Nutrition Path Limited is committed to protecting and respecting your privacy. Using your personal data and the legal basis for processing Nutrition Path Limited will rely on GDPR for the processing of your data. In addition, Nutrition Path Limited will rely one or more of the following basis when sharing personal data:
- Legal obligation: the processing is necessary for compliance with a legal obligation
- Vital interests: the processing is necessary to protect someone’s life.
- Public interest: the processing is necessary to perform a task in the public interest.
- Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third party
When processing special category data for the purposes of;
- Employment, social security and social protection
- Vital interests of the Data Subject
- Substantial public interest
- Provision of health or social care
- Public interest in the area of public health such as protecting against serious cross border threats to health
* This includes the Notice by Secretary of State under Reg 3(4) of Health Service Control of Patient Information Regulations issued 1st April 2020 allowing healthcare providers to share personal data and any other such notice that may be issued to support efforts against COVID-19.
Data Subject Rights
At this current time and following Government advice, we are unable to collect any correspondence sent via post at our address. If you need to get in touch regarding a Subject Access Request (SAR) or other information request wherever possible please contact us via email at: firstname.lastname@example.org Due to the current circumstances, if you submit a SAR or other Data Subjects Rights request, please be aware that you may experience a delay in us responding to your request. That’s because we will be diverting resources to help with other challenges and ensuring the ongoing healthcare and treatment of our patients.
We assure you that all necessary steps will continue to be taken to maintain the security of your personal information and our focus will be to prioritise information flows, to ensure ongoing safe and effective care during these unprecedented times.
What personal data may we collect from you?
When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual. Accordingly, we may hold and use personal data about you as a customer, a patient or in any other capacity, for example, when you visit our websites, complete a form, access our services or speak to us. Personal data we collect from you may include the following:
- information that you give us when you enquire or become a customer or patient of us or apply for a job with us including name, address, contact details (including email address and phone number)
- the name and contact details (including phone number) of your next of kin
- details of referrals, quotes and other contact and correspondence we may have had with you
- details of services and/or treatment you have received from us or which have been received from a third party and referred on to us
- information obtained from customer surveys, promotions and competitions that you have entered or taken part in
- recordings of calls we receive or make
- notes and reports about your health and any treatment and care you have received and/or need, including about clinic and hospital visits and medicines administered
- patient feedback and treatment outcome information you provide
- information about complaints and incidents
- information you give us when you make a payment to us, such as financial or credit card information
- other information received from other sources, including from your use of websites and other digital platforms we operate or the other services we provide, information from business partners, advertising networks, analytics providers, or information provided by other companies who have obtained your permission to share information about you.
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
The data that we request from you may include special category data. This includes information that relates to the following:
- racial or ethnic origin, or
- political opinions, or
- religious or philosophical beliefs, or
- trade union membership, or
- genetic data, biometric data for the purpose of uniquely identifying a natural person, or
- health data,
- or data concerning a natural person’s sex life or sexual orientation.
When do we collect personal data about you? We may collect personal data about you if you:
- visit one of our websites
- enquire about any of our services or treatments
- register to be a customer or patient with us or book to receive any of our services or treatments
- fill in a form or survey for us
- carry out a transaction on our website
- participate in a competition or promotion or other marketing activity
- make online payments
- contact us, for example by email, telephone or social media
- participate in interactive features on any of our websites
In the interests of training and continually improving our services, calls to Nutrition Path Limited and its agents may be monitored or recorded. Private calls to and from patients in our hospitals are not recorded. What personal data we may receive from third parties and other sources? We may collect personal data about you from third parties such as:
- If you are an employee of one of our corporate clients who has taken up one of our services, we may be passed your name, contact number and email address, in order to get in touch with you to arrange an appointment or collect further information from you;
- We have a number of independent third parties acting on our behalf who may collect personal data from you to allow us to carry out the services we offer e.g. an independent physiotherapist may carry out your initial Triage call or a subsequent consultation and collect personal data from you which is subsequently shared with Nutrition Path Limited for the continuity of your care and may be used for quality and monitoring purposes;
- Your work/business contact information e.g. name, job title, address, email, contact number, which may have been collected from agencies, partner organisations or other third parties, for the purpose of business to business marketing activity, to allow Nutrition Path Limited to provide you with direct marketing communication about relevant products or services to you in your professional capacity or your organisation;
- We carry out work on behalf of the NHS and for the continuity of your care we may be passed medical information usually in the form of a referral for the purposes of your treatment with Nutrition Path Limited or a third-party consultant;
- Nutrition Path Limited use the services of independent consultants who carry out procedures at Hospitals. Consultants may need to share your personal data and medical records with Nutrition Path Limited;
Insurance providers will pass Nutrition Path Limited personal data of patients who have commenced a claim and require medical treatment with Nutrition Path Limited. This will normally be in the form of a referral and may consist of basic details e.g full name, date of birth, address, contact number and email address and the type of procedure/treatment they require.
