Privacy Notice for Samantha Flower Nutrition and Pilates

If you are a client of Samantha Flower Nutrition and Pilates, we hold 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. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in January 2024.

1. What We Do

Samantha Flower Nutrition and Pilates provides nutritional therapy services to clients to improve their health through nutrition and lifestyle interventions. We focus on preventative healthcare and the optimisation of physical health, specialising in gastrointestinal 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.

Samantha Flower Nutrition and Pilates also writes and delivers nutrition workshops and educational seminars for members of the general public, including clients, and occasionally, for healthcare practitioners. She also teaches Pilates classes both privately and in group sessions.

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 and/or Pilates questionnaire
• By signing a terms of engagement form
• By signing the original ‘new client’ form
• During a nutritional therapy consultation or in a Pilates session
• Through email, text, 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, 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 associations the FNTP and ANP. 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.

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 professional association FNTP and ANP, 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 (e.g., sending your contact details to biochemical testing laboratories for the purposes of ordering any tests that you have indicated a wish to undertake)

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 if we have a duty to do so or if the law allows us to do so.

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 samantha@samanthaflower.co.uk. 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 FNTP and ANP 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 Samantha Flower Nutrition and Pilates: email samantha@samanthaflower.co.uk.

6. What safeguards are in place to ensure the 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 PCs, laptops and smartphones with password protection (so that unauthorised users cannot access 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.

Samantha Flower Nutrition and Pilates 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 Samantha Flower Nutrition and Pilates will be kept for the duration specified by guidance from our professional associations FNTP and ANP.

8. Website technical details

For information on Cookies, click here.

9. Analytics

We do not make use of analytics software on our website.

10. Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Samantha Flower Nutrition and Pilates, email samantha@samanthaflower.co.uk 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: 0303 123 1113.

Changes to this Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Latest update: January 2024.