At Functional Medicine Associates we are strongly committed to protecting the privacy of your information any information and providing a safe and secure environment for our users. Any information about you is collected lawfully and in accordance with the GDPR (General Data Protection Regulation).
Functional Medicine Associates Ltd 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 or registration reference ZA127466).
This document informs you of our policies regarding the collection, use and disclosure of personal information when you use our website and/or our services. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation if needed. Any requests for this should be sent to firstname.lastname@example.org
We offer functional medicine consultations and biochemical testing in order to get to the underlying causes of a patient’s health issues. During a consultation dietary and lifestyle factors are examined in detail alongside past and current medical history. This information together with the results of any testing carried out testing is used to provide a personalised programme which may include dietary and lifestyle advice, exercise, supplements etc.
We also provide corporate well-being programmes as part of our service.
We collect information from you when you fill out a form or enter information on our site or when you engage our services as a patient/client.
As a patient of ours, you provide us with personal data in a number of ways. For example, by completing detailed medical and health questionnaires using the secure online medical platform Living Matrix (https://livingmatrix.com). You may also provide us with contact details such as phone number or email address when you make an enquiry with us. Information may also be taken for the purposes of billing. Information is also provided by you during a consultation whether this be virtually or face to face.
We use this information in order to provide you with direct healthcare and we hold the information on our system whilst you are under our care and for a period of 7 years after this. This means that the legal basis of our holding your personal data is for legitimate interest. If at any time after you no longer require our services, you can ask to have your data removed by contacting us on email@example.com
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.
Depending on your settings or the privacy policies for other online services, you may give us permission to obtain information from your account with those other services such as analytics providers, advertising networks and search information providers. For example, this can be via social media or by choosing to send us your location data when accessing our Site from your smartphone. Upon acceptance of our policy, we can track your behaviour on our Site from social media, direct, referral, organic or email traffic using Facebook Pixel and Google Analytics. We may also receive personal data about you from public sources.
We act as a data controller for use of your personal data to provide direct healthcare. We use this information to follow-up with you after correspondence (responding to an email or phone enquiry) and to support your treatment programme once you have engaged as a patient.
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 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.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
• Pete Williams, Functional Medicine Practitioner
• Despina Giannapolou, Functional Medicine Practitioner
• Deirdre Nazareth, Functional Medicine Practitioner
• Shelley Williams, Practice Manager
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:
• 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 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.
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.
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@example.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 firstname.lastname@example.org
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.
Non-sensitive details (e.g. your name and email address) are sent normally over the internet and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our clients/customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients/customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
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If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller by emailing email@example.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.