Here is the privacy policy for the www.patriciadaly.com site.
I respect your privacy and am committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit use patriciadaly.com (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. This site has been solely developed by myself, Patricia Daly, trading as Nutrition Choices. I strive to maintain the highest standards of decency, fairness and integrity in all operations. Likewise, I am dedicated to protecting my customers’, consumers’ and online visitors’ privacy on my website.
1. Introduction
Patricia Daly, trading as Nutrition Choices, is an experienced and internationally recognized Nutritional Therapist (BA Hons, dipNT, mBANT, rCNHC), specialising in the area of Integrative Cancer Support. This privacy notice is issued on behalf of Nutrition Choices so when we mention “we”, “us” or “our” in this privacy notice, we are referring to Nutrition Choices responsible for processing your data. Nutrition Choices is the controller and responsible for this website.
1.1 Purpose of Policy
Nutrition Choices needs to gather and use certain information about individuals.
These can include clients, suppliers, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.
1.2 Policy Statement
Nutrition Choices is committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.
Nutrition Choices commits to:
- comply with both the law and good practice
- respect individuals’ rights
- be open and honest with individuals whose data is held
- Register our details with the Information Commissioner’s Office (ICO)
1.3 Personal Data
Nutrition Choices may hold data for the following purposes:
- Provision of direct healthcare
- Marketing and newsletters
- Transactional records when purchasing one of our self-published eBooks
- Case histories
Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.
Nutrition Choices may hold special category data for the following purposes:
- Provision of direct healthcare
How we obtain your personal data?
We use different methods to collect data from and about you including:
Information provided by you
You provide us with personal data in the following ways:
- By filling in forms on our website(s), or by corresponding with us by phone, e-mail, live-chat or otherwise;
- By signing up to our Mailing/Waiting List;
- By scheduling an Appointment;
- By signing a terms of engagement form;
- During a Nutritional Therapy Consultation
- By purchasing one of our self-published eBooks
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 you such as referrals and appointment requests;
- health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results and clinic notes;
- GP contact information;
- Payment 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. By providing us with this information, you expressly consent to our use of your sensitive personal information in accordance with this privacy policy.
Mailing List
If you choose to sign up to our Mailing List, we may track what pages you visit on this website as well as any links you open in our emails to you. For transparency, this tracking is disabled by default. You may choose to accept this tracking by clicking on the button ‘Accept’ on the sign-up form. This will place a cookie on your device which will expire after 30 days.
Automated technologies or interactions
When you visit our website(s) we may automatically collect information about your computer, including your IP address, information about your visit, your browsing history, and how you use our website. This information may be combined with other information you provide to us, as described above. Please see ‘Cookies and Analytics‘
1.4 Data Protection Principles
There are six data protection principles that are core to the General Data Protection Regulation. Nutrition Choices will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:
- Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used. - Limited for its purpose
Data can only be collected for a specific purpose. - Data minimisation
Any data collected must be necessary and not excessive for its purpose. - Accurate
The data we hold must be accurate and kept up to date. - Retention
We cannot store data longer than necessary. - Integrity and confidentiality
The data we hold must be kept safe and secure.
1.5 Key risks
The main risks are in two key areas:
- information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
- individuals being harmed through data being inaccurate or insufficient
2. Responsibilities
Nutrition Choices is the data controller for all personal data held by us and is responsible for:
- Analysing and documenting the type of personal data we hold
- Checking procedures to ensure they cover all the rights of the individual
- Identifying the lawful basis for processing data
- Ensuring consent procedures are lawful
- Implementing and reviewing procedures to detect, report and investigate personal data breaches
- Storing data in safe and secure ways
- Assessing the risk that could be posed to individual rights and freedoms should data be compromised
3. Data Recording, Security and Storage
3.1 Data accuracy and relevance
Nutrition Choices will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
3.2 Data security
Nutrition Choices will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
3.3 Storing data securely
- In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
- Printed data will be shredded when it is no longer needed
- Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords.
- Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
- Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
- Servers containing personal data must be kept in a secure location, away from general office space
- Data will be regularly backed up.
- All servers containing sensitive data must be protected by security software
- All possible technical measures will be put in place to keep data secure
3.4 Data retention
Nutrition Choices will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of our professional association, BANT.
4. Accountability and Transparency
Nutrition Choices will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the GDPR principles.
We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.
Mailing List
Every email we send through ActiveCampaign will include an opt out link for any email newsletters.
You can unsubscribe from our Mailing List by contacting us at any time or by clicking on the “Unsubscribe” button in the Newsletter footer.
