PRIVACY NOTICE FOR KF NUTRITION COACH
KF Nutrition Coach 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 firstname.lastname@example.org. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.
1. What We Do
KF Nutrition Coach provides nutritional therapy 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 and biochemical testing, 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.
Occasionally we will also present health information at workshops and educational seminars.
2. How We Obtain Your Personal Data
Information provided by you
You provide us 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
- At workshops or educational seminars
- When signing up for pour newsletter via our website
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
- Bank details
We use this information (over the phone, email, nutrition questionnaire) 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 signing the Terms of Engagement form, or when we obtain your email and signature at workshops or educational events, the legal basis of holding your data is for contract.
We send out a seasonal newsletter and may ask if you would like to receive this when you attend your first nutrition consultation. You will have the opportunity to consent or decline. If you provide consent, you will have the opportunity to unsubscribe at any time. The legal basis of our holding your personal data is consent.
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.
3. How we use your personal data
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.
Storage of your data on Practice Better Nutrition Portal
We store your personal data on the Practice Better Nutrition Portal where you will have exclusive access on a personal ‘log in’ basis to your Nutrition Protocols and Online Food Diary, as well as access to a private message service to KF Nutrition Coach. Questionnaires, Terms of Engagement and Waivers will also be stored on the Portal.
Practice Better stores data in Canadian and US data centers. Both Canada and US (limited to Privacy Shield certified entities) are acknowledged as countries which provide adequate levels of data protection outside of the EU:
Although Practice Better is a Canadian-based company, we do work with a vendor based in the United States, Amazon Web Services (AWS). Data stored in AWS are primarily housed in Amazon's Canadian data centers, but we do rely on an American location for backup and redundancy purposes in some scenarios.
As per GDPR guidance, data can be stored by US-based entities as long as these entities are certified under the EU/US Privacy Shield.
Although Practice Better cannot directly certify under the Privacy Shield as we are not US-based, we rely on the security, policy, safeguards, and Privacy Shield certification achieved by Amazon to meet our GDPR requirements regarding data storage in the US.
Details on the Amazon Privacy Shield certification can be found here:
More details on AWS GDPR compliance can be found here:
Review our article about the security policies and controls we use to protect your data:
Practice Better have implemented several security mechanisms to keep your personal data safe.
We believe in transparency. The following guide highlights some of the ways Practice Better keeps your data safe and secured.
1. HIPAA and PIPEDA Compliance
We are fully compliant with HIPAA and PIPEDA regulations:
Need Practice Better Approach
Encryption Data is encrypted during transfer and at rest. We also encrypt all backups and log data
Minimum Necessary Access Access controls always default to no access unless overridden manually.
Physical Security Our servers are maintained by an SSAE 16 Type II provider which utilizes industry-leading security tools, and best practices.
Monitoring All network requests, successful and unsuccessful, are logged.
Auditing All log data is encrypted and unified, enabling secure access to full historical network activity records.
Vulnerability Scanning All customer and internal networks are scanned regularly for vulnerabilities.
Backup All customer data is backed up every 24 hours. Thirty (30) days of rolling backups are retained.
A HIPAA BAA is available upon request. Contact us if you have specific concerns about regulations outlined by your governing body.
2. Security in the browser
We do not persist your password in your browser cache. We also use secure cookies with a 30-60 minute lifespan. You will be asked to re-enter your login credentials if your session is idle for the allotted timeout period.
All data sent between your browser and our servers are secured using the industry standard AES-256 bit encryption. Data stored on our servers is also encrypted using AES encryption algorithms.
4. Server & Backups
We store your data on encrypted hard drives on servers in North America.
Data backups are done nightly, so you can rest assured you won't lose sensitive data in the unlikely event of a disaster. Backups are stored for 30 days, after which they are purged from our system.
We provide you with activity logs when your clients view, sign and complete forms and waivers. The logs include your clients' IP address and location. An IP address uniquely identifies a computer or mobile device on the Internet.
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.
4. Do you share my information with other organisations?
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 and biochemical testing 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.
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. 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.
Withdrawing Consent & Opting-out of the Practice Better Nutrition Portal
We can remove your data from the Nutrition Portal at any time when you make a request for us to do so either by email or secure communication within Practice Better (Secure Messaging).
The Portal stores backups of your data for 30 days.
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 Kathleen Farren, Data Controller, KF Nutrition Coach, 15 Trafalgar Road, Twickenham, Middlesex TW2 5EJ. Or email firstname.lastname@example.org.
6. What safeguards are in place to ensure data that identifies me is secure?
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 laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). 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.
KF Nutrition Coach 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 KF Nutrition Coach will be kept for the duration specified by guidance from our professional association BANT.
8. Website technical details
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.
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 Kathleen Farren, KF Nutrition Coach, 15 Trafalgar Road, Twickenham, Middlesex, TW2 5EJ or email email@example.com 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.