This policy (together with the website Cookie Policy) sets out the basis on which any personal data is collected from you, or that you provide, how it 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 the [email protected].
We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2018.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is MetaWell Ltd.
Information Collected by our Website
- Your personal information is not required to visit this website.
- Any personal information collected is knowingly provided by you and only required when you use the form on the ‘Contact‘ page to send MetaWell Ltd a message. No personal data collected from this contact form is stored on this website.
- We do not allow ‘comments’ on this website blocking this feature sitewide, therefore no personal data is stored on this website.
- We do not allow visitors to ‘register’ as a ‘user’ on this website, therefore no personal data is stored on this website.
Information Provided by You
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 feedback forms, 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
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.
Following completion of your healthcare we retain your personal data for the period defined by our professional association BANT (British Association for Applied Nutrition & Nutritional Therapy) and registrant body CNHC (Complimentary & Natural Healthcare Council). 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.
Site Visitation Tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor.
GA makes use of cookies, details of which can be found on Google’s developer guides. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website, instructions on how to disable or control Cookies from the most popular browsers can be seen on our Cookie Policy
- Your IP address is a numeric address assigned to your computer, assigned by your Internet service provider. We automatically collect your IP address as traffic data so that we can send information back to you when requested. This is not used to identify your personal information.
- Referrers are references to the web address you linked from and is automatically passed along by your web browser. We collect referrers your browser sends as part of traffic data. This is not attached to personally identifiable information.
- System information such as your operating system/platform, and the type of web browser you use. This is not attached to personally identifiable information.
Links to 3rd Party Data Processors / Websites
MetaWell Ltd includes links to other websites whose privacy practices may differ from those of MetaWell Ltd. If you submit personal information to any of those sites, your information is governed by their privacy statements. It is our suggestion that you carefully read the privacy statement of any website you visit.
Information Use
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 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.
Sharing Data 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 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 (e.g. CNHC) if we have a duty to do so or if the law allows us to do so.
We may share your information with supplement companies and biochemical testing companies 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.
As part of providing you with direct healthcare, we may share your case history in an anonymised form. This may be with our peers, at clinical supervision meetings or online forums.
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 processing your data in this way.
Children’s Privacy
Services/products we supply are intended for general audiences and not for children under the age of 13. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
Website Security
This website takes every precaution to protect visitor’s information. When visitors submit personal information via this website, their information is protected both online and off-line.
Our website uses specialist security software (WP Cerber) to ensure data breaches do not occur. WP Cerber protects and monitors web traffic and web server logs, WP Cerber blocks potential hacks and notifies our IT support instantly should there be any hack or breach.
Should our website be hacked, no personal data can be compromised, no personal data is stored on our website, either by contact forms, user registration or comments.
Data Security
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, 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). 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.
MetaWell 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).
Right to Access, Data Portability & Right to Be Forgotten
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 [email protected]. 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 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 decision based on your personal data.
If you would like to invoke any of the above rights then please email Minna Wood at [email protected].
Retention of your Information
All records held by the MetaWell will be kept for the duration specified by guidance from our professional association BANT.
Complaints
If you have a complaint regarding the use of your personal data then please contact us by emailing Minna Wood at [email protected] 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.
Changes to our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on this website and you will be deemed to have accepted the terms of the Privacy Policy on your first use of this website following the alterations. We recommend that you check this page regularly to keep up-to-date.