PRIVACY POLICY FOR XANTHE GRACE HEALTH COACH

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Xanthe Grace holds some information about you. 

This document outlines how that 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 xanthegracehealth@gmail.com. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2020.

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1. WHAT WE DO

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Xanthe Grace health coaching 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, 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 may in the future also provide group coaching, workshops and corporate events.

 

2. HOW WE OBTAIN YOUR PERSONAL DATA

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Information provided by you:

You provide us with personal data in the following ways:

–       By completing a health history 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 BANT and registrant body CNHC.  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.

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3. HOW WE USE YOUR PERSONAL DATA

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We act as a data controller for use of your personal data to provide direct healthcare.  We 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.  We act as a data controller and processor in regard to the processing of credit card and online payments.

We 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 General Data Protection Regulation (GDPR) concerning data protection.  We will also take reasonable security measures to protect your personal data storage.

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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4. DO YOU SHARE MY INFORMATION WITH OTHER ORGANISATIONS?

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We will keep information about you confidential.  We 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 association, BANT, for the processing of a complaint made by you

–       Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential

–       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 (eg, CNHC if we have a duty to do so or if the law allows us to do so

We may share your information with supplement 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.

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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5. WHAT ARE YOUR RIGHTS?

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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 xanthegracehealth@gmail.com. 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

–       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 BANT and CNHC 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 xanthegracehealth@gmail.com.

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6. WHAT SAFEGUARDS ARE IN PLACE TO ENSURE DATA THAT IDENTIFIES ME IS SECURE?

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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 IMac and which is password protected. 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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7 HOW LONG DO YOU HOLD CONFIDENTIAL INFORMATION FOR?

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All records held by Xanthe Grace will be kept for the duration specified by guidance from our professional association BANT.

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8. WEBSITE TECHNICAL DETAILS

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a) Forms

We do use electronic forms on our 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.

In compliance with EU legislation, the following table lists the use of cookies on this web site:

AcceptCookies: 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

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9. OUR SOCIAL MEDIA PAGES

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Type of information

• This Website contains links to Xanthe Grace’s social media sites.

• These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.

• Should you visit those social media pages and choose to follow us on Facebook or Instagram, Xanthe Grace may receive personal information from the social media providers, including: Your name (first and last);

– Your email address;

– Your postal address;

– Your telephone number(s);

– IP address;

– Location data;

– Social Media account url;

– Your login details;

– Your date of birth/age;

– Your gender; and/or

– Your general interests.

Purpose of the processing and legal basis for the processing

• If we do receive any personal information about you from these third party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.

• We may use this information to find out more about our digital community so that we can better understand and serve our customers and website visitors (for example, to create bespoke content by analysing general interests).

 

10. OUR APPROACH TO MARKETING

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Type of information

• Our Website does not contain third party advertising.

• We may collect information about you in order to send you our promotional or marketing communications, such as;

–      Your name (first and last);

–      Your email address;

–      Any other personal information that you may provide in a message you submit to us.

• While we do not permit third party advertising (or targeted advertising) on our Website, if you do link to one of our Seven Lemons’ social media platforms you may be subject to targeted marketing via that site.

Purpose of the processing and legal basis for the processing

• Where we  provide you with information about our products, services, offers (such as via our e-newsletters) or if we contact you for market research purposes (such as surveys and feedback requests), we will only use your personal information in this way in accordance with laws relating to marketing directly to individuals, and in the pursuit of our legitimate interest of marketing our business.

• If you have asked to be added to our mailing list, we will provide your details to a third party company called MailChimp that helps us to produce and manage our newsletters.  We provide these communications on the basis that you have asked to receive these.

• If you change your mind, you may opt-out at any time via the unsubscribe feature that appears in our emails or by contacting us at jo@sevenlemons.co.uk

Who is this information shared with?

• We will not share with any third party the personal information that we obtain about you for the purposes of marketing, except for as stated in this policy and only where those third parties have agreed to make no independent or further use of that data and to maintain its confidentiality.

 

11. OUR APPROACH TO OBJECTIONABLE CONTENT

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Type of information

• If you send us objectionable content, or behave in a disruptive manner when using our Website, we may process any personal information that you have submitted to us, including in your personal messages, to respond to and stop such behaviour.

Purpose of the processing and legal basis for the processing

• We will only process personal information in this way for the following legitimate interests:

–      Ensuring that the use of our Website is lawful;

–      Ensuring that users do not disrupt or harass our staff, clients or other Website users; and

–      Enforcing our legal rights and complying with our legal obligations.

Who is this information shared with?

• Where we reasonably believe that you are or may be in breach of the law (i.e the content you share on the Website amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties about the content, such as:

–      Your email or internet provider; or

–      Law enforcement agencies.

• Where we process personal information in this way, we will hold that personal information on our systems for as long as is reasonably necessary to achieve these objectives.

Location: EU

https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

• Google LLC (for Google Drive) (Cloud Storage)

Location: US (EU-US Privacy Shield certified)

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

• We Transfer (Cloud Storage)

Location: EU

https://wetransfer.com/legal/privacy

• Dropbox (storage)

Location: EU

https://www.dropbox.com/en_GB/privacy

• Facebook, Inc. (Social Media Platform)

Location: US (EU-US Privacy Shield certified)

https://www.privacyshield.gov/participant_searc

• Instagram (subsidiary of Facebook, Inc.) (Social Media Platform)

Location: US (EU-US Privacy Shield certified)

See above for Facebook, Inc. EU-US Privacy Shield certification link

• Google LLC (for Google Analytics) (Web Management Tools)

Location: US (EU-US Privacy Shield certified)

See above for Google LLC EU-US Privacy Shield certification link

 

12. COOKIES & ANALYTICS

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Our Website does not use cookies.

Our Website uses website analytics, including Google Analytics, to evaluate and improve our Website, personalise your experience and to offer the best, most accessible service possible to all of our customers.

To find out more about Google Analytics and to learn how to opt out, please visit:

•       How Google uses data when you use our partners’ sites or apps, or

•       https://tools.google.com/dlpage/gaoptout/.

 

13. COMPLAINTS

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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 xanthegracehealth@gmail 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), you can contact them on 01625 545745 or 0303 1231113.

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CHANGES TO THIS POLICY

This privacy policy may be updated from time to time. We will notify you of any changes to our privacy policy by posting the new privacy policy on our Website. You are advised to consult this privacy policy webpage regularly for any changes.

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CONTACT

Questions, comments and requests in relation to this privacy policy are welcome and should be addressed to xanthegracehealth@gmail.com

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