Privacy Policy

The content on this website/blog is for informational purposes only and is not intended to be a substitute for medical advice, diagnosis or treatment. BioNourish Limited (Meg Kennedy) makes no representations as to the accuracy or completeness of any information on this site or found by following any link on this site. This site is not intended for diagnosis, including information regarding which drugs or treatment that may be appropriate for you.

If you sign up as a client, BioNourish Limited (Meg Kennedy) holds some information about you. This document outlines how that information 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 meg@megkennedy.com. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in December 2021.

1) What We Do

BioNourish Limited (Meg Kennedy) provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, workshops and educational seminars, 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. Other activities may include workshops, educational seminars and guided shopping trips.

2) How We Obtain Your Personal Data

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 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 Insurance company. 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.

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 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.

4) Do you share my information with other organisations?

We will keep information about you strictly 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 professional association, Institute of Functional Medicine (IFM), 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 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.

5) What are your rights?

Every individual has the right to see 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 meg@megkennedy.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 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 IFM 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. If you would like to invoke any of the above rights then please write to the Data Controller at meg@megkennedy.com

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 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.

BioNourish Limited (Meg Kennedy) 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 BioNourish Limited (Meg Kennedy) will be kept for the duration specified by guidance from our insurance provider.

8) Website technical detail

Forms

We do use electronic forms on our website making use of an available ‘forms module’ which has several built-in features to help ensure privacy. We also aim to use secure forms where appropriate.

Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.
Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

9) Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

10) Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at meg@megkennedy.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.