TWJ PRIVACY NOTICE
The Wellnesss Junction 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.
- What We Do
The Wellness Junction 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. Other services also include, workshops, seminars, talks and wellbeing retreats.
- 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
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, genetic information, 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, CNM. 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.
- 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.
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.
- 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, CNM 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 (CNM) 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.
- 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
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 at The Wellness Junction or email firstname.lastname@example.org.
- 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.
The Wellness Junction 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).
- How long do you hold confidential information for?
All records held by The Wellness Junction will be kept for the duration specified by guidance from our professional association BANT.
- 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.
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We may collect information automatically when you visit the Website, using cookies. The cookies allow us to identify your computer and find out details about your last visit. You can choose, below, not to allow cookies. If you do, we can’t guarantee that your experience with the Website will be as good as if you do allow cookies.
The information collected by cookies does not personally identify you; it includes general information about your computer settings, your connection to the Internet e.g. operating system and platform, IP address, your browsing patterns and timings of browsing on the Website and your location.
Most internet browsers accept cookies automatically, but you can change the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. These links explain how you can control cookies via your browser – remember that if you turn off cookies in your browser then these settings apply to all websites not just this one:
Internet Explorer http://support.microsoft.com/kb/278835 (this page links to further information for different versions of IE – the mobile version is at http:/ /www.microsoft.com/windowsphone/en-us/howto/wp7/web/changing-privacy-and-other-browser-settings.aspx).
Safari: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html (or http://support.apple.com/kb/HT1677 for mobile versions)
Firefox: http://support.mozilla.org/en-US/kb/ Enabling%20and%20disabling%20cookies
Blackberries: http://docs.blackberry.com/en/smartphone_users/deliverables/ 32004/Turn_off_cookies_in_the_browser_60_1072866_11.jsp
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Cookies and IP Addresses
When you visit one of our websites, we may send you a cookie. A cookie is a small file placed on your computer for the following purposes:
Cookies help us to recognise you when you come back to our websites and to note the advertisements displayed to you. This helps us to choose adverts that we think are more relevant to you. We may use the services of third party ad servers for this purpose. A third party ad server is a company that specialises in maintaining, serving, tracking and analysing results of online advertising campaigns.
Cookies may be used to compile anonymous statistics about online activity. A third party collects such data on our behalf to measure website performance. Information collected is aggregated for reporting purposes. The use of this service assists us in measuring and improving our websites.
We may also track IP addresses. An IP Address is a number that can identify an Internet Service Provider and country location. It cannot provide personal information.
Cookies cannot be used by themselves to identify you. You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. Please be aware that if you disable cookies, many personalised services on our websites will not work as we intended.
Web Beacons and URL Tracking
As part of our email communications and website analyses, we may use web beacons and track URLs.
Web beacons are electronic files that count users who access a website or page and can also allow us to see if a cookie has been activated. Web beacons on web pages or email communications allow us to see how successful an article may be or that an email message was successfully delivered and read.
Tracked URLs will count the amount of clicks on a web page. This allows us to edit the site according to the popularity of the articles you read.
You can’t decline web beacons, however by preventing cookies being used on your computer, you can prevent web beacons from tracking your activity.
Please be aware that if you disable cookies, many services on our websites will not be available to you, particularly those that contain personalised content as outlined in the section Personalised content.
When you request to have your profile removed from further marketing offers from us, you will be added to a suppression list to ensure your request is complied with. All personal data is processed in line with the requirements of the Data Protection Act 1998 and The Privacy and Electronic Communications (EC Directive) Regulations 2003.
You have a right to ask for a copy of your personal information from The Wellness Junction (for which we charge a small processing fee) and to ask us to correct any inaccuracies in your personal information. To make sure we follow your instructions correctly and to improve our service to you through training of our staff, we may monitor or record telephone calls.
Notification of Changes
How to contact us:
Data Protection Enquiries
The Wellness Junction
General information about data protection may be found at:
Information Commissioner’s website: https://ico.org.uk
Direct Marketing Association: http://www.dma.org.uk
Consumer advice from the DMA: http://www.mydm.co.uk
This copyright policy summarises how users are permitted to use our content.
Our Terms of Engagement set out the detail of what you can and cannot do with our content. This copyright policy summarises how users are permitted to use our content. All of the material published on our website and other platforms is protected by copyright law. Use that is made without our permission may therefore infringe our copyright which can result in personal and corporate liability.
As specified above you may not republish or redistribute full text. You may however republish or redistribute summaries of articles if you comply with the conditions set out below. “Summaries” can be either an “extract” or an “abstract”. By “extract” we mean 30 words copied verbatim from an article which is inserted into a longer original work. By “abstract” we mean a 30 word non-verbatim summary of the news or facts reported in an article which does not form part of a longer work.
