CREATED ON 01/05/2018. LAST REVIEWED AND UPDATED ON 23/01/2023.

What I do

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Anna Bentley provides counselling and nutritional therapy to clients, based on their needs and requests. As a fully qualified integrative counsellor I offer clients a safe, confidential space to explore and express their feelings and help them to understand themselves and others better. As a qualified nutritional therapist I offer my clients personalised diet and lifestyle interventions to help them achieve their health goals. I also offer talks and workshops on health and nutrition topics.

Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (GDPR EU/2016/679), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
I am happy to answer any questions you might have about my data protection policy and you can contact me at anna@annabentley.co.uk. I am registered with the Information Commissioner's Office [Registration Number: ZA236753].

How I obtain your personal data

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Information provided by you
 

You provide me with personal data in the following ways:
• By completing a nutritional therapy questionnaire.
• By signing a nutritional therapy terms of engagement form or counselling agreement.
• During a nutritional therapy consultation or counselling session.
• Through email, over the telephone or by post.
• By making online payments.
This may include the following information:
• 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.
• Counselling session notes.
• GP contact information.
• Bank details.

I use this information in order to provide you with appropriate health treatment (counselling and/or nutritional therapy). This means that the legal basis of holding your personal data is for legitimate interest. Following the end of our agreed contract I retain your personal data for the period defined by my professional associations BANT and BACP (i.e. for 6 years from the end of our contact with each other). This enables me to process any complaint you may make. In this case the legal basis of holding your personal data is for contract administration.
Information provided by other sources.

I may obtain sensitive medical information in the form of test results from biochemical testing companies. I use this information in order to provide you with direct healthcare. This means that the legal basis of holding your personal data is for legitimate interest.

How I use your personal data

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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 online payments.
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 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. I may use your data for marketing purposes such as newsletters but this would be subject to you giving me your express consent.

Who I will share your data with

I will keep information about you confidential. I will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
• My registrant body, CNHC and professional association, BANT, for the processing of a nutritional therapy complaint made by you. Or BACP for the processing of a counselling complaint made by you.
• Any contractors and advisors that provide a service to me or acts as my agent on the understanding that they keep the information confidential (e.g. biochemical testing companies, bookkeeper).
• 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, CNHC) if I have a duty to do so or if the law allows me to do so.
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 peers and my clinical supervisor for the purpose of professional development and ethical practice.

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.
You can request 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 the information could be disclosed to.
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, CNHC and BACP guidelines.
• Receive a copy of your personal data in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.
• Object at any time to the processing of personal data concerning you.

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What safeguards are in place to ensure data that identifies me 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.
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. Any paper notes are stored in a locked filing cabinet. Any notes from counselling sessions are stored under a code rather than the client's name and are stored separately from any personal data about the client. Any data that is stored electronically is done so under password-protection.

Website technical details
Forms: 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.
Cookies: Like most websites I use cookies to help the site work more efficiently. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me. 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
Links from my website: My site contains links to and from other websites which are operated by individuals and companies over which I have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use policies. I do not accept any responsibility or liability for these policies. I advise you to check the policies for third party sites before you submit any personal data to the website.

Analytics: Like most websites, I make use of analytics software in order to help me 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 use an analytics package called Google Analytics who provide details of their privacy policy on the Google website. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Complaints

If you have a complaint regarding the use of your personal data then please contact me by writing to anna@annabentley.co.uk and I will do my 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 01625 545745 or 0303 1231113 or go to ico.org.uk/make-a-complaint for more information.

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