How do we lawfully process your personal data?
- necessary to provide you with our services – to enable us to carry out our obligations to you arising from any contract entered into between us and you including relating to the provision by us of services or treatments to you and related matter such as billing, accounting and audit, credit or other payment card verification and anti-fraud screening
- in our or a third party’s legitimate interests to do so
- required or allowed by any applicable law
- with your explicit consent for example: direct consumer marketing communications.
Generally, we will only ask for your consent to processing if there is no other legal grounds to process. In these circumstances, we will always aim to be clear and transparent about why we need your consent and what we are asking it for. Where we are relying on consent to process personal data you have the right to withdraw your consent at any time by contacting us using the details below and we will stop the processing for which consent was obtained. To process special category data we rely on additional legal grounds and generally, they are as follows:
- With your explicit consent
- It is necessary for the purposes of preventive or occupational medicine, to assess whether you are able to work, medical diagnosis, to provide health or social care treatment, or to manage health or social care systems and services. This may also include monitoring whether the quality of our services or treatment is meeting expectations
- It is necessary to establish, make or defend legal claims or court action
- It is necessary so that we can comply with employment law
- It is necessary for a public interest purpose in line with any laws that are applicable. This should assist in protecting the public against dishonesty, malpractice or other seriously improper behaviour for example, investigating complaints, clinical concerns, regulatory breaches or investigations e.g the Care Quality Commission or GMC or ICO.
Processing of personal data which you have made public:
As stated above, one of the legal grounds for processing data is where it is in our legitimate interest to do so, taking into account your interest’s rights and freedoms. This allows us to manage the relationship that exists between you and us and can include the following reasons:
- provide you with information, products or services that you request from us
- managing all aspects of our relationship with you, our products and services and any third parties who may provide products or services on our behalf
- allow you to participate in interactive features of our services, when you choose to do so
- notify you about changes to our products or services
- keep our records up to date
- respond to requests where we have a legal or regulatory obligation to do so
- check the accuracy of information about you and the quality of your treatment or care, including auditing medical and billing information for insurance claims as well as part of any claims or litigation process
- support your doctor, nurse or other healthcare professional
- assess the quality and/or type of care you have received (including giving you the opportunity to complete customer satisfaction surveys) and any concerns or complaints you may raise, so that these can be properly investigated
- to conduct and analyse market research
- to ensure that content from any of our websites is presented in the most effective manner for you and for your computer
- to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations including to defend ourselves from claims, exercise our rights and adhere to laws and regulations that apply to us and the third parties we work with
- to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part our business
- to administer your account on our Digital Wellbeing Platform and allow you to login into it, if you have one
- to personalise the marketing emails we send you, where you have consented to us doing so
The security of your personal data
How long do we retain your personal data?
Unless we explain otherwise to you, we will retain your personal data on the basis of the following guidelines:
- for as long as we have a reasonable business need, such as managing our relationship with you and managing our business
- for as long as we provide services and/or treatment to you and then for as long as someone could bring a claim against us (in general this is a period of 8 years); and/or
- in line with legal and regulatory requirements or guidance.
Disclosure of your personal data to third parties
In the usual course of our business we may disclose your personal data (which will be limited to the extent reasonably necessary) to certain third party organisations that we use to support the delivery of our services. This may include the following:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with you,
- organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored,
- third party debt collectors for the purposes of debt collection,
- delivery companies for the purposes of transportation,
- third party service providers for the purposes of storage of information and confidential destruction, third party marketing companies for the purpose of sending marketing emails, subject to having an appropriate lawful basis for such processing.
Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws. We may also disclose your personal data to third parties in the event that we sell or buy any business or assets or where we are required by law to do so.
Special Category/Health information collected during provision of treatment or services
Independent Healthcare Providers – Performance Information
In the interest in providing comparable clinical outcome and performance data to the public across independent sector providers in healthcare, we – like all independent hospital operators – are required by law to provide activity data, including some personal data, as set out in more detail below, for publication by The Private Healthcare Information Network (PHIN). PHIN is responsible for collecting, processing and publishing information on the quality and cost of privately-funded healthcare in the UK. The publication of this information is intended to:
- provide GPs with reliable information to inform their decisions about which providers to choose
- help future patients make informed choices about where to seek treatment
- enable providers of care (hospitals and consultant clinicians) to improve the quality and safety of their services by better understanding their performance by comparison with other providers
- to support regulator information to help identify any causes of concern
- enabling them to target inspections and help ensure safer care for patients.
