Client Privacy Notice

Last Updated On 08-Nov-2021
Effective Date 08-Nov-2021

The following section describes how your data is handled by Cambridge Functional Medicine Ltd (CFM), and your rights regarding this. By agreeing to these Terms of Engagement, you agree to the following use of your data.

Engaging services with Cambridge Functional Medicine Ltd (CFM) requires CFM to gather and store information about you. This Privacy Notice outlines how that information is gathered and 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 additional information or explanation if needed. Requests should be sent to our “Contact Us” page. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in November 2021.

1. What We Do

CFM provides Nutritional Therapy services to clients to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, i.e., the optimisation of physical and mental health 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. (Please see ‘Part 1: The Nutritional Therapy Descriptor’ within our Terms of Engagement for a more complete explanation.)

CFM also engages in other activities outside the clinic with the purpose of disseminating information relevant to nutrition and lifestyle medicine: for example, creating and publishing online resources, and giving educational talks.

2. How We Obtain Your Personal Data

Information provided by you

You provide us with personal data in the following ways:

By completing Nutritional Therapy questionnaires
By signing a Terms of Engagement form
During a Nutritional Therapy consultation
Through email, video, over the telephone or by post
In the ‘Practice Better’ platform through instant messaging, document upload, or completion of forms (see later section on third-party services)
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 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 our services to you, we retain your personal data for the period defined by our professional association BANT and our 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.

Information we get from other sources

We may obtain sensitive medical information in the form of test results from testing companies. We use this information 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 regarding the processing of your data from third parties such as testing companies and other healthcare providers. We act as a data controller and may act as a data processor regarding the processing of payments. Note that if you pay online via Practice Better, as is our standard arrangement, we will never see your payment information.

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 UK GDPR concerning data protection. We 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., to safeguard an individual, or to prevent a serious crime. Also, we may provide your personal data where there is a legal requirement such as a formal court order. We do not use your data for marketing purposes without your express consent.

At CFM, it is standard for us to discuss aspects of cases under anonymisation between practitioners. This helps us to provide you with a better service because it means we can share expertise, discuss clinical approaches, and make sure you benefit fully from the collective experience of the team. All discussions take place in confidence and are conducted with respect.

As we are a small business, as an extra precaution, if we know you are personally acquainted with another practitioner at CFM, we will not discuss any details of your case with that practitioner unless you have specifically indicated that you would be happy for this to occur. If you would not like your anonymised case to be discussed with a specific practitioner or practitioner(s), please let us know who you would like this exclusion to apply to. You may send us this information through our “Contact Us” page or contact your practitioner directly.

We respect your privacy and handle your personal information with care. We will only disclose your information with 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 contractors and advisors that provide a service to us 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 (eg, CNHC) if we have a duty to do so or if the law requires us to do so

We use third-party services outside of the UK and EU to manage your personal information. Our standard practice is to store your information using the Practice Better platform as part of providing you with direct healthcare using the legal basis of legitimate interest. At the time of last review, Practice Better state the use of data servers in Canada and the US. Practice Better have an independent Privacy Policy you may wish to review: https://practicebetter.io/privacy/.

We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. If you consent to undertake functional testing, then we will share your relevant information with a relevant testing company such that we can arrange this test for you. The biochemical testing company may be international.

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 vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

We will share your sensitive information with your GP or other healthcare provider if you have given us express consent to do this, and you have provided us with the relevant contact details.

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 seek your explicit consent before sharing your data in this way.

5. What are your rights?

You have the right to see, amend, delete, or have a copy of data held by CFM 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 via our “Contact Us” page. 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 (or have shared) 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 BANT and CNHC 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 decisions based on your personal data.

If you would like to invoke any of the above rights then please write to the Data Controller at Cambridge Functional Medicine Ltd, 28 High Street, Bidford-on-Avon, B50 4AA, or online via our “Contact Us” page.

6. What safeguards are in place to ensure data that identifies me is secure?

We only use information that may identify you in accordance with UK GDPR. This requires us to process personal data only if there is a legitimate basis for doing so, and states that any processing must be fair and lawful.

Within the health sector, we also 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 suitable security measures. We will only appoint external data processors to support us if these processors can provide sufficient evidence of addressing the guidelines set out by UK GDPR that the rights of data subjects will be respected and protected, where data that could or does identify a person are processed.

CFM 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 CFM will be kept for the duration specified by guidance from our professional association BANT.

8. Website and third-party service providers

The Privacy Policy for our clinic website (www.cambridgefunctionalmedicine.co.uk) is available at www.cambridgefunctionalmedicine.co.uk/privacy-policy/.

We use a third-party service, Practice Better, to provide you with your client portal. Practice Better is an electronic practice management tool which stores health records, appointment information, and communication between practitioners and clients. Practice Better has a separate Privacy Policy (viewable at https://practicebetter.io/privacy/).

Both policies also detail the use of cookies by these websites.

9. Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Cambridge Functional Medicine Ltd, 28 High Street, Bidford-on-Avon, B50 4AA, or online via our “Contact Us” page 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.