Anna Winek Nutritional Therapist 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 the
email@example.com I keep my Privacy Notice under regular review.
1. What I Do
Anna Winek Nutritional Therapist 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
2. How I Obtain Your Personal Data
Information provided by you
You provide me 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
This may include the following information:
– basic details such as name, address, contact details
– 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
– GP contact information
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 association BANT and registrant body, 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 me may be less effective.
3. 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 undertake at all times to
protect your personal data, including any health and contact details, in a manner which is
consistent with my duty of professional confidence and the requirements of the General Data
Protection Regulation (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.
4. Do I share your 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
– My professional association, BANT or CNHC, for the processing of a complaint made by you
– Anyone to whom I may transfer my rights and duties under any agreement I
have with you
– Any legal or crime prevention agencies and/or to satisfy any regulatory request, if I have a duty to
do so or if the law allows me 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
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.
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
firstname.lastname@example.org Under special circumstances, some information may be
withheld. 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 BANT 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 decision
based on your personal data.
6. What safeguards are in place to ensure data that identifies me is secure?
I only use information that may identify you in accordance with 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. I ensure external data processors that support me
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.
7. How long do I hold confidential information for?
All records held by the Anna Winek will be kept for the duration specified by guidance
from my professional association BANT.
8. Website technical details
I do use electronic forms on my website 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.
If you have a complaint regarding the use of your personal data then please contact me by
writing to at email@example.com and I will do my best to help you.
Cookies are small files that are stored on your computer’s hard drive that track and save your
interaction and usage of the website. When you visit my website, it may gather information about
your computer to provide statistical information regarding the use of our website. Such information
will not identify you personally. All computers have the ability to decline cookies. This can be done
by activating the setting on your browser that enables you to decline the cookies.
Last updated: 20.07.18