information
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 info@deborahgingellnutrition.co.uk. We keep our Privacy
Notice under regular review.
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What we do
Deborah Gingell Nutrition: provides nutritional therapy services to clients to improve their health
through diet and lifestyle interventions. We focus 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, we aim to understand the underlying causes of your health issues
which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements)
and lifestyle advice. We also provide group coaching and workshops.
How we obtain your personal data
Information provided by you
You provide us 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
By downloading a free resource, such as an e book.
This may include the following information:
Basic details such as name, address, email address, phone number, other contact details and next of kin
Details of contact we have had 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
We use this information in order to provide you with direct healthcare. This means that the legal basis of
our holding your personal data is for legitimate interest.
Following completion of your healthcare we retain your personal data for the period defined by our professional
association. This enables us to process any complaint you may make. In this case the legal basis of
our holding your 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 you with direct healthcare. This means that the legal basis
of our holding your personal data is for legitimate interest.
We may obtain sensitive information from other healthcare providers. The provision of this information is
subject to you giving us your express consent. If we do not receive this consent from you, we will not be
able to coordinate your healthcare with that provided by other providers which means the healthcare provided
by us may be less effective.
How we use your personal data
We act as a data controller for use of your personal data to provide direct healthcare. We also act as a controller
and processor regarding the processing of your data from third parties such as testing companies and
other healthcare providers. We act as a data controller and processor regarding the processing of credit card
and online payments.
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We always undertake to protect your 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 General Data Protection
Regulation (GDPR) concerning data protection. We will also take reasonable security measures to
protect your personal data storage.
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We 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. Also, where there is a legal requirement such
as a formal court order. We may use your data for marketing purposes such as newsletters, but this would be
subject to you giving us your express consent.
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Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with other third
parties with your express consent except for 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
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Anyone to whom we may transfer our rights and duties under any agreement we have with you
Any legal or crime prevention agencies and/or to satisfy any regulatory request
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 information with your GP or other healthcare providers.
However, if we believe that your life is in danger then we 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.
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We may share your 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 your explicit consent before
processing your data in this way.
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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 info@deborahgingellnutrition.
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 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
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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 NNA 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 info@deborahgingellnutrition.
co.uk
What safeguards are in place to ensure data that identifies me, is secure?
We only use information that may identify you in accordance with GDPR. 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 you has been given in confidence, it should be treated as confidential
and only shared for the purpose of providing direct healthcare. We 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.
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.
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Deborah Gingell 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).
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How long do you hold confidential information?
All records held by Deborah Gingell Nutrition will be kept for the duration specified by guidance from our
professional association NNA.
Website technical details
a. Forms
We do use electronic forms on our website making use of an available ‘forms module’ which has several
built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
In compliance with EU legislation, the following table lists the use of cookies on this web site:
Accept Cookies: this is used to store whether you have agreed to receive cookies. Persistent for one year.
Google Analytics: these cookies are used to collect information about how visitors use our site. We use the
information to compile reports and to help us 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. We do 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 http://tools.google.com/dlpage/gaoptout
Analytics
Like most websites, we make use of analytics software in order to help us understand the trends in popularity
of our website and of different sections. We make no use of personally identifiable information in any of
the statistical reports we use from this package. We use 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, then please contact us by writing to the
Data Controller by email at Deborah Gingell Nutrition and 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)