1 Introduction
1.1 Purpose of Policy
This policy describes how personal data will be collected, handled and stored to comply with
the UK General Data Protection Regulation.
If you would like any clarification on the details set out below, please contact
sam@bodypsychnutrition.com. This policy is kept under regular review. It was last
reviewed in September 2022.
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1.2 Policy Statement
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BodyPsych Nutrition is committed to a policy of protecting the rights and privacy of clients,
staff and others in accordance with UK General Data Protection Regulation.
BodyPsych Nutrition commits to:
ï‚· comply with both the law and good practice
ï‚· respect individuals’ rights
ï‚· be open and honest with individuals whose data is held
ï‚· Register our details with the Information Commissioner’s Office (ICO)
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1.3 Personal Data
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BodyPsych Nutrition may hold data for the following purposes:
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- Provision of direct healthcare
- Marketing and newsletters
- Case histories
Special categories of data included race, ethnic origin, politics, religion, trade union
membership, genetics, biometrics (where used for ID purposes), health and sexual
orientation. BodyPsych Nutrition may hold special category data for the following purposes:
- Provision of direct healthcare
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1.4 Data Protection Principles
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There are six data protection principles that are core to the UK General Data Protection
Regulation BodyPsych Nutrition will make every possible effort to comply with these
principles at all times in our information-handling practices. The principles are:
1) Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and
transparent as to how the data will be used.
2) Limited for its purpose
Data can only be collected for a specific purpose.
3) Data minimisation
Any data collected must be necessary and not excessive for its purpose.
4) Accurate
The data we hold must be accurate and kept up to date.
5) Retention
We cannot store data longer than necessary.
6) Integrity and confidentiality
The data we hold must be kept safe and secure.
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1.5 Key risks
The main risks are in two key areas:
ï‚· information about individuals getting into the wrong hands, through poor security or
inappropriate disclosure of information
ï‚· individuals being harmed through data being inaccurate or insufficient
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2 Responsibilities
BodyPsych Nutrition is the data controller for all personal data held by us and is responsible
for:
• Analysing and documenting the type of personal data we hold
• Checking procedures to ensure they cover all the rights of the individual
• Identifying the lawful basis for processing data
• Ensuring consent procedures are lawful
• Implementing and reviewing procedures to detect, report and investigate
personal data breaches
• Storing data in safe and secure ways
• Assessing the risk that could be posed to individual rights and freedoms should
data be compromised
3 Data Recording, Security and Storage
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3.1 Data accuracy and relevance
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BodyPsych Nutrition will ensure that any personal data we process is accurate, adequate,
relevant and not excessive, given the purpose for which it was obtained. We will not process
personal data obtained for one purpose for any unconnected purpose unless the individual
concerned has agreed to this or would otherwise reasonably expect this.
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3.2 Data security
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BodyPsych Nutrition will keep personal data secure against loss or misuse. Where other
organisations process personal data as a service on our behalf, we will establish what, if
any, additional specific data security arrangements need to be implemented in contracts with
those third-party organisations.
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3.3 Storing data securely
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• In cases when data is stored on printed paper, it will be kept in a secure place
where unauthorised personnel cannot access it
• Printed data will be shredded when it is no longer needed
• Data stored on a computer will be protected by strong passwords that are
changed regularly.
• Cloud services used to store personal data will be assessed for compliance with
UK GDPR principles. An authenticator app will be used to access cloud data.
• Servers containing personal data must be kept in a secure location, away from
general office space
• Data will be regularly backed up.
• All servers containing sensitive data must be protected by security software
• All possible technical measures will be put in place to keep data secure
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3.4 Data retention
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BodyPsych Nutrition will retain personal data for no longer than is necessary. This shall be in
accordance with the guidelines of our professional association, BANT.
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4 Accountability and Transparency
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BodyPsych Nutrition will ensure accountability and transparency in all our use of personal
data. We will keep written up-to-date records of all the data processing activities that we do
and ensure that they comply with each of the UK GDPR principles.
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We will regularly review our data processing activities and implement measures to ensure
privacy by design including data minimisation, pseudonymisation, transparency and
continuously improving security and enhanced privacy procedures.
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5 Consent
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BodyPsych Nutrition will ensure that consents are specific, informed and plain English such
that individuals clearly understand why their information will be collected, who it will be
shared with, and the possible consequences of them agreeing or refusing the proposed
use of the data. Consents will be granular to provide choice as to which data will be
collected and for what purpose. We will seek explicit consent wherever possible.
We will maintain an audit trail of consent by documenting details of consent received
including who consented, when, how, what, if and when they withdraw consent.
For online consent, we may use a cryptographic hash function to support data integrity. Alternatively,
we will maintain the consents information in a spreadsheet with links to the consent forms.
We will regularly review consents and seek to refresh them regularly or if anything changes.
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6 Direct Marketing
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BodyPsych Nutrition will comply with both data protection law and Privacy and Electronic
Communication Regulations 2003 (PECR) when sending electronic marketing messages.
PECR restricts the circumstances in which we can market people and other organisations by
phone, text, email or other electronic means.
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We will seek explicit consent for direct marketing. We will provide a simple way to opt out of
marketing messages and be able to respond to any complaints.
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7 Subject Access Requests
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7.1 What is a subject access request?
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An individual has the right to receive confirmation that their data is being processed, access
to their personal data and supplementary information which means the information which
should be provided in a privacy notice.
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7.2 How to deal with subject access requests
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BodyPsych Nutrition will provide an individual with a copy of the information requested, free
of charge. This will occur within one month of receipt. We endeavour to provide data
subjects access to their information in commonly used electronic formats (as described in
section 7.3).
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If complying with the request is complex or numerous, the deadline can be extended by two
months, but the individual will be informed within one month.
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We can refuse to respond to certain requests, and can, in circumstances of the request
being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity
of data, we can request the individual specify the information they are requesting.
Once a subject access request has been made, we will not change or amend any of the data
that has been requested. Doing so is a criminal offence.
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7.3 Data portability requests
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We will provide the data requested in a structured, commonly used and machine-readable
format. This would normally be a PDF file, although other formats are acceptable. We must
provide this data either to the individual who has requested it, or to the data controller they
have requested it be sent to within one month.
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8 Transferring data internationally
There are restrictions on international transfers of personal data. We will not transfer
personal data abroad without express consent.
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9 Third Parties
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9.1 Using third party controllers and processors
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As a data controller and/or data processor, we will have written contracts in place with any
third-party data controllers (and/or) data processors that we use. The contract will contain
specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we will only appoint processors who can provide sufficient guarantees
under UK GDPR and that the rights of data subjects will be respected and protected.
As a data processor, we will only act on the documented instructions of a controller. We
acknowledge our responsibilities as a data processor under UK GDPR and we will protect
and respect the rights of data subjects.
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9.2 Contracts
Our contracts will comply with the standards set out by the ICO and, where possible, follow
standard contractual clauses. Our contracts with data controllers (and/or) data processors
will set out the subject matter and duration of the processing, the nature and stated purpose
of the processing activities, the types of personal data and categories of data subject, and
the obligations and rights of the controller.
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10 Reporting breaches
​Any breach of this policy or of data protection laws will be reported as soon as practically
possible. This means as soon as we become aware of a breach.
BodyPsych Nutrition has a legal obligation to report any data breaches to UK Supervisory
authority which is the Information Commissioners Officer within 72 hours.