The Natural Health Advisory holds some information about you. This document
outlines how that information is used, who I may share that information with and
how I keep it secure. This notice does not provide exhaustive detail. However, I am
happy to provide any additional information or explanation needed. Any requests
for this should be sent to info@thenaturalhealthadvisory.co.uk. I keep my Privacy Notice
under regular review. This Privacy Notice was last reviewed in November 2024.

What I do
The Natural Health Advisory provides nutritional therapy services to clients to improve
their health through diet and lifestyle interventions. I 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, I aim to understand the underlying causes of
your health issues which I will seek to address through personalised dietary
therapy, nutraceutical prescription (supplements) and lifestyle advice.

How I obtain your personal data

Information is provided 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 I 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

I use this information in order to provide you with direct healthcare. This means
that the legal basis of me holding your personal data is for legitimate interest.

Following completion of your healthcare I retain your personal data for the period
defined by our professional associations Naturopathic Nutrition Association (NNA), General Naturopathic Council (GNC) and registrant body, the Complementary and Natural Healthcare Council (CNHC). This enables me to
process any complaint you may make. In this case the legal basis of me holding
your personal data is for contract administration.

Information I get from other sources

I may obtain sensitive medical information in the form of test results from
biochemical testing companies. I use this information in order to provide you
with direct healthcare. This means that the legal basis of me holding your
personal data is for legitimate interest.

I may obtain sensitive information from other healthcare providers. The provision
of this information is subject to you giving me your express consent. If I do not
receive this consent from you, I will not be able to coordinate your healthcare
with that provided by other providers which means the healthcare provided by I
may be less effective.

How I use your personal data

I act as a data controller for use of your personal data to provide direct healthcare.
I also act as a controller and processor in regard to the processing of your data
from third parties such as testing companies and other healthcare providers. I act
as a data controller and processor in regard to the processing of credit card and
online payments.

I undertake at all times 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 UK General Data Protection Regulation
(UK GDPR) concerning data protection. I will also take reasonable security
measures to protect your personal data storage.

I 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. I may
use your data for marketing purposes such as newsletters but this would be
subject to you giving us your express consent.

Do you share my information with other organisations?

I will keep information about you confidential. I will only disclose your information
with other third parties with your express consent with the exception of the
following categories of third parties:
• Our registrant body, CNHC and our professional associations, NNA & GNC, for the
processing of a complaint made by you
• Any contractors and advisors that provide a service to me or act as my
agents on the understanding that they keep the information confidential
• Anyone to whom I may transfer our rights and duties under any
agreement I have with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory
request (e.g., CNHC) if I have a duty to do so or if the law allows us to do so.

I may share your information with supplement companies and biochemical
testing companies as part of providing you with direct healthcare. I will not
include any sensitive information.

I will seek your express consent before sharing your information with your GP or
other healthcare providers. However, if I believe that your life is in danger then I
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.

I may share your case history in an anonymised form with my 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. I 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 them, 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@thenaturalhealthadvisory.co.uk. Under special circumstances, some
information may be withheld. I shall respond within 20 working days from the
point of receiving the request and all necessary information from you. My
response will include the details of the personal data I hold on you including:
• Sources from which I acquired the information
• The purposes of processing the information
• Persons or entities with whom I am 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 me to stop processing information about you where I am not required
to do so by law or in accordance with the NNA, GNC and CNHC guidelines
• Receive a copy of your personal data, which you have provided to me, in a
structured, commonly used and machine-readable format and have the
right to transmit that data to another controller, without hindrance from
me
• Object at any time to the processing of personal data concerning you
I do not carry out any automated processing, which may lead to automated
decisions based on your personal data. If you would like to invoke any of the above rights then please email info@thenaturalhealthadvisory.co.uk.

What safeguards are in place to ensure data that identifies me is secure?

I only use information that may identify you in accordance with UK GDPR. This
requires me 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, I 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. I 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.

I also ensure the information I 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). I 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.

How long do you hold confidential information for?

All records held by The Natural Health Advisory will be kept for the duration specified
by guidance from our professional association NNA & GNC.
• Site technical details
• Forms
• I use electronic forms on my site making use of an available ‘forms module’
which has a number of built-in features to help ensure privacy. I also aim
to use secure forms where appropriate.

Cookies

I use cookies to collect information about how visitors use my site. I use the
information to compile reports and to help me 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. I do not make use of cookies to collect any private or personally
identifiable information. The technical platform of this site uses cookies solely to
aid the proper technical functioning of the site. The cookies used contain random
strings of characters alongside minimal information about the state and session
of the site – 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 the statement on analytics software below – as analytics
software also uses cookies to function.

Most 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 sites
visit http://tools.google.com/dlpage/gaoptout

Analytics

Like most sites, I make use of analytics software in order to help me understand
the trends in popularity of my site and of different sections. I make no use of
personally identifiable information in any of the statistical reports I use from this
package. I use an analytics package called Google Analytics who provide details
of their privacy policy on the Google site.

Complaints

If you have a complaint regarding the use of your personal data then please
contact me by emailing info@thenaturalhealthadvisory.co.uk and I will do my best to
help you