Privacy policy
Diane McCrystal Nutrition (dianemccrystalnutrition.co.uk) 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. I keep my privacy notice under regular review. This privacy policy was last reviewed December 2024.
I comply with data protection legislation such as the Data Protection Act 1998 and the General Data Protection Regulation which regulates the processing of data and ensures that your data is processed fairly and lawfully, kept securely and only that data necessary for processing is retained.
If a piece of information tells you anything at all about a living person, no matter how small or trivial, assume that it's covered. It doesn't matter what format the data is in - digital or hard copy - it is still likely to be covered by GDPR regulation. This includes: names, email addresses, home addresses, phone numbers, medical history, dietary requirements, age and more.
DianeMcCrystalNutrition 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).
1.What I do
Diane McCrystal Nutrition provides nutritional therapy services to clients to help improve health through diet and lifestyle interventions. 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 advice.
2. How I Obtain Your Personal Data
You provide me with personal data in the following ways:
- By completing a nutritional therapy questionnaire, functional medicine or Biocare adaptive health questionnaire prior and during consultations
- By signing a terms of engagement and consent form
- During a nutritional therapy consultation
- Through email, over the telephone or by post
- By taking credit card and online payment such as paypal.
3. The type of information that is requested includes:
- Basic details such as name, address, contact details and next of kin
- 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 improvement plans
- GP contact information
- Bank details
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 which in this case are to reply to communications, to keep records and to establish, pursue or defend legal claims.
Following completion of your healthcare I retain your personal data for the period defined by our professional association, BANT and registrant body, Complementary and Natural Healthcare Council (CNHC). This enables me to process any complaint you may make.
4. Information I get from other sources
I may obtain sensitive medical information in the form of test results from biochemical testing companies and from other healthcare providers. 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. The provision of this information is subject to you giving me your express consent.
5. How I use your personal data
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 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 act as a data controller and processor in regard to the processing of credit card and online payments.
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.
6. Sharing information with other organisations?
I will keep information about you confidential. I will only disclose your information with other third parties such as biochemical testing companies or peers with your expressed consent with the exception of the following categories of third parties:
· My 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 me or act as my agent on the understanding that they keep the information confidential.
· 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 (eg, BANT, CNHC) if I have a duty to do so or if the law allows me.
· 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 and will seek your consent beforehand.
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 interests.
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 informed consent via a consent form before processing your data in this way.
7. How long do I hold confidential information for?
All records held by DianeMcCrystalNutrition will be kept for the duration specified by guidance from my professional association BANT.
8. 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: diane.mccrystal@icloud.com
Under special circumstances, some information may be withheld. I shall respond within 20 working days from the point of receiving the request and all necessary information from you.
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, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.
You have the right to 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.
If you would like to invoke any of the above rights then please email: diane.mccrystal@icoud.com
You can also contact the Information Commissioner’s Office (ICO) if you are require further assistance www.ico.org.uk
9. What safeguards are in place to ensure data 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 (see above sections).
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. All paper copies are kept in a locked filing cabinet in a locked room. All information stored on computer is identifiable by initials only apart from biochemical testing companies online forms and communication with other health professionals that may require more detail such as date of birth and address. I ensure external data processors 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.
10. Website technical details
I use electronic forms on the 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.
Like most websites,www.dianemccrystalnutrition.co.uk may make use of analytics software in order to help understand the trends in popularity of the website and of different sections. I make no use of personally identifiable information in any of the statistical reports I use from this package.
I may use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.
I use cookies when you visit my website www.dianemccrystalnutrition.co.uk
Cookies are tiny text files stored on your computer that websites can interact with, allowing me to keep track of your website session. These cookies are used to collect information about how visitors use the site. I use the information to compile reports and to help me 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.
By using my website, you agree to me placing these cookies on your device and accessing them when you visit in the future. You can disable cookies using your web browser – see your browser’s ‘help’ section for details of how to do this. Please note that if you do disable cookies, you may impact your browsing experience.
I 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. Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information.
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
11. Complaints
If you have a complaint regarding the use of your personal data
please email: diane.mccrystal@icloud.com and I will do my best to help.
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