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Privacy statemen

Introduction

Caroline Seale owner of Discover Nutrition 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.

Caroline Seale is an experienced Nutritional Therapist (BA Hons, dipNT, mNTOI), specialising in the area of digestive health and energy management. This privacy notice is issued on behalf of Discover Nutrition so when we mention “we”, “us” or “our” in this privacy notice, we are referring to Discover Nutrition responsible for processing your data. Discover Nutrition is the controller and responsible for this website.

This is the privacy policy of Caroline Seale, Discover Nutrition and how we collect, process, store and share your data.

This Privacy Policy only relates to personal data collected by Caroline Seale, Discover Nutrition on our website, consultation forms, emails and telephone calls. Any personal data collected by Caroline Seale, Discover Nutrition is used in accordance with EU data protection legislation.

Users should be aware that if they access other websites, using the links provided, these are outside our control. If they provide personal data to other companies, the privacy policies of those companies determine the uses to which that information is put and the Caroline Seale, Discover Nutrition Privacy Policy will no longer apply.

The Data Protection Bill 2018

Caroline Seale, Discover Nutrition complies with the principles of the Data Protection Bill 2018 in accordance with General Data Protection Regulations (GDPR).

Policy Statement

Discover Nutrition is committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.

Discover Nutrition commits to

  • comply with both the law and good practice
  • respect individuals’ rights
  • be open and honest with individuals whose data is held
  • Register our details with the Information Commissioner Office (ICO)

 

Personal Data

Discover Nutrition may hold data for the following purposes:

  • Provision of direct healthcare
  • Marketing and newsletters
  • Case histories

 

How we obtain your personal data?

We use different methods to collect data from and about you including:

 

Information provided by you

You provide us with personal data in the following ways:

  • By filling in forms on our website, or by corresponding with us by phone, e-mail, or otherwise
  • By signing up to our Mailing List
  • By scheduling an Appointment
  • By filling in a nutrition and lifestyle questionnaire
  • By signing a terms of engagement form or contract
  • During a Nutritional Therapy Consultation

 

This may include the following information:

  • basic details such as name, address, contact details, date of birth
  • 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 and clinic notes
  • GP contact information

 

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. By providing us with this information, you expressly consent to our use of your sensitive personal information in accordance with this privacy policy.

Data Protection Principles

There are six data protection principles that are core to the General Data Protection Regulation. Discover Nutrition will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:

Lawful, fair and transparent

Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.

Limited for its purpose

Data can only be collected for a specific purpose.

Data minimisation

Any data collected must be necessary and not excessive for its purpose.

Accurate

The data we hold must be accurate and kept up to date.

Retention

We cannot store data longer than necessary.

Integrity and confidentiality

The data we hold must be kept safe and secure.

 

Key risks

The main risks are in two key areas:

  • information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
  • individuals being harmed through data being inaccurate or insufficient

 

Responsibilities

Discover Nutrition is the data controller for all personal data held by us and is responsible for:

  • Analysing and documenting the type of personal data we hold
  • Checking procedures to ensure they cover all the rights of the individual
  • Identifying the lawful basis for processing data
  • Ensuring consent procedures are lawful
  • Implementing and reviewing procedures to detect, report and investigate personal data breaches
  • Storing data in safe and secure ways
  • Assessing the risk that could be posed to individual rights and freedoms should data be compromised

Data Recording, Security and Storage

Data accuracy and relevance

Discover Nutrition will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Data security

Discover Nutrition will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations

Storing data securely

  • In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
  • Printed data will be shredded when it is no longer needed
  • Data stored on a computer will be protected by strong passwords that are changed regularly.
  • Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
  • Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
  • Servers containing personal data will be kept in a secure location, away from general office space
  • Data will be regularly backed up.
  • All servers containing sensitive data will be protected by security software.
  • All possible technical measures will be put in place to keep data secure

 

Data retention

Discover Nutrition will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of our professional association, NTOI.

 

Accountability and Transparency

Discover Nutrition will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the GDPR principles.

We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

Mailing List

Every email we send through Mailchimp will include an opt out link for any email newsletters.

You can unsubscribe from our Mailing List by contacting us at any time or by clicking on the “Unsubscribe” button in the Newsletter footer.

Consent

Discover Nutrition will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.

We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. For online consent, we may use a cryptographic hash function to support data integrity. Alternatively we will maintain the consents information in a spreadsheet with links to the consent forms.

