We, Joanna Bannerman and Lisa Ryan, trading, as sole traders under umbrella name “One Step Wellness”, hold some personal information about you. This document outlines how that information is used, who we share that information with and how we keep it secure. We are happy to provide any additional information or explanation, or, if you would like to see a copy of our data protection policy, then please e-mail us at info@onestepwellness.co.uk. This Privacy Notice is kept under regular review.

1. What we do

We provide nutritional therapy, personal training and life coaching advice to clients to improve their health through diet, exercise and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through our nutritional therapy, personal training and life coaching consultations, dietary and lifestyle analysis and on occasion possible biochemical testing, we endeavour to understand the potential underlying factors of your health issues which we then seek to address through personalised dietary therapy, nutraceutical prescription (supplements), personal training advice and lifestyle advice.

2. How we obtain your personal data

You provide us with personal data in any of the following ways:

• By completing a nutritional therapy health questionnaire
• By signing a terms of engagement form
• During a nutritional therapy consultation
• By signing a coaching agreement
• By completing a PARQ (Physical Activity Readiness Questionnaire, short and long version)
• By completing a client/trainer agreement
• By completing an informed consent form
• During a Life Coaching or a Personal Training consultation
• Through email, over the telephone or by post
• By making a payment to us for the service

This may include the following information:

• Name, address, contact details, next of kin, GP name and address
• Details 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
• Bank details

We use this information in order to provide you with direct healthcare. This means that the legal basis of us holding your personal data is for legitimate interest.

3. How we use your personal data

We are the data controller for use of your personal data to provide direct healthcare. We also act as a controller and processor in the processing of your data from third parties such as testing companies and other healthcare providers. We act as a data controller and processor to the processing of some credit card and online payments.

We strive 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 take all 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: this is subject to you giving us your express consent.

4. Do you share my information with other organisations?

We keep all information about you confidential, we will only disclose your information with other third parties with your express consent except for the following categories of third parties:

• Our registrant body, CNHC, and our professional associations, BANT, CIMSPA, 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 information about you with supplement and biochemical testing companies as part of providing you with direct healthcare.

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 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 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, 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 info@onestepwellness.co.uk

Under special circumstance, 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 purpose 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, CNHC and CIMSPA guidelines.
• Receive a copy of your personal data, which you have the 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 decisions based on your personal data.

6. How do you keep my data 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 must 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 (locked filing cabinet in a locked office – unless it is in transit between locations e.g. from home office to therapy centre), restrict access to information to authorised personnel only, protect personal and confidential information held on laptops with password encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support our business 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.

If information is emailed between ourselves and you as a client, it is done so in the knowledge that email as a form of communication is inherently insecure even when accounts are password protected.

We, Joanna Bannerman and Lisa Ryan, trading as One Step Wellness, are registered with the Information Commissioner’s Office (ICO) as a data controller and collect 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 written records held by ourselves will be kept for the duration specified by guidance from the professional association BANT which is currently 8 years.

8. Website technical details

The website www.onestepwellness.co.uk uses cookies to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. We use Google Analytics to analyse this data for website improvement and SEO purposes.

We do not make use of cookies to collect any private or personally identifiable information. The technical platform of our 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.

Advance areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information.
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. Making a complaint

If you have a complaint regarding the use of your personal data, then please contact us by email at info@onestepwellness.co.uk.

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 0303 1231113.