Alible Nutrition holds some information about clients. This document outlines what that information is, how it is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to firstname.lastname@example.org.
- Nutritional therapy communications with children under 16 years of age will require written consent from an appropriate guardian, who is expected to be present during consultations with the child.
- Where a carer is involved in the healthcare of an adult who does not have the capacity to understand the information provided to, or decisions required by a personalised nutrition (nutritional therapy or nutritional analysis) client, that carer, or person with lasting power of attorney of health and welfare, may act in the best interests of the client. Evidence of their authority will be required.
Alible Nutrition provides nutritional analysis, advice and therapy services to individual clients to optimise their health, through diet and lifestyle interventions. In addition, Alible Nutrition provides 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 through preventative healthcare, and the optimisation of physical and mental health using scientifically-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 talks in line with client requirements. These talks may provide science-based information around healthful eating habits or specific nutrients. Topics and content will vary according to client needs.
How We Obtain Personal Data
Information provided by clients
Clients and prospective clients (hereby included under the term “clients”) provide us with 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 we have had 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.
We use this information in order to provide direct healthcare/nutritional advice based on the service the client requested. This means that the legal basis of our holding personal data is for legitimate interest.
Following completion of the client’s chosen service, we retain personal data 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 us to process any complaint that may be made by the client. In this case the legal basis of our holding 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 biochemical testing companies. We use this information in order to provide clients with direct healthcare. This means that the legal basis of our holding personal data is for legitimate interest.
We may obtain sensitive information from other healthcare providers. The provision of this information is subject to the client giving us their express consent. If we do not receive this consent, we will not be able to coordinate the client’s healthcare with that provided by other providers which means the healthcare provided by us may be less effective.
How we use personal data
We undertake at all times to protect clients’ 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 Data Protection Act 2018. We will also take reasonable security measures to protect personal data storage.
We may use 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.
We do not use client data for marketing purposes such as newsletters or web-based advertising.
Sharing of Information with Other Organisations
Alible Nutrition will keep information about clients confidential and will only disclose their information with other third-parties with the client’s express consent, with the exception of the following categories of third-parties:
- BANT, CNHC or Balens Ltd, for the processing of a complaint
- 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 we may transfer our rights and duties under any agreement we have with the client
- Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so.
We may share client information with biochemical testing companies as part of providing the client’s chosen healthcare service. We will not include any sensitive information.
Third-party software is used for the purpose of diet analysis, personal 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.
We will seek the client’s express consent before sharing their information with their GP or other healthcare providers. However, if we believe that the client’s life is in danger then we may pass their 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 the client’s case history in an anonymised form with our 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. We will seek explicit consent before processing any personal data in this way.
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 email@example.com. 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, which you have provided to us, 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.
We 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 the Data Controller at Alible Nutrition, 36 Welbeck Street, Whitwell, Derbyshire, S80 4TW; or email firstname.lastname@example.org.
Alible Nutrition only uses information that may identify clients in accordance with the Data Protection Act 2018. 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 clients has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We 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.
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 laptops with encryption (which masks data so that unauthorised users cannot see or make sense of 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.
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).
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.
All records held by Alible Nutrition will be kept for the duration specified by guidance from our professional association BANT.
Website Technical Details
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. We also aim to use secure forms 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.
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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 email@example.com 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.