We will regularly review consents and seek to refresh them regularly or if anything changes.

Direct Marketing

Discover Nutrition will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can market people and other organisations by phone, text, email or other electronic means.

We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.

Subject Access Requests

What is a subject access request?

An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.

How to deal with subject access requests

Discover Nutrition will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats.

If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month

We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.

Once a subject access request has been made, we will not change or amend any of the data that has been requested. Doing so is a criminal offence.

Data portability requests

We will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.

Transferring data internationally

There are restrictions on international transfers of personal data. We will not transfer personal data abroad without express consent.

Mailing List

When subscribing to our Mailing List, all personal data is processed in Ireland by us and our subcontractors and only in connection with the services provided to the Controller.

The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.

No automated decision making is made using your personal data.

Booking an Appointment

When booking an appointment through our Online booking form , all personal data is processed in Ireland by us and our subcontractors and only in connection with the services provided to the Controller.

The Controller and Processor have a Data Protection regime in place to oversee the effective and secure processing of your personal data.

No automated decision making is made using your personal data.

Third Parties

Using third party controllers and processors

As a data controller and/or data processor, we will have written contracts in place with any third-party data controllers (and/or) data processors that we use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.

As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.

As a data processor, we will only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.

Contracts

Our contracts will comply with the standards set out by the ICO and, where possible, follow standard contractual clauses. Our contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.

The following are Third Party Suppliers we contract with for processing purposes:

Mailing List

Mailchimp is the Processor of the personal data we hold and that is provided to us when you sign up to our Mailing List.

Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Links to other websites

We may include or offer third party products or services on our website run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Reporting breaches

Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach.

Discover Nutrition has a legal obligation to report any data breaches to the Information Commissioners Officer within 72 hours.

Cookies

A “cookie” is a small text file that is placed on a user’s computer hard drive by a website. There are several types of cookie and the most common are often referred to as ‘session’ cookies. These are used to keep track of information needed by a user as they travel from page to page within a website. These cookies have a short lifetime and expire within a few minutes of the user leaving the site.

Other types of cookies can be used to track internet activity after the user has left a website. These are usually sponsored by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being used.

Discover Nutrition uses benign, short lived ‘session’ cookies to tell whether a website user has logged in, where to find details that can be used to pre-fill parts of on-line forms and to personalise the user’s visit to the website.

Discover Nutrition cookies do not analyse visits to other website or any searches undertaken whilst on the Discover Nutrition website.

Internet browsers normally accept cookies by default; however, it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third party and long lived cookies.

Disclaimer

NOTICE: The information contained or presented on www.discovernutrition.ie is for educational purposes only. Information on this site is NOT intended to serve as a substitute for diagnosis, treatment, or advice from a qualified, licensed medical professional. The facts presented are offered as information only – not medical advice – and in no way should anyone infer that we or anyone appearing in any content on this website are practicing medicine. Any diet, health, or nutritional program you undertake should be discussed with your doctor or other licensed medical professional. Seek the advice of a medical professional for proper application of ANY material on this site to your specific situation.

In addition, no statement on this website has been evaluated by the Food and Drug Administration, and any product mentioned or described on this website is not intended to diagnose, treat, cure, or prevent any disease. If you purchase anything through a link on this website, you should assume that we have an affiliate relationship with the company providing the product or service that you purchase, and that we will be paid in some way. We recommend that you do your own independent research before purchasing anything.

www.discovernutrition.ie does not control, monitor or guarantee the information contained in external web sites that are linked to from our site and does not endorse any views expressed or products or services offered therein.

Children’s Online Privacy Protection Act

This website is directed to adults; it is not directed to children under the age of 13. We operate our site in compliance with the Children’s Online Privacy Protection Act, and will not knowingly collect or use personal information from anyone under 13 years of age.

Complaints

If you have a complaint regarding the use of your personal data then please contact us by email caroline@discovernutrition.ie 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 Data Protection Commissioner at www.dataprotection.ie

Updates and Effective Date

If you do not agree to my Privacy Policy as posted here on this website, please do not use this site or any services offered by this site.

I reserve the right to make changes in this privacy policy. If there is a material change in my privacy practices, I will indicate on my site that my privacy practices have changed and provide a link to the new privacy policy. I encourage you to periodically review this policy so that you will know what information I collect and how I use it. Your continued use of the site following these changes means that you are deemed to accept the revised Privacy Policy.

We keep this Policy under regular review. This Policy was last updated on 14th June 2018.