Privacy

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data at Angelique Panagos Nutrition and through your use of our site www.angeliquepanagos.com, including any information you may provide, via email, over the phone, in person or through our site when you purchase a product or service, make an enquiry, sign up to our newsletter or take part in a prize draw or competition.

Angelique Panagos Ltd trading as Angelique Panagos Nutrition is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy-related matters for us. If you have any questions about this privacy notice or would like further information on how we use and store your personal data, please contact the Data Protection Officer by email at info@angeliquepanagos.com.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). In the event that you do have a complaint, we would be grateful if you would contact us first so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@angeliquepanagos.com/

We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in April 2018.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data – This may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data – This may include your billing address, delivery address, email address and telephone numbers.
• Financial Data – This may include your bank account and payment card details. We are able to process card payments for products and services over the phone using the software Stripe. We will not store your financial or identity data without your explicit consent and will only do so in the event that you would like to have a card saved on file with us. We can only process a payment once we have received explicit consent from you via email for each transaction. Please see more regarding Stripe’s privacy policy: https://stripe.com/gb/privacy
• Transaction Data – This may include details about payments between us and other details of purchases made by you.
• Technical Data – This may include your internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Usage Data – This may include information about how you use our website, products and services.
• Marketing and Communications Data – This may include your preferences in receiving marketing communications from us and our third parties, your communication preferences as well the contact and identity data you have provided when you opted in to receiving such communications. Our newsletters and marketing communication emails are managed and delivered using MailChimp. Please see more regarding their privacy policy: https://mailchimp.com/legal/privacy/

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

• Sensitive Data

As we are a healthcare providing service, we need to collect the following sensitive data about you in order to deliver the services of a Nutritional Therapist such as:

Name, address, information about your health, diet and lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans.

We may obtain sensitive medical information in the form of test results from biochemical testing laboratories. This would only be done with your express consent and is service you would need to purchase from us. 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.

Where we are required to collect personal data by law, or under the terms of the engagement between us and you do not provide us with that data when requested, we may not be able to perform the service (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

Following completion of your healthcare with us, we retain your personal data for the period defined by our professional association BANT and registrant body, CNHC.  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.

3. HOW WE COLLECT YOUR PERSONAL DATA

You provide us with personal data in the following ways:

• By completing a nutritional therapy questionnaire
• By signing a terms of engagement form
• During a nutritional therapy consultation
• Through email, over the telephone or by post
• By providing credit card and online payment details

3.1 People who email us

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 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.

3.2 People who use our services

We offer one-to-one consultations in person at our clinic and via Skype and telephone.

We collect personal, medical and other information to enable us to provide our services. Data is collected, analysed and stored using the client relations management software Penocchio. Please see details of their privacy policy: https://www.penocch.io/privacy/

Our practitioners may make handwritten notes during a consultation, however afterward, these will be securely stored electronically via Penocchio and the hard copies destroyed. Data may also be stored on the hard-drive of computers used by Angelique Panagos Nutrition. These computers are encrypted and password protected and access is only available to staff members of Angelique Panagos Nutrition.

If you come and see one of our therapists in clinic, your identity and contact data will be shared with 58 South Molton Street wellbeing centre and their staff. An appointment booking will be made using their booking system MINDBODY online, which has a privacy shield certification which complies with GDPR regulation related to storing and transferring data. Please see more on 58 South Motlon Street’s privacy policy: https://58southmoltonstreet.co.uk/privacy-policy/

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.

In accordance with our regulator, the Complementary and Natural Healthcare Council (CNHC), we hold patient records for 8 years from the date of the patient’s last visit with us, or where the patient is a child, until their 25th Birthday if that is longer. These records are held in Pennochio and on the hard drive of computers used by Angelique Panagos Nutrition. Once a record passes the relevant regulatory time limit, it will be securely destroyed within 1 year.

4. 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 laboratories 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.

5. 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, CNHC and our professional association, BANT, for the processing of a complaint made by you
• Any legal or crime prevention agencies and/or to satisfy any regulatory if we have a duty to do so or if the law allows us to do so
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We may share your identity and contact data with third-party biochemical testing laboratories in order for you to complete the testing, in the event that you would like to undergo private testing. This can only be done with your explicit consent. We will not include any sensitive information.  For more information on this process, our affiliated laboratories and their privacy policies please contact our Data Protection Officer at info@angeliquepanagos.com.

We will always 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 or through online forums.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. WHAT ARE YOUR RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data, where we are not required to retain it by law or in accordance with the BANT and CNHC guidelines.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

You can see more about these rights at:  https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ 

If you wish to exercise any of the rights set out above, please email us at info@angeliquepanagos.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. WHAT SAFEGUARDS ARE IN PLACE TO ENSURE DATA THAT IDENTIFIES ME IS SECURE?

We only use the information that we have relating to 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 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 laptops and computers. 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.

9. COOKIES

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