Author: alex

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.

Our internal CFM data sharing policy

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.

4. Do you share my information with other organisations?

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. 

Alex Wilber, PhD

In my previous career as a physicist, I was involved in the development of many medical and diagnostic devices, such as blood glucose monitors for diabetes.

We decided to explore what new biological sensors might be useful for doctors. So, we obtained a list of the most significant diseases in the developed world, and started building our understanding of them.

What I learned shocked me at the time – of the 20 diseases in our list, 18 were known to be “inflammatory” diseases, meaning that they were connected to an inappropriate immune response in the body. This included diseases like heart disease, diabetes and even depression, which I would never have connected to the immune system before.

What was more, rates of all these diseases were increasing rapidly. As I dived into the scientific literature, it became clear that rates of “chronic inflammation” were known to be increasing. However, addressing this underlying inflammation was in no way a focus of mainstream health efforts.

We can think of inflammation as representing an “alarm state” in the body. When the body sees itself as under threat, it prioritises short-term defence over long-term maintenance. This is fine – unless the threat lasts for decades.

The scientific literature on the subject is, in fact, vast and relatively uncontroversial. Inflammation is known to be caused by many aspects of modern life – processed food, chronic stress, an unbalanced microbiome, and many more – and in turn is known to play a causal role in almost all of the chronic diseases that affect so many of us, including metabolic syndrome and obesity.

However, all these interactions are very individual. For one person, a diet high in processed food can lead to serious health problems, while the next may be unaffected – and the same goes for stress, sleep and all the other factors of modern life. Then, if chronic inflammation is triggered, the effects also vary hugely. One person may develop arthritis, the next heart disease; one person may be overweight while the next may struggle with their mental health. And of course, this is a simplification. Inflammation is hugely complex, and many other factors also play a role.

Addressing the root causes is clearly the answer. But because of how much things vary from person to person, a personalised approach is the only way to go. There’s no one-size-fits-all answer, and no drug is going to fix the underlying issues.

As I came to understand these connections, making a difference on this front seemed hugely more important than anything I might achieve in my work on medical devices. So, I decided to make a change.

Through incredible luck, Lydia and Stephanie were eager to make the same leap. Together, we’ve committed our careers to this new approach. Our goal is to help as many people as we can, and to spread the message as far we’re able. We hope we’ll be able to help you.

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

This Privacy Policy describes the policies of Cambridge Functional Medicine Ltd (registered address: 28 High Street, Bidford on Avon, Warwickshire B50 4EE, United Kingdom) on the collection, use and disclosure of your information that we collect when you use our website (http://www.cambridgefunctionalmedicine.co.uk) (the “Service”).

This policy relates only to the use of the website; a separate policy applies for information collected from clients as part of the practitioner-client relationship. By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

1. Information We Collect

When you use our website, you may voluntarily choose to give us your personal information (for example, by filling in forms). Our collection of your personal information requires direct action by you.

We may collect your personal information through the following avenues:

• If you fill in our ‘Contact Us’ form
• If you make a booking through our ‘Booking’ page
• If you email us
• If you comment on our blog

We may collect and process the following personal information about you:

• Name
• Email
• Phone number
• Any further information, such as health information, that you choose to provide us with by email or via our online form(s).

In addition, when visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service Privacy Policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

2. How we use your information

We may use the information that we collect about you for the following purposes:

• Marketing/Promotional
• Customer feedback collection
• User to user comments
• To provide you with our services; for example, to answer your queries, or to make a booking with our clinic and provide you with an appropriate service at your booked appointment.

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent, and then only for the purpose(s) for which you grant consent, unless we are required to do otherwise by law.

We undertake to protect your personal data in a manner which is consistent with the requirements of the UK GDPR concerning data protection.

We may disclose your personal information to third-party services that are engaged by us to perform services to us or on our behalf. Third-party services are only permitted to use your personal data for the purpose for which it was provided. We use the third-party service ‘Practice Better’, an electronic practice management tool, to manage our clinic bookings from our Bookings page. Practice Better have an independent Privacy Policy that you may wish to review: https://practicebetter.io/privacy/.

Please note that your personal data may be handled through servers outside the UK/EU.

3. Retention of your information

We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. If you subsequently become a client of our clinic then we will retain your personal information for as long as is necessary and legally appropriate given the provision our provision of services to you, and the terms of this will be detailed in a separate Privacy Notice that you will review prior to engaging our services. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

If you leave a comment, the comment and its metadata are retained indefinitely. This is to preserve the context of conversations in comments, and so that we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

4. Your rights

Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us via our “Contact Us” page. We will respond to your request in accordance with applicable law.

You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by writing to us via our “Contact Us” page.

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

5. Cookies etc.

Like most websites, the Service uses cookies to capture certain information including about how the Website is used.

When you use the Service we set Google Analytics cookies to measure the number of visitors, to see how visitors navigate the site and to see which resources they access. This helps us to improve the way the Service works. To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.

By continuing to use this Website, you consent to the relevant cookies being set on your device.

For general information about cookies and how to disable them, please visit http://www.allaboutcookies.org.

6. Security

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

7. Third party links and use of your information

Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Visitor comments may be checked through an automated spam detection service.

8. Grievance / Data Protection Officer

If you have any queries or concerns about the processing of your information that is available with us, you may write to our Grievance Officer at Cambridge Functional Medicine Ltd, 28 High Street, Bidford on Avon, or online via our “Contact Us” page. We will address your concerns in accordance with applicable law.