GDPR PRIVACY NOTICE
This document outlines how personal information is used and safeguarded in accordance with the General Data Protection Regulation (GDPR) to avoid unlawful processing and storing of personal information. Cristina Ronchi keeps her Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.
What We Do
Cristina Ronchi provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. She focuses 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, she aims to understand the underlying causes of your health issues which she will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.
She also provides health and cookery educational seminars for private clients and companies.
2. How personal data are obtained:
You provide Cristina Ronchi 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 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
Cristina Ronchi uses this information in order to provide you with direct healthcare. This means that the legal basis of holding your personal data is for legitimate interest.
Following completion of your healthcare your personal data are retained for the period defined by the professional association BANT. This enables Cristina Ronchi to process any complaint you may make.
Information from other sources
Cristina Ronchi may obtain sensitive medical information in the form of test results from biochemical testing companies. This information is used in order to provide you with direct healthcare. This means that the legal basis of 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 Cristina Ronchi do not receive this consent from you, she will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by her may be less effective.
3. Use of personal data
Cristina Ronchi acts as a data controller for use of your personal data to provide direct healthcare. She 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. She acts as a data controller and processor in regard to the processing of credit card and online payments.
She undertakes at all times to protect your personal data, including any health and contact details, in a manner which is consistent with her duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. She will also take reasonable security measures to protect your personal data storage.
She may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
4. Sharing information about other organisations
Cristina Ronchi will keep information about you confidential. She will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
- Her professional association, BANT, for the processing of a complaint made by you.
Any contractors and advisors that provide a service to her or act as her agents on the understanding that they keep the information confidential
Anyone to whom she may transfer her rights and duties under any agreement she has with you
She may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. She will not include any sensitive information
She will seek your express consent before sharing your information with your GP or other healthcare providers. However if she 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.
She 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. She will seek your explicit consent before processing your data in this way.
5. 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 email@example.com. Under special circumstances, some information may be withheld. She shall respond within 20 working days from the point of receiving the request and all necessary information from you. Her response will include the details of the personal data she holds on you including:
Sources from which she acquired the information
The purposes of processing the information
Persons or entities with whom she is 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 her to stop processing information about you where she is not 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 been provided to her, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from her.
Object at any time to the processing of personal data concerning you
She 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 email firstname.lastname@example.org.
6. What safeguards are in place to ensure data that identifies me is secure?
Cristina Ronchi 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, she 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. She 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.
She also ensures 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). She 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.
Cristina Ronchi 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).
7. How long do you hold confidential information for?
All records held by Cristina Ronchi will be kept for the duration specified by guidance from our professional association BANT.
8. Website technical details
Cristina Ronchi uses electronic forms on her 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.
Eg, This is used to store whether you have agreed to receive cookies. Persistent for one year.
Google Analytics _utma
Eg, 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.
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
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Cristina Ronchi
1 Kingswood Court Marchmont Road Richmond TW10 6EU or email email@example.com.
IfIf you do not get a response within 30 days you can make a complaint to the British Association of Nutritional Therapists on 08706061284.