or direct marketing.
Sharing of Information With Other Organisations
Alible Nutrition will only disclose client information to other third-party organisations with the client’s express consent, with the exception of the following categories of third-parties:
- 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 rights and duties under any agreement with the client may be transferred
- Any legal or crime prevention agencies and/or to satisfy any regulatory request if there is a duty to do so, or if the law allows us to do so
- BANT, CNHC or Balens Ltd, for the processing of a complaint.
Client information may be shared with biochemical testing companies as part of providing the client’s chosen healthcare service. This will not include any unnecessary sensitive information.
Specific third-party software is used for the following purposes:
- Diet analysis. Data included will be limited according to need and anonymised as appropriate, for example by using a reference in place of the client’s name, and a false date of birth.
- Digital contractual signatures. This information consists of the client’s given email address, name and the signature. The company used states that they are GDPR compliant.
- Online meetings. These meetings are not recorded and the company controlling the software is believed to be GDPR compliant.
- Calendar bookings. Carefully selected online calendars are used to provide a booking system available to potential clients, as well as in-house time management.
- Online payments. The integrated payment service provider used is Stripe. Please refer to their policies regarding their data handling processes: www.stripe.com/gb/privacy and www.stripe.com/payment-terms/legal
Alible Nutrition will seek the client’s express consent before sharing their information with their GP or other healthcare providers. However, if it is believed that the client’s life is in danger then their information may be passed 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.
Anonymised client case history may be shared with 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. Explicit consent from the client will be sought before processing any personal data in this way.
Clients’ Rights
Every client has the right to see, amend, delete or have a copy of data held that can identify them, with some exceptions. Clients do not need to give a reason to see their data.
To access your data you must make a subject access request in writing to nutrition@alible.diet. Under special circumstances, some information may be withheld. Responses shall be provided within 20 working days from the point of receiving the request along with all necessary information from you. The response will include the details of the personal data held about you including:
- Sources from which the information was acquired
- The purposes of processing the information
- Persons or entities with whom the information has been 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 us to stop processing information about you where it is not required by law or in accordance with the BANT and CNHC guidelines.
- Receive a copy of your personal data, which you have provided, 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.
Alible Nutrition does 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 at Alible Nutrition, 36 Welbeck Street, Whitwell, Derbyshire, S80 4TW; or email nutrition@alible.diet.
Data Safeguards
Alible Nutrition only uses information that may identify clients in accordance with the Data Protection Act 2018. This requires that personal data is only processed if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, Alible Nutrition also have to follow the common law duty of confidence. This means that where identifiable information about clients has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. Alible Nutrition will protect client information, inform clients of how that information will be used, and allow them to decide if and how information can be shared.
The information held is kept in secure locations with access restricted to authorised personnel only and personal and confidential information held on protected equipment protected. Alible Nutrition ensures that supporting external data processors 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.
Alible 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).
Email Communications
While precautions are taken to protect clients’ data within our email system, Alible Nutrition accepts no liability in relation to the security of emails outside of this system. Clients who chose to send personal information via this method, do so accepting the associated risks.
Timescales
All records held by Alible Nutrition will be kept for the duration specified by guidance from our professional association BANT.
Marketing Emails
Marketing emails will only be sent to individuals who have subscribed to this service by:
- opting-in to receive a quarterly newsletter and/or occasional business updates via the online subscription form, which employs double opt-in functionality. Subscribers are under no obligation to purchase Alible Nutrition services.
- agreeing to be added to the marketing list as a result of making a purchase. Information within the newsletters is deemed to be helpful to individual’s ongoing nutritional health.
Individuals are able to unsubscribe from these emails at any time.
The newsletter subscription service is operated using a third-party (Mailerlite). MailerLite may process your data using industry standard technologies that help Alible Nutrition to monitor and improve the newsletter, and to manage the subscribed email addresses. MailerLite’s privacy policy can be found at: https://www.mailerlite.com/privacy-policy.
Website Technical Details
Forms
Alible Nutrition uses electronic forms on its website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. Secure forms will be used where appropriate. The whole site is set up to reduce the risk of ‘man-in-the-middle’ attacks thereby further protecting data that is input on to forms.
Cookies
In compliance with legislation, the following table lists the use of cookies on our website (alible.diet)
Cookie | Purpose |
---|---|
cookie-notice-accepted | This is a functional cookie notice for GDPR purposes. It checks if cookies can be placed. |
timezone | Provides timezone. |
roundcube_sessauth | Used for protection against session hijacking – a security mechanism. |
Is-smartpush | Used by the website server to store settings to improve the performance of the website. |
PHPSESSID | This identifies your unique session on the website. |
roundcube_sessid | Stores your unique session id. |
wordpress_test_cookie | This is set up by WordPress to check if the cookies are enabled on the browser to provide appropriate user experience to the users. |
Roundcube_cookies | This cookie is linked to the webmail function on the website. |
Advanced areas of this site may use cookies to store visitors’ presentation preferences in a purely technical fashion with no individually identifiable information. Note also the statement on analytics software below – as analytics software also uses cookies to function. Cookies are small.
Alible Nutrition does 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 visitors.
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
Analytics
Like most websites, alible.diet makes use of analytics software in order to help us understand the trends in popularity of the website and of different sections. Alible Nutrition does not use any personally identifiable information in any of the statistical reports we use from this package (Google Analytics). Google Analytics provide details of their privacy policy on the Google website.
If you have not opted out of Google Analytics tracking, additional cookies related to this will be in operation. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Complaints
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Alible Nutrition, 36 Welbeck Street, Whitwell, Derbyshire, S80 4TW or email nutrition@alible.diet 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.