Providers must provide PHIN with details of each episode of care, including a summary of each record of treatment including; the dates when each patient was in hospital, what treatment was carried out and by whom. Providers are also required to provide: patient satisfaction survey data, Patient Reported Outcome Measures (PROMS) – patient reported health improvements following treatment and details of any adverse events relating to the patients treated. Certain personal data will be provided to PHIN, including patients postcode of residence. PHIN securely submits such data and records to information authorities such as:
- for England, NHS digital;
- for Wales, the NHS Wales Informatics Service;
- for Scotland, the Information and Statistics Division;
- for Northern Ireland, the Health and Social Care Board; and
- for UK-wide mortality data, the Office of National Statistics.
PHIN will only disclose records of care and personal data to the non-departmental bodies/authorities identified above, as required by law or where there is an overriding public interest, and /or to investigate or prevent fraud. Data Protection Laws give all individuals the right to make a ‘Subject Access Request’ to obtain a copy of any information that any organisation holds about them (as set out in more detail below). As PHIN cannot identify individuals from the data it holds, applicants would need to provide further proof of identity in order to access whether it is possible to access any information held. Further information about how PHIN uses information, including its Privacy Notice, is available at: www.phin.org.uk.
National Data Opt-Out
The national data opt-out is an NHS Digital service which allows an NHS patient to opt out of their confidential patient information being used for research and planning. Further information on the National Data Opt-Out programme can be found here: https://digital.nhs.uk/services/national-data-opt-out-programme
What do we do with any non-personal information collected when accessing the website?
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
These cookies are essential in order to enable you to move around our websites and use its features, such as accessing secure areas of the websites. Without these cookies, services you have asked for cannot be provided. Your consent is not required for the delivery of those cookies which are strictly necessary to provide services requested by you. We use these types of cookies.
These cookies allow our websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect is generally anonymised and they cannot track your browsing activity on other websites. We use these types of cookies, but you are able as a user to follow the link below and manage whether or not they are implemented on your device. Cookie Settings
Nutrition Path Limited carries out two types of direct marketing: 1) Business to Consumer (B2C) which means, if you engage with Nutrition Path Limited in your capacity as an individual i.e. you are a client, then we may process your personal data for marketing purposes but only if we have your prior consent to do so; and 2) Business to Business (B2B) which means, if you engage with Nutrition Path Limited in your professional capacity e.g. if you represent a company with whom Nutrition Path Limited has an existing or prospective business relationship, Nutrition Path Limited may keep you up to date with services we offer/provide.
Business to Consumer (B2C)
Business to Business (B2B)
Whether you have received a B2C marketing communication or a B2B marketing communication you will have the right to ask us to stop sending you marketing communication. B2B customers will have the right to opt out of receiving any further specific marketing communication at any time. Our marketing emails will include an unsubscribe option which you can select or, If you no longer wish to receive web based marketing information you can unsubscribe by emailing email@example.com. For non-web based marketing information please email to: firstname.lastname@example.org. Please note, you only need to withdraw your consent once and this withdraws your consent to receive marketing B2C and opts you out of receiving further B2B marketing. You may also receive service communications from time to time which will not include an unsubscribe option as they are not considered marketing communication and will remain unaffected by your marketing preferences. We would ask you to give us a reasonable amount of notice, to give us time to update our systems. While the precise timings vary by department we generally ask that you give us at least 30 days’ notice.
Many of our premises are surveyed by CCTV for the purposes of security and ensuring the health and safety of our members, patients, staff and guests. Images and videos may will be retained for 30 days in accordance with ICO guidelines.
Your Rights under Data Protection Laws
The law gives you certain rights in respect of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs. The website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth of useful information in respect of your rights in your personal data. In addition to your right to stop marketing, detailed above, below is a short overview of the most commonly-used rights.
- Data Subject Access Request – With some exceptions designed to protect the rights of others you have the right to a copy of the personal data that we hold about you as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
- The Right of Erasure (‘Right to be Forgotten’) – the right to have your personal information erased where we have no reason to continue processing;
- Data Portability – the right to move, copy or transfer personal information you have provided to us;
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
- Right to Rectification – You have the right to have the personal data we hold about you corrected if it is factually inaccurate. It is important to understand that this right does not extend to matters of opinion, such as medical diagnoses. If any of your personal data has changed, especially contact information such as: email address, postal address and phone number please get in touch with us at email@example.com
If you want to exercise your rights in respect of your personal data, the best way to do so is to contact us by email on firstname.lastname@example.org, In order to protect your privacy, we may ask you to prove your identity before we take any steps in response to such a request. If you are not satisfied with how we handle your request, you can contact the at email@example.com