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The following Privacy Policy governs the information collection practices of Gemma Wade Wellness. This document outlines how that information is used, who we may share that information with and how we keep it secure. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in September 2024.
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Gemma Wade is the data controller and is responsible for personal data. If there are any questions regarding this privacy policy please contact us at hello@gemmawade.com
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WHAT WE DO
Gemma Wade Wellness provides nutritional therapy services to support clients improve their physical and mental health and well-being using personalised diet, lifestyle and coaching interventions. Through nutritional therapy consultations, dietary and lifestyle analysis, functional testing and coaching sessions we aim to identify factors that may be negatively contributing to your physical and mental well-being and then seek to address them through dietary recommendations, nutraceutical prescription (supplements), lifestyle advice and coaching tools to apply in your everyday life. We also carry out specialised online and in-person workshops and educational seminars as well as nutritional programmes throughout the year.
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HOW WE OBTAIN YOUR PERSONAL DATA
There are a number of ways that we may obtain information about you
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Information provided by you
- Submitting a contact form via the website
- By completing a nutritional therapy health questionnaire
- By signing the terms of engagement form
- During a nutritional therapy consultation
- Through email, over the telephone or by post
- By making a payment over the phone or online
This may include the following information:
- Personal details such as name, address, contact details, date of birth and your next of kin
- Details of contact we have had with you such as referrals, appointment requests or contact requests made by you through the website
- Health information including your previous medical history, dietary, lifestyle, supplement and medicine details, functional test results, clinic notes and health optimisation plans
- Summary of topics discussed during Nutritional Therapy session
- GP contact information
- Bank details
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We use this information to provide you with direct nutritional advice. This means that the legal basis of our holding your personal data is for legitimate interest. Upon completion of your healthcare, we retain your personal data for the period defined by our professional association, The British Association for Nutrition and Lifestyle Medicine (BANT), and registrant body, Complementary and Natural Healthcare Council (CNHC), which, enables us to process any complaint you may make. The legal basis of our holding your personal data is for contract administration.
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Information we get from other sources
We may also obtain sensitive medical information from functional testing companies in the form of test results. We use this information to provide you with direct healthcare. The legal basis of our holding your personal data is for legitimate interest.
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We may also obtain sensitive information from other healthcare providers but only after having received express permission from you to do so or having been provided with this information from you directly. If we do not receive this consent from you then we will not be able to coordinate with your other healthcare provider.
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HOW DO WE USE YOUR PERSONAL DATA
We act as a data controller for the use of your personal data to provide direct healthcare and coaching services. We also act as a controller and processor in regard to the processing of your data from third parties such as testing laboratories and other healthcare providers. We act as a data controller and processor in regard to the processing of credit card and online payments.
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At all times we undertake to protect your personal data in line with our duty of professional confidence and requirements under the General Data Protection Regulation (GDPR) concerning data protection. Reasonable security measures are taken to protect your personal data storage.
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In a situation where there is an overriding public interest, such as to safeguard an individual or to prevent a serious crime, we may use your personal information and provide it to an appropriate authority. This is also true where we have a legal requirement such as an official court order.
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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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We do not sell or trade your personally identifiable information.
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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 except for the following categories of third parties:
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- Our registrant body (CNHC) and our professional association (BANT) for the purpose of processing 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 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 functional testing companies in the course of providing you with healthcare. We will seek your express consent before sharing your information with your GP or other healthcare providers unless 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.
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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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WHAT ARE MY 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 hello@gemmawade.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:
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- 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
If you would like to invoke any of the above rights then please write to the Data Controller at hello@gemmawade.com
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WHAT SAFEGUARDS ARE IN PLACE TO ENSURE MY DATA IS SECURE?
We only use information that may identify you in accordance with GDPR which requires us to only process personal data if there is a legitimate basis for doing so and that any processing must be fair and lawful.
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We ensure that the information we hold is kept in secure locations, access to information is restricted to authorised personnel only, personal and confidential information held on equipment such as laptops is protected with encryption (which masks data so that unauthorised users cannot see or make sense of it).
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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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Gemma Wade Wellness 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 (https://ico.org.uk/ESDWebPages/Searchthen search by business name).
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HOW LONG DO YOU HOLD CONFIDENTIAL INFORMATION FOR?
All records held by Gemma Wade Wellness will be kept for the duration specified by guidance from our professional association BANT.
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WEBSITE TECHNICAL DETAIL
Forms
We may 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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In compliance with EU legislation, the following lists the use of cookies on this website:
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Accept Cookies
This is used to store whether you have agreed to receive cookies. Persistent for one year.
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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.
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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.
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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.
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Most web browsers allow some control of most cookies through the browser settings.
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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
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To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
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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.
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COMPLAINTS
I am committed to protecting your personal information and handling it responsibly. If you have any questions or concerns about how your personal data is processed, please contact me via hello@gemmawade.com, and I will do my best to address and resolve your concerns promptly.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), the UK’s independent authority for upholding information rights, you can contact them on 0303 123 1113. Further information can be found on the ICO website at www.ico.org.uk.