Privacy Notice

Caroline Sheldon (the Nutritional Therapist) holds some information about you. This document outlines how that information is used, who that information may be shared with and how that information is kept secure. This notice does not provide exhaustive detail. If any further information is needed, please contact hello@midlifemanagement.com. This Privacy Notice is kept under regular review and was last reviewed in September 2020.

Nutritional Therapy

The Nutritional Therapist provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions.  The focus is on preventative healthcare, the optimisation of physical and mental health and chronic health conditions.  Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, the Nutritional Therapist aims to understand the underlying causes of your health issues which may be addressed through personalised dietary therapy, supplements and lifestyle advice.

Obtaining Personal Data

Information provided by you

You provide the Nutritional Therapist with personal data in the following ways:

  • By completing a nutritional therapy questionnaire,

  • By signing a terms of engagement form,

  • During a nutritional therapy consultation,

  • Through email, over the telephone or by post,

  • By taking 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 you such as referrals and appointment requests,

  • health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans,

  • GP contact information,

  • bank details.

This information is used in order to provide you with direct healthcare.  In these circumstances, your personal data is held for a legitimate interest.  

Following completion of your healthcare, the Nutritional Therapist retains your personal data for the period defined by the professional association (BANT) and registrant body (CNHC).  This enables the Nutritional Therapist to process any complaint you may make.  In these circumstances, the legal basis for holding your personal data is for contract administration.

Information from other sources

Sensitive medical information may be obtained in the form of test results from biochemical testing companies.  This information is used in order to provide you with direct healthcare.  In these circumstances, the legal basis for holding your personal data is for legitimate interest.   

Sensitive information may 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 a data controller for use of your personal data to provide direct healthcare.  The Nutritional Therapist also acts as a 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 a 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 your personal data storage.

The Nutritional Therapist 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, or where there is a legal requirement such as a formal court order. The Nutritional Therapist may use your data for marketing purposes such as newsletters but this would be subject to you giving your express consent.

Do you share my information with other organisations?

The Nutritional Therapist will keep information about you confidential.  Information will only be disclosed to other third parties with your express consent with the exception of the following categories of third parties:

  • The registrant body, CNHC, and the professional association, BANT, for the processing of a complaint made by you,

  • Any contractors and advisors that provide a service to the Nutritional Therapist or act as her agent on the understanding that they keep the information confidential,

  • Anyone to whom the Nutritional Therapist may transfer her rights and duties under any agreement with you,

  • Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. from the CNHC) if the Nutritional Therapist has a duty to do so or if the law allows her to do so.

The Nutritional Therapist may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare.  Some biochemical testing companies may be from outside of the European Union. The Nutritional Therapist will not include any sensitive information.  

The Nutritional Therapist will seek your express consent before sharing your information with your GP or other healthcare providers.  However if the Nutritional Therapist believes that your life is in danger then she 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.

The Nutritional Therapist may share your case history in an anonymised form with her 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.  The Nutritional Therapist 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. 

If you want to access your data you must make a subject access request in writing to hello@midlifemanagement.com. Under special circumstances, some information may be withheld.   The Nutritional Therapist shall respond within 20 working days from the point of receiving the request and all necessary information from you.  The response will include the details of the personal data held on you including:

  • Sources from which the information was acquired,

  • The purposes of processing the information,

  • 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 and 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. 

  • 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 any of the above rights then please write to the Data Controller at Midlife Management or email hello@midlifemanagement.com.

What safeguards are in place to ensure 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, 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. 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 held 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. 

Caroline Sheldon 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 confidential information for? 

All records held by the Nutritional Therapist will be kept for the duration specified by guidance from her professional association BANT.

Website technical details

The Nutritional Therapist uses electronic forms via the Swandoola client management system which has a number of built-in features to help ensure privacy and security.

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 small. The Nutritional Therapist 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 you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

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.

Analytics

Like most websites, analytics software is used to help identify the trends in popularity of the website and of different sections. No use is made of personally identifiable information in any of the statistical reports from this package. The Nutritional Therapist uses an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Complaints

If you have a complaint regarding the use of your personal data, please contact the Data Controller at hello@midlifemanagement.com.

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.