5. Consent
Nutrition Choices will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.
We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. For online consent, we may use a cryptographic hash function to support data integrity. Alternatively we will maintain the consents information in a spreadsheet with links to the consent forms.
We will regularly review consents and seek to refresh them regularly or if anything changes.
6. Direct Marketing
Nutrition Choices will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can market people and other organisations by phone, text, email or other electronic means.
We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.
7. Subject Access Requests
7.1 What is a subject access request?
An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.
7.2 How to deal with subject access requests
Nutrition Choices will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 4.3).
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.
We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.
Once a subject access request has been made, we will not change or amend any of the data that has been requested. Doing so is a criminal offence.
7.3 Data portability requests
We will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.
8. Transferring data internationally
There are restrictions on international transfers of personal data. We will not transfer personal data abroad without express consent.
Mailing List / Waiting List
When subscribing to our Mailing List / Waiting List, all personal data is processed in the USA by us and our subcontractors and only in connection with the services provided to the Controller.
The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
No automated decision making is made using your personal data.
Booking an Appointment
When booking an appointment through our Online Appointment Scheduler (Green Patch Inc., trading as Practice Better), all personal data is processed in the USA by us and our subcontractors and only in connection with the services provided to the Controller.
The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
No automated decision making is made using your personal data.
Buying self-published eBooks by Patricia Daly
When buying one of our self-published eBooks through E-Junkie, all personal data is processed in the USA by us and our subcontractors and only in connection with the services provided to the Controller.
The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
No automated decision making is made using your personal data.
9. Third Parties
9.1 Using third party controllers and processors
As a data controller and/or data processor, we will have written contracts in place with any third-party data controllers (and/or) data processors that we use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
As a data processor, we will only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.
9.2 Contracts
Our contracts will comply with the standards set out by the ICO and, where possible, follow standard contractual clauses. Our contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
The following are Third Party Suppliers we contract with for processing purposes:
Booking an Appointment
Processors
Green Patch Inc., trading as Practice Better, is the Processor of the personal data we hold and that is provided to us when you book an Appointment with us.
PayPal Inc, is the Processor of the personal data we hold and that is provided to us when you book an Appointment with us.
Buying self-published eBooks by Patricia Daly
Processors
e-Junkie is the Processor of the personal data we hold and that is provided to us when you buy one of our self-published eBooks.
PayPal Inc, is the Processor of the personal data we hold and that is provided to us when you buy one of our self-published eBooks.
Mailing List / Waiting List
Processor
ActiveCampaign is the Processor of the personal data we hold and that is provided to us when you sign up to our Mailing List / Waiting List.
10. Reporting breaches
Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach.
Nutrition Choices has a legal obligation to report any data breaches to UK Supervisory authority which is the Information Commissioners Officer within 72 hours.
Disclaimer
Children’s Online Privacy Protection Act
This website is directed to adults; it is not directed to children under the age of 13. I operate our site in compliance with the Children’s Online Privacy Protection Act, and will not knowingly collect or use personal information from anyone under 13 years of age.
Links to other websites
We may include or offer third party products or services on our website run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
Non-Personal Information
In some cases, I may collect information about you that is not personally identifiable. I use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. The information collected is used solely for internal review and not shared with other organizations for commercial purposes.
Release of Information
If Nutrition Choices is sold, the information I have obtained from you through your voluntary participation in my site may transfer to the new owner as a part of the sale in order that the service being provided to you may continue. In that event, you will receive notice through my website of that change in control and practices, and I will make reasonable efforts to ensure that the purchaser honors any opt-out requests you might make of me.
Updates and Effective Date
If you do not agree to my Privacy Policy as posted here on this website, please do not use this site or any services offered by this site.
I reserve the right to make changes in this privacy policy. If there is a material change in my privacy practices, I will indicate on my site that my privacy practices have changed and provide a link to the new privacy policy. I encourage you to periodically review this policy so that you will know what information I collect and how I use it. Your continued use of the site following these changes means that you are deemed to accept the revised Privacy Policy.
We keep this Policy under regular review. This Policy was last updated on 07 December 2019.
Patricia Daly is an experienced and internationally recognized Nutritional Therapist (BA Hons, dipNT, mBANT, rCNHC). Following her cancer diagnosis, she left her corporate career and started studying nutrition. She is currently pursuing an MSc degree at Middlesex University in the UK. As a Swiss native, she regularly attends training courses in Switzerland/Germany, including at the renowned Tumor Biology Center in Freiburg, Germany.