©2017 by SAGE Health + Nutrition.

SAGE Health + Nutrition

  

PRIVACY NOTICE


SAGE Health + Nutrition may 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. Any requests for this should be sent to info@sagehealthnutrition.com. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.

What We Do​

SAGE Health + Nutrition provides nutrition and functional medicine 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 and functional medicine 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.

How We Obtain Your Personal Data

Information provided by you


You may provide us with personal data in any of the following ways:

  • By contact us through this website

  • By completing a nutritional and health questionnaire

  • By signing a terms of engagement form

  • During a 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, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans

  • GP contact information

  • Bank details or card 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. 

In accordance with our insurance provider, we hold client records for 8 years from the date of the client’s last contact with us, or when the client is a minor, until their 25th birthday if that is longer. Once a record passes the relevant regulatory time limit, it will be securely destroyed within 1 year. 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 appropriate 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, or professional insurance provider, for the processing of a complaint made by you

  • Any contractors and advisors that provide a service to us (such as biomedical testing companies) 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 if we have a duty to do so or if the law allows us to do so


We may share information about you with supplement companies (i.e., to discuss an appropriate supplement regime) and biochemical testing companies (i.e., to order a test, or to discuss a test result with an expert advisor) 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 always seek your consent before processing your data in this way.

In the case of clients who attend the Amelia Freer clinic in London, your information and management plan (including your nutrition report) will be shared confidentially with Amelia Freer as part of providing you with direct healthcare. 

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 info@sagehealthnutrition.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

  • 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 SAGE Health + Nutrition or email info@sagehealthnutrition.com.

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, and 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).


SAGE Health + Nutrition 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).


Where consultations take place via Skype or other electronic meeting software, you may need to provide your name and email address to the software provider. Please review their privacy policy before doing this.


How long do you hold confidential information for?

All records held by the SAGE Health + Nutrition will be kept for the duration specified by guidance from our professional indemnity body.

In accordance with our insurance provider, we therefore hold client records for 8 years from the date of the client’s last contact with us, or when the client is a minor, until their 25th birthday if that is longer. Once a record passes the relevant regulatory time limit, it will be securely destroyed within 1 year. 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

Website technical details


​Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to inform you of our services and allows you to contact us. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

Wix.com demonstrates its GDPR compliance at: https://support.wix.com/en/article/general-data-protection-regulation-gdpr. For further information on how Wix handles your data, please review sections 8, 12 and 13 of  Wix’s privacy policy: https://www.wix.com/about/privacy.

In line with common practices, we may use website analytics software to track our website impact. Visitor Analytics is a simple website analytics service which measures traffic and website visitors' general details. By collecting these statistics, a website can make their visitors' experience better (e.g. which pages they visit and when, where they are approximately located, where does a user land first or if they are coming from a specific referral).

All this data is pseudonymized and Visitor Analytics will never use the collected data to identify individual users or to match it with additional information on an individual user. For further information on the cookies that Visitor Analytics may use, please click here. Each visitor has control over the cookies placement. Please see below for more information on controlling cookies.

We may also use Wix.com, to deliver our occasional e-newsletters. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. We will ask for consent before sending marketing mail or newsletters.


When people subscribe to our newsletter, they can cancel their subscription at any time by emailing info@sagehealthnutrition.com or replying to a newsletter asking to unsubscribe.

This privacy notice does not cover any links within our site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.


We no longer use electronic forms on our website.  

In compliance with EU legislation, the following lists the use of cookies on this web site:

Name of cookie; Life span; Purpose

svSession; Permanent; Creates activities and BI


Hs; Session; Security


incap_ses_${Proxy-ID}_${Site-ID}; Session; Security

incap_visid_${Proxy-ID}_${Site-ID}; Session; Security


nlbi_{ID}; Persistent cookie; Security

XSRF-TOKEN; Persistent cookie; Security


smSession; Two weeks; Identify logged in site members

In order for some of the website technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, Wix.com uses several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of their services and marketing campaigns, and generally providing and improving their website Services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org 


Please note that deleting cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our website, or may otherwise adversely affect your user experience.

Email


We use standard email software to send and receive emails. If you send personal information to use via email, this may be unencrypted and will be stored in our email system whilst we need access to it. We may monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.


Please note that email correspondence may constitute part of the health records we hold about you.


Contact


If you have a concern or question regarding the use of your personal data then please contact us by emailing info@sagehealthnutrition.com 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 01625 545745 or 0303 1231113.