These are the conditions you must comply with in order to produce summaries:
you source The Wellness Junction as the author of any article from which you have derived a summary by way of an attribution such as “[journalist name] at The Wellness Junction reported that”, with a hypertext link from the word “The Wellness Junction ” to the original story published on www.thewellnessjunction.com;
in the case of abstracts, you make clear that the abstract has been produced by you by stating “this abstract from “The Wellness Junction was produced by [name]”, with a hypertext link from the word “The Wellness Junction ” to the original story published on www.thewellnessjunction.com;
you ensure that your summaries do not in whole or in part form a Substitute for The Wellness Junction own products and services
you do not use or create summaries that promote or endorse any product or service; and
if The Wellness Junction notifies you that it believes you are creating, republishing or redistributing summaries outside of these parameters, you shall immediately cease doing so and your rights to create summaries shall be regarded as having been withdrawn, unless/until The Wellness Junction reaches an agreement with you regarding your use of The Wellness Junction articles.
Please note that these rights do not extend to content, data or other material published by The Wellness Junction that we licence from third parties which you may not republish or redistribute.
TWJ TERMS OF ENGAGEMENT
The Nutritional Therapy Descriptor
Nutritional Therapy is the application of nutrition science in the promotion of health, peak performance and individual care. Nutritional therapy practitioners use a wide range of tools to assess and identify potential nutritional imbalances and understand how these may contribute to an individual’s symptoms and health concerns. This approach allows them to work with individuals to address nutritional balance and help support the body towards maintaining health. Nutritional therapy is recognised as a complementary medicine and is relevant for individuals with chronic conditions, as well as those looking for support to enhance their health and wellbeing.
Practitioners consider each individual to be unique and recommend personalised nutrition and lifestyle programmes rather than a ‘one size fits all’ approach. Practitioners never recommend nutritional therapy as a replacement for medical advice and always refer any client with ‘red flag’ signs or symptoms to their medical professional. They will also frequently work alongside a medical professional and will communicate with other healthcare professionals involved in the client’s care to explain any nutritional therapy programme that has been provided.
The Nutritional Therapist (NT) requests that the Client notes the following:
- The degree of benefit obtainable from Nutritional Therapy may vary between clients with similar health problems and following a similar Nutritional Therapy programme.
- Nutritional advice will be tailored to support health conditions and/or health concerns identified and agreed between both parties.
- Nutritional therapists are not permitted to diagnose, or claim to treat, medical conditions.
- Nutritional advice is not a substitute for professional medical advice and/or treatment.
- Your Nutritional Therapist may recommend food supplements and/or functional testing as part of your Nutritional Therapy programme and may receive a commission on these products or services.
- Standards of professional practice in Nutritional Therapy are governed by the CNHC Code of Conduct.
- This document only covers the practice of Nutritional Therapy within this consultation, and your practitioner will make it clear if he or she intends to step outside this boundary.
- The Client understands and agrees to the following:
- I am responsible for contacting my GP about any health concerns.
- If I am receiving treatment from my GP, or any other medical provider, I should tell him/her about any nutritional strategy provided by my nutritional therapist. This is necessary because of any possible reaction between medication and the nutritional programme.
- It is important that I tell my nutritional therapist about any medical diagnosis, medication, herbal medicine, or food supplements, I am taking as this may affect the nutritional programme.
- If I am unclear about the agreed nutritional therapy programme/food supplement doses/time period, I should contact my nutritional therapist promptly for clarification.
- I must contact my nutritional therapist should I wish to continue any specified supplement programme for longer than the original agreed period, to avoid any potential adverse reactions.
- Recording consultations using any form of electronic media is not allowed without the written permission of both me and my Nutritional Therapist.
We understand the above and agree that our professional relationship will be based on the content of this document. We declare that all the information we share during this professional relationship is confidential and to the best of our knowledge, true and correct.
A deposit of 25% of the total value is required when booking all consultations. This deposit can be made by card or bank transfer. The balance is payable either by cash, card or bank transfer on the day of the consultation. All card payments will incur an additional 3% charge.
Payment for ‘out of consultation hours’ is due upon agreement of the hours.
We request that you give 48 hours’ notice of cancellation. Less than 48 hours’ notice of cancellation of an appointment will incur a 100% cancellation fee.
The term The Wellness Junction or ‘us’ or ‘we’ refers to the owner of the website whose registered office is The Wellness Junction, UK. The term ‘you’ refers to the user or viewer of our website.
The content of the pages of this website is for your general information and use only. It is subject to change without notice.
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Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
